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Bank of America

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FY2019 Annual Report · Bank of America
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Bank of America 2019 Annual Report

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What would you like 
the power to do?® 

Annual Report 2019  

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Bank of America 2019 Annual Report

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CONTENTS 

01  A letter from Chairman and CEO 

Brian Moynihan: Responsible Growth 
drove our performance in 2019 

07 

 A message from Lead Independent  
Director Jack Bovender 

09   A message from Brian Moynihan: 

Responsible Growth and stakeholder 
capitalism in action 

14  Q&A with Dean Athanasia: 

Consumer & Small Business priorities 

16  Q&A with Katy Knox and Andy Sieg: 
Transforming wealth management 

18  Personalized banking, digitally delivered 

19  Building rewarding relationships 

20  Making financial lives better in 
underserved communities 

21  Market presidents deliver the bank 

22  Q&A with Tom Montag: 

Global Banking and Global Markets 

23  Powerful CashPro® platform 

24  Q&A with Anne Finucane: 

Addressing society’s biggest challenges 

27  A world of ESG innovation 

28 

Investing to improve the environment 

29  Driving economic mobility: 
one community’s story 

30 

32 

Diversity at work and in our communities 

Creating opportunities through employee 
development 

34  Supporting teammates in moments 

that matter 

35  Partnering to end AIDS 

35 

Courageous conversations 

36 

Total rewards 

37  Funding the power to dream 

37  2019 Human Capital Management Report 

38  2019 ESG highlights 

40  Financial highlights 

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Bank of America 2019 Annual Report

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A letter from Chairman and CEO Brian Moynihan: 
Responsible Growth drove our performance in 2019 

To our shareholders and clients,  
To my teammates,  
To leaders and partners in the communities we serve  
across the U.S. and around the world,  

I am pleased to share the 2019 Bank of America Annual Report with  
you. In this report, my teammates and I share highlights of the progress  
our company made during the year, which capped off a decade of  
growth for our company and for the U.S. and global economy.  

In 2019, your company followed its Responsible 
Growth operating principles and delivered $27.4 billion 
in earnings, or $2.75 per share. After adjusting for a 
third-quarter non-cash impairment charge, we earned 
$29.1 billion.1 That adjusted figure exceeded our record 
2018 results. We returned more than $34 billion in capital 
to you, our shareholders, including $28 billion in share 
buybacks and $6 billion in common dividends. We raised 
the annual dividend by 22%, from $0.54 to $0.66 cents 
per share. Through our capital deployment over the last 
few years, we reduced the number of outstanding shares 
to below 9 billion last year, 2.5 billion fewer than at the 
peak. We committed to you that we would wring out 
the share dilution caused by the increased capital levels 
required under the new capital rules and the shares we 
issued to rebuild our base of capital last decade. We 
remain committed to that reduction and will accomplish 
it while continuing to invest in our company. 

We enter 2020 with strength and momentum after a 
decade of transformative change. Our capital, liquidity 
and capacity to serve clients are excellent, and we are 
delivering strong earnings. Our products are best in 
class, and we continue to improve them. Our team gets 
stronger every day, as we continue to invest heavily to 
make sure we are the best place to work. 

Over the course of the decade that just ended, we 
earned $127 billion and returned $97 billion to you, 
our common shareholders, and $111 billion to you and 
our preferred shareholders together. The rest is in our 
capital base to serve our customers. Our stock returns 
have also been strong and you can see our one-, three-
and five-year charts below. We have balanced our risk 
and streamlined our company, and our returns are well 
in excess of our cost of capital. 

What a difference a decade makes. 

1-year stock 
performance2 

3-year stock 
performance2 

5-year stock 
performance2 

96.9% 

59.4% 

60.1% 

56.9% 

52.7% 

43.8% 

42.9% 

44.4%  44.3% 

28.9% 

32.1%

35.9% 

22.3% 

23.5%

22.1% 

DJIA 

S&P 
500 

BKX 
Index 

U.S. LC  BAC 
Peers 

DJIA 

S&P 
500 

BKX 
Index 

U.S. LC  BAC 
Peers 

DJIA 

S&P 
500 

BKX 
Index 

U.S. LC  BAC 
Peers 

1 The $29.1 billion net income represents a non-GAAP financial measure, as it excludes the third-quarter $2.1 billion pre-tax, $1.7 billion after-tax, 
non-cash impairment charge related to the notice of termination of our merchant services joint venture which increased noninterest expense and 
is included in the reported net income of $27.4 billion. 
2 U.S. large cap (LC) peers include JPM, C, WFC, GS, and MS. 

BANK OF AMERICA 2019   |   1
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Client activity was strong across all business lines, 
allowing the benefits of our growth in loans and 
deposits to offset the impact of lower rates. 

Total loans and leases 
(billions)

Total deposits 
(trillions)

Those accomplishments are due to our team. It starts 
with our dedicated group of independent directors, 
led by Jack Bovender, our lead independent director. 
You can see the board’s commitment to our strategy in 
Jack’s letter on page 7 of this report. I thank Jack for his 
board leadership; his term runs through our 2021 annual 
meeting. Jack’s leadership is stellar, and his eventual 
successor will have big shoes to fill. 

Our team includes the 208,000 teammates who work 
tirelessly every day to serve our customers well and 
deliver the returns for you. They are led by a talented 
management team, many of whom share their insights 
about our company in this report. I thank the board and 
the management team for the work they do on behalf of 
our company. 

At Bank of America, we focus on results and we 
focus on how we deliver them. One of the things we 
should all be proud of is how we have delivered for our 
traditional stakeholders, customers, teammates and 
shareholders, and how we delivered for the broader 
society at the same time. A concept we embrace — the 
“genius of the and”3 — applies to how we are delivering 

for customers, for teammates, for shareholders, 
AND for our communities and the society in which 
we operate. 

In a separate note on page 9 of this report, I offer a 
more extended discussion that addresses questions 
being raised about whether the challenges we face are 
so profound that our capitalist system itself is incapable 
of addressing them. 

While we must acknowledge and address some short-
comings within our capitalist system, I will discuss our 
belief at Bank of America that the remedies to these 
shortcomings are found within capitalism itself. 

So how does Bank of America produce these results? 
We do it by delivering on Responsible Growth. Let’s 
discuss how we did in 2019. 

Responsible Growth 
Our 208,000 teammates delivered the 2019 results 
I mentioned earlier — $29.1 billion in adjusted earnings 
and $34 billion in capital returns to you — through their 
disciplined focus on Responsible Growth. 

3 This is a concept developed by Jim Collins in his book Built to Last: Successful Habits of Visionary Companies. 

2   |   BANK OF AMERICA 2019
2   |   BANK OF AMERICA 2019

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$897$907$937$947$98320152016201720182019Total loans and leases (billions)$1.20$1.26$1.31$1.38$1.4320152016201720182019Total deposits (trillions)Bank of America 2019 Annual Report

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Responsible Growth has four straightforward tenets: 

We have to grow — no excuses. 

We have to be client focused in our growth. 

We have to grow within our risk appetite. 

And our growth must be sustainable, which has three 
elements: 1) we have to drive operational excellence; 
2) we have to be a great place to work; and 3) we 
have to share our success with our communities. 

Grow and win in the market — no excuses 
The first pillar of Responsible Growth is to grow, no 
excuses. And we did that in 2019. Client activity was 
strong across all business lines, allowing the benefits of 
our growth in loans and deposits to offset the impact 
of lower rates. Average deposits grew $65 billion, or 
5%, year over year. We have grown deposits every 
quarter over the prior year by more than $40 billion for 
nearly five years now. Average loans were up 3% last 
year, again led by Consumer Banking, where average 
loans grew 6%. Dean Athanasia, who leads Consumer 
Banking and Small Business, shares some insights in 
his Q&A on page 14 about how we continue to deliver 
for retail and preferred clients and small business with 
innovation and great service. 

We saw commercial loan growth last year of 4% and 
a 10% increase in our lending to small businesses and 
loans to middle market clients. We are proud this year 
that we became the largest U.S. lender to small busi-
nesses, the lifeblood of the American economy. We also 
became the largest commercial and industrial lender 
in the U.S. Our growth efforts continue to bear fruit as 
we added hundreds of commercial and small business 
bankers across our footprint. And you can rest assured, 
we have done so by staying within our risk appetite, 
as I will discuss below. In a Q&A on page 22, Chief 
Operating Officer Tom Montag discusses the invest-
ments we are making to deepen our client relationships 
and the other opportunities ahead in our Global Banking 
and Global Markets businesses. 

Each of our businesses contributed to our strong earn-
ings last year. And most of them grew their market share 
while producing good bottom-line growth. Consumer 
Banking earned $13 billion last year by deepening rela-
tionships with our clients while we continued to invest 
in infrastructure and client capabilities. Our wealth 
management teams saw net new household growth 
of more than 20% last year, earning record income of 
$4.3 billion with average client deposits up $15 billion. 

Our Global Banking business earned $8.1 billion, and our 
Global Markets business earned $3.5 billion. Combining 
the results for these businesses, as other financial 
services companies report them, would result in 
$11.6 billion for 2019. 

We must grow and 
remain customer focused 
We deliver Responsible Growth by focusing on our 
clients and what they need to live their financial lives. 
All our growth is organic. We call it growth that will stick 
to our ribs, not run off. We are seeing the results of our 
client focus in many areas. Client satisfaction scores 
across our eight lines of business, for instance, are at 
an all-time high. Our brand continues to be very strong. 
We see continued gains in attracting new clients, and 
importantly our current clients continue to do more 
with us. That means we are doing a great job for them. 

Our 65,000-strong team in our consumer businesses 
has grown Consumer Banking checking balances 44 
consecutive quarters. At the end of 2019, Consumer 
Banking held more than $700 billion in deposits. Our 
66 million consumer and small business clients value 
our online and mobile capabilities along with the 
convenience of 4,300 financial centers and more than 
16,800 ATMs. In addition to this high-touch capability, 
our clients value the high-tech capabilities we offer. 
We interact with our clients almost 28 million times 
every day, and 81% of these interactions come from 
our 38 million active digital banking clients. Our clients 
benefit from our investments in artificial intelligence 
(AI) to help personalize their individual financial habits, 
goals and priorities. Clients who use Zelle® for sending 
and receiving money through their mobile phone made 
300 million transfers representing $78 billion last year. 
Our AI-driven digital assistant, Erica®, was launched in 
2018, and we topped 10 million users last year, while 
roughly 10 million clients are active users of Zelle. More 
than 55% of our total consumer client payments are 
made digitally. This is more than $1.6 trillion moved digi-
tally by Bank of America consumer clients each year. 

Of our total deposit transactions, 27% were done 
through our mobile channels, and 79% through mobile 
and ATMs together. More than 50% of our clients 
have gone paperless. Digital channels generated 29% 
of overall sales, with 34% of mortgages and 56% of 
auto loans now originating in our mobile app or online 
banking site. Customers also arranged more than 
2.3 million appointments through digital and mobile in 
2019, up 19% from 2018. This enables our teammates 
in the financial centers to efficiently address the more 
complex needs of their clients in person and contributes 
to a better client experience. 

There is much talk about what happens to traditional 
banks when digitization occurs. You can see that in 
the statistics above. We are enabling our clients, and 
the teammates who serve them, with the best, most 
comprehensive high-tech digital capabilities, while 
investing and advancing high-touch service through 
financial centers and other channels, for an unmatched 

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range of access that reflects the many ways clients 
choose to do business with us. 

Client-centered growth drove our results in our wealth 
management businesses, too. Wealth management 
client balances exceeded $3 trillion for the first time. 
The Bank of America Private Bank saw an increase of 
64% in net new households, while Merrill saw a 25% 
gain. Merrill alone brought in more than 40,000 net 
new affluent households, and we added 60% more 
private bank relationships in 2019 over 2018. Our 
wealth management clients benefit from a high-touch 
and high-tech mix, too. Household mobile usage was 
up 39% in the private bank and 44% in Merrill, and 
we had the most top advisor rankings in the industry. 
For a deeper look at how we are transforming wealth 
management, look for a discussion on page 16 with 
Katy Knox, president of Bank of America Private Bank, 
and Andy Sieg, president of Merrill Lynch Wealth 
Management. 

We’re driving deeper client engagement with our Global 
Banking and Global Markets teams, too. Our teams 
continue to grow loans, adhering to our risk framework 
that is more stringent than industry averages. They 
are growing transaction services fees nicely, too. In 
investment banking, we have gained share of the global 
fee pools with a successful retooling of the business. 

We are the largest U.S. commercial lending business 
and have one of the top market-making and investment 
banking platforms that can deliver for clients globally. 

Global Banking deposits grew $23 billion, a reflection of 
the hundreds of additional relationship bankers we have 
added in the U.S. and globally in the last several years. 
Our Global Markets business serves our clients well and 
last year made money on 98% of the trading days. 

Grow while staying within 
our risk appetite 
Growing within our risk appetite is another tenet of 
Responsible Growth. Our loan losses are at historic lows. 
Asset and credit quality are strong across our consumer 
and commercial portfolios, and our capital and liquidity 
are much higher than a decade ago. Even as we returned 
$34 billion to shareholders last year, our Tier 1 common 
equity ratio was 11.2%, well above our 9.5% minimum 
requirement. We continued to use our operational excel-
lence work to drive operational risk out of the company. 
We are growing the right way. 

TOTAL 
SHAREHOLDER 
RETURN4 
Rolling 5-year 

Bank of 
America 

114.1% 

S&P 500 

73.8% 

U.S. 
Large Cap 
Peer Avg. 

60.5% 

Growing in a sustainable manner 
Earlier I stated the three tenets to growth that is 
sustainable. They are 1) drive operational excellence, 
2) be the best place for teammates to work, and 
3) share our success with our communities. The combi-
nation of delivering all the results I’ve discussed rests 
upon a bedrock of this pillar of Responsible Growth. 
This ensures that we are investing long term, while 
delivering near-term results. This tenet ensures that we 
deliver for all our constituencies. And this tenet ensures 
we have the best team. 

Operational excellence 
Operational excellence generates savings and efficien-
cies that make it possible for us to continue to invest. 
By improving the way we serve clients, streamlining 
our internal processes and creating other efficiencies 
that stem from the thousands of ideas our teammates 
generated last year, we were able to invest in our capa-
bilities even as we managed our expenses consistent 
with the $53 billion target for 2019, which we set in 2016. 
This has been a continuous process of improvement. 

4 Total shareholder return includes stock price appreciation and dividends paid. U.S. large cap (LC) peers include JPM, C, WFC, GS, and MS. 

4   |   BANK OF AMERICA 2019
4   |   BANK OF AMERICA 2019

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Since the beginning of 2010, we have invested $30 billion 
in new technology initiatives, including the mobile and 
digital capabilities we highlight throughout this report. 

In addition, in just the last year, we completed the 
upgrade of our network of more than 16,800 ATMs and 
added 900 new ones, while modernizing more than 
500 of our financial centers and opening 90 new ones. 
We continue to add financial centers in new markets 
starting where we already have wealth management 
and business clients — all made possible by savings 
from our focus on operational excellence. For instance, 
we opened our first financial centers in Ohio in 2019, 
and plan to open more than 30 centers in Cincinnati, 
Columbus and the Cleveland area over the next two 
years. We added about 100 ATMs in the state in the last 
year and a half. 

The investment in our financial centers and ATMs goes 
beyond modernizing existing centers and building new 
ones. It connects all of our client services and experi-
ences and creates the opportunity to build on existing 
relationships, attract new ones and acquaint clients with 
Preferred Rewards, which rewards members for doing 
more with us across their entire banking relationship. 

As our clients’ needs and expectations evolve, the 
financial center client experience and design has to 
evolve with them. Every day, 800,000 clients visit our 
financial centers. The financial centers continue to 
evolve to better serve the range of needs of our clients. 
Last year, we developed 1,500 “One Team” financial 
centers with dedicated wealth management, Business 
Advantage and consumer lending specialists to make 
it easier for clients to connect across all our products 
and services. 

Another example of the type of investment that opera-
tional excellence helps generate is our Aira service—a 
new technology to help blind and low-vision clients gain 
better access to our financial centers and ATMs. Aira 
delivers instant access to visual information at the touch 
of a button. This free service connects these special 
needs clients with visual information on demand. 

At the same time, we are making investments in tech-
nology to optimize the digital experience for chief 
financial officers and treasurers of our corporate clients. 
Some 500,000 clients now use CashPro®, our digital 
application for our business client treasury and lending 
needs. Mobile CashPro logins grew more than 100% 
year over year. Adoption of other new tools relying on 
AI and machine learning for corporate clients is growing 
even faster. 

Even as our team maintained expense discipline over 
the past decade, we continued to invest in our people, 
our technology, infrastructure, buildings and facilities, 

BANK OF AMERICA 2019   |   5
BANK OF AMERICA 2019   |   5

We continue to 
use our operational 
excellence work to 
drive operational risk 
out of the company. 
We are growing the 
right way. 

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and in helping make progress on many societal 
priorities. And — by the way — we made these invest-
ments while returning our excess of our earnings to 
you — $34 billion — through dividends and buybacks. 
A company like ours can invest and manage its capital. 

Here are a few highlights of investments we made for 
2019 alone: 

• We made $1.7 billion in capital investments in new and 
modernized facilities in 2019. This past decade, we 
invested in new buildings in Charlotte, Dallas, Houston, 
Chicago, Paris, Hong Kong and many other markets. 
We modernized more than 1,300 financial centers the 
last three years, and the plan we announced in 2016 
to upgrade and expand our entire financial center and 
ATM network by 2021 is on track. 

• In 2019, we added 3,600 new teammates. We hired 
32,000 employees, including 6,300 new employees 
from low- and moderate-income neighborhoods, and 
4,000 college and MBA graduates. We passed a major 
milestone of our 100-year support for the military, 
and reached our five-year goal to hire 10,000 military 
veterans. 

• For our employees, it was the third consecutive year 

in which we recognized approximately 95% (all but the 
top 5% paid) of our teammates for driving Responsible 
Growth with a special compensation award. (In total, 
more than $1.5 billion in the last three years.) In the 
first quarter of 2020, we raised our minimum starting 
salary to $20 per hour, up from $17 per hour in 2019. 

As you can see, operational excellence allows us to 
deliver industry-leading efficiency, while investing 
heavily. And that serves us well no matter what environ-
ment is ahead of us. 

A great place to work 
Being a great place to work is another driver of sustain-
able Responsible Growth. To provide the best service 
to our clients and to support the communities in which 
we operate, we must continue to attract and retain 
the best talent. Being a great place to work includes 
our ongoing commitment to developing and managing 
talent, employee engagement, equal pay for equal work 
and core values anchored in our commitment to diver-
sity and inclusion. 

In 2019, we published our first Human Capital 
Management Report. Throughout the report, we provide 
detailed information about the actions our company 
has taken for teammates and their families across the 
globe. I encourage you to review it carefully; there is 
additional detail and insight throughout this report 
as well. 

To highlight one area of focus, since 2012, there has 
been no increase in medical premiums for teammates 
earning less than $50,000. For all teammates, we vary 
the medical premium contribution by annual pay level, 
with larger company subsidies for those earning less. 
Also, our average contribution increases since 2012 
have been below national health care trends. Another 
area of focus in the report is the progress we continue 
to make to ensure diverse representation at all levels 
of our company, including a board of directors and 
management team who are more than 45% diverse. 
Additionally, women comprise more than 45% of the 
management team and 40% of the top three levels of 
our company. 

We saw significant internal and external awareness 
for being a great place to work. In 2019, the Diversity 
& Inclusion Index in our 2019 Employee Engagement 
Survey was the highest it has ever been. Bank of 
America also was the top financial institution in the 
2019 LinkedIn Top Companies list, which recognizes 
the most sought-after places to work. 

Sharing success 
One way we share our success is through our local 
market and country teams and their support of 
local partners through community development lending 
and philanthropy. Over the last decade, we have 
provided around $50 billion in community development 
lending, including for priorities in affordable housing 
and economic mobility, and $2 billion in philanthropy. 
Last year alone, we delivered nearly $5 billion in 
community development financing for affordable 
housing and other community priorities, and made 
more than $250 million in philanthropic contributions. 
Our employees directed more than $60 million 
through individual giving and matching gifts and 
logged nearly 2 million volunteer hours to strengthen 
local communities. 

Sharing success also includes the work we do in our 
Environmental Business Initiative. In 2019, we met our 
10-year, $125 billion environmental business initiative— 
six years ahead of schedule. We established a new 
target of $300 billion in clean energy finance by 2030. 
Consistent with the objectives of our Environmental 
Business Initiative, we have met our 2020 goal of 
becoming carbon neutral in our own activities. Look 
for a discussion on page 24 with Vice Chairman Anne 
Finucane, who leads our sustainable development 
work and co-chairs with Tom Montag our broader work 
in sustainable finance, on the leadership we bring to 
driving progress on the societal priorities through our 
core financing and other activities. 

6   |   BANK OF AMERICA 2019
6   |   BANK OF AMERICA 2019

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A message from 
Lead Independent Director 
Jack Bovender 

Dear fellow shareholders, 

As the lead independent director and on behalf of the 
independent directors of Bank of America Corporation, 
thank you for choosing to invest in Bank of America. The 
directors comprise individuals representing a diverse 
range of informed expertise. Sixteen of the 17 directors 
are independent; 65% have CEO-level experience; 
and 35% have senior executive experience at financial 
institutions. 

Your board reviews and approves the company strategy 
as presented by the management team each fall. The 
directors oversee the execution of the strategy by 
engaging in a year-round strategic assessment and 
planning process. Throughout 2019, our dialogue at the 
board and with the company’s management included 
regular review of the company’s adherence to its tenets 

of Responsible Growth, including risk management 
and environmental, social and governance practices. 
We remain abreast of developments in markets, the 
economy and geopolitical issues that may affect 
them. We discuss and assess trends in the financial 
services industry, all with an eye toward ensuring 
the long-term, sustainable value of the company. 

I also meet regularly with shareholders and gather 
viewpoints that I share with the board. This direct 
engagement with shareholders provides feedback 
on executive compensation, capital allocation and 
other important matters. That feedback informs 
our board meeting agendas and helps enhance our 
governance discussions. You will find extensive 
discussion of all of these matters throughout this 
annual report and in our 2020 Proxy Statement. 
I encourage you to review this material carefully. 

On behalf of the directors, I join Chairman and 
CEO Brian Moynihan and the management team 
in thanking you again for your investment in 
our company. 

Sincerely, 

In the United States, one of the important ways 
we engage and share success in the communities we 
serve is through our market president organization. 
Our network of 90 market presidents is responsible 
for leading an integrated team to deliver for clients, 
teammates and the community, serving as the chief 
executive for Bank of America in that market. You will 
see a more detailed discussion of how our market 
president organization does this through the experience 
of Raul Anaya, our Los Angeles market president, on 
page 21. 

External recognition 
Because of our investments in our capabilities and in 
our people, in 2019 we received recognition in many 
areas, including for our products and services, for our 
commitment to our team and to diversity and inclu-
sion, and for our contributions addressing important 
societal priorities. 

We are proud that Global Finance recognized Bank 
of America as the Best Bank in the World in 2019. In 
early 2020, Fortune named your company to its list of 
the 100 Great Places to Work, and as the only global 
financial services firm on its list of the top 18 Best Big 
Companies to Work For. 

Also last year, our research team was recognized as 
Top Global Research Firm by Institutional Investor, an 
honor we held for most of the last decade, including 
each year from 2011 to 2016. 

Global Finance also named Bank of America the 
Best Consumer Digital Bank in America and Money 
magazine ranked us the Best Bank for College Students. 
Reflecting our focus on managing risk well, for ourselves 
and for our clients, we earned prestigious recognition 
from Risk magazine, which named us Derivatives House 
of the Year, Equity Derivatives House of the Year and 
OTC Client Clearer of the Year. 

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The external recognition includes several areas that 
reflect our commitment to being a great place to work, 
another tenet of Responsible Growth. Euromoney 
named us the World’s Best Bank for Diversity & 
Inclusion, and Forbes included us in their JUST 100: 
Companies Doing Right by America ranking of how the 
country’s largest publicly traded companies perform in 
important areas including fair wages, acting ethically 
and setting the standard in stakeholder treatment. 

Looking ahead 
to 2020 
I hope you’ll enjoy reading about your company in 
the following pages, where you can look at how we’re 
helping make financial lives better through every 
connection. 

Our performance and recognition took place against a 
backdrop of a growing U.S. and global economy, driven 
by solid consumer spending. While geopolitical and 
trade uncertainty remains, we saw some of it clear up 
as trade agreements with Canada, Mexico and China 
were concluded in 2019. 

There are factors beyond our control that impact the 
markets and economies in which we operate. As this 
report is being completed, we are experiencing volatility 
because of uncertainties around the impacts of the 
coronavirus. We are taking the necessary measures to 
look after our employees and serve them as this situa-
tion develops. 

Despite headwinds that may arise from time to time, 
over the last decade we have built a strong, stable 
platform, with significant liquidity and capital, and we 
will remain resilient as we maintain disciplined focus on 
what we can control, which is embedded in delivering 
Responsible Growth. 

As we look ahead to 2020 and beyond, we will maintain 
our focus on delivering Responsible Growth through 
disciplined adherence to the tenets I’ve discussed: by 
serving our clients, managing risk well and ensuring 
those results are sustainable through operational excel-
lence, being a great place to work for our teammates, 
and sharing our success. The three-year company 
strategy that our board of directors reviewed in the 
fall of 2019 is based on continued adherence to this 
approach. And as always, we will continue to learn what 
is most important to those we serve by asking: 

What would you like the power to do?  

Let me know at brian.t.moynihan@bofa.com  

Brian Moynihan 
March 3, 2020 

Total assets 
(trillions) 

Return on average tangible 
common shareholders’ equity5 

$2.28 

$2.35

$2.43 

$2.14 

$2.19

15.55% 

14.86% 

9.16% 

9.51% 

9.41%

2015 

2016 

2017 

2018  2019 

2015 

2016 

2017 

2018  2019 

5 Represents 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 48 and Non-GAAP Reconciliations on page 101 of the 2019 Financial Review section. 

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A message from Brian Moynihan: 
Responsible Growth and stakeholder 
capitalism in action 

What would you like the power to do? 

Our core job is to ask this question of our teammates, our clients, our shareholders and the 
communities we serve. By listening to the answer, we learn what is most important to them. 
And then we try to help them do it. 

Our clients want the best capabilities, services and ideas to help them live their financial lives. 

Our employees want to be able to bring their authentic selves to work and to create a good 
life for themselves and their families with competitive compensation and benefits. 

Our shareholders want the best returns on their investment in Bank of America. 

By driving Responsible Growth, we deliver for these 
stakeholders. 

At the same time, we also serve broader society. 
We must tackle important societal priorities, such as 
affordable housing, economic mobility and a clean 
energy future. And we are. There is a lot of discussion 
today about the best ways to mobilize the resources 
needed to address these challenges. The discussion 
includes questions about how effective our capitalist 
economic system is at prioritizing these needs and 
whether we need to think differently about it. Simply 
stated: Can capitalism address the most challenging 
societal priorities, or might we need to think about 
another economic model? 

In 2019, the Business Roundtable in the U.S. issued a 
Statement on the Purpose of a Corporation. Bank of 
America is a member of the Business Roundtable, and 
I signed the statement, because it reflects the way 
our company has operated for many, many years. The 
statement is straightforward, and I encourage everyone 
with an interest in Bank of America to read it. 

The Business Roundtable issued its statement in 
the context of this ongoing discussion about capitalism. 
In that context, the statement has been interpreted 
in some quarters as a step away from the important 
responsibility we have to deliver the best financial 
returns to our shareholders so that companies can focus 
on other, “more important” societal priorities. 

At Bank of America, we reject that false choice. 
The simple fact is that at Bank of America, we believe 
we must continue to deliver great returns AND help 
drive progress on societal priorities. There is ample 
evidence to suggest the wisdom of this approach. The 
BofA Global Research team — ranked number one in 

the world by Institutional Investor for seven of the last 
nine years — has published a series of research reports 
demonstrating that companies that pay close attention 
to environmental, social and governance (ESG) priorities 
are much less likely to fail than companies that do not. 

At Bank of America, we believe capitalism is best at 
creating opportunity for people to realize their hopes 
and dreams. We believe if we keep aiming capital-
ism’s power toward the challenges we face, we can 
make significant progress on society’s most pressing 
problems. 

Bank of America’s role in that system is to help all of our 
stakeholders — our clients, shareholders, teammates 
and those in the communities where we operate — grab 
the opportunities they see for themselves by helping 
with their financial lives. 

We also believe, though, that it is important to acknowl-
edge questions being raised, such as: 

• How do we ensure equal access to opportunity? 

• Are companies sharing their success equitably with 

their employees? 

• Are we doing all we can do to accelerate the transition 

to a low carbon, clean energy economy? 

• What will happen to today’s employees as technology 

advancements change the nature of work? 

• Can companies hold themselves accountable through 

strong self-governance? 

These discussions are at the heart of the policy debates 
in legislative and executive bodies around the world. 
These are concerns for our clients, our communities 
and increasingly for our shareholders. Our teammates 
discuss them with their families and with each other. 

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How do we ensure the opportunities are available to all 
and that we harness the energy of capitalism to address 
society’s concerns? These issues can be solved if the 
private sector is engaged and helping to drive forward. 
But it has to be done the right way. 

Which brings me 
back to our question. 
What if we asked the world: “What would you like the 
power to do?” 

The answer might be summed up in what the U.S. and 
nearly 200 other countries agreed to at a summit in 
2015 when they set forth the Sustainable Development 
Goals (SDGs). The SDGs represent 17 categories of 
societal priorities that address equality of opportunity … 
access to clean water … renewable energy … affordable 
housing … and other priorities, with specific goals to be 
met. World leaders agreed that these goals are the ones 
we need to address to build a sustainable future and 
create opportunity and prosperity for all. 

The SDGs are estimated to require about $6 trillion 
annually of investment capital. This will take all sectors 
of society. Certainly philanthropy and governments 
have critical roles to play, but all annual charitable 
contributions in the world total just over $800 billion. 
Total global non-profit foundation assets are about 
$1.5 trillion. Even if annual charitable contributions 
and every endowment and foundation in the world 
were directed toward reaching the SDGs and no other 
priorities — not the arts, not additional medical causes, 
not any of the other worthy priorities that get support 
today — we still would fall far short of what is needed. 

Governments alone also cannot address the challenges 
laid out in the SDGs. The U.S. operating budget is the 
largest in the world at about $4.5 trillion. If all of it were 
dedicated to the SDGs only — meaning not funding 
national security, basic research, basic services for the 
U.S. taxpayers, and not paying the federal debt — we 
still would fall short of the annual need. 

So how can we 
fund these needs? 
The private sector and capitalism. 
This goes well beyond corporate philanthropy, as 
important as that is. Since I became CEO of Bank of 
America in 2010, we have delivered more than $2 billion 
in philanthropy to support important priorities in the 
U.S. and around the world. Our teammates have, with 
our support, volunteered about 2 million hours of their 
time each year to non-profit organizations and causes. 
We are proud of that, but even if every company on the 

Fortune 500 delivered that amount of philanthropy in 
a year, we would still fall well short of the need. 

What the private sector is doing, and what is reflected 
in the Business Roundtable statement, is aligning 
our ordinary business activities to help solve these 
challenges. 

For Bank of America, that means we have to bring our 
$2.4 trillion balance sheet to bear to the task. 

We have to bring our $53 billion expense base to 
the task. 

We have to bring our $268 billion equity base to 
the task. 

We have to bring our trillions a year of capital raising 
for our clients to the task. 

Based on client desires, we have to usher the $3 trillion 
in assets in our wealth management business to 
the task. 

If all operating companies continue to align themselves 
to deliver on those SDGs on which they can have the 
most impact, and if we measured ourselves to be sure 
we’re making progress, we would deliver the capital, 
the creativity and the expertise to address the world’s 
most pressing challenges. 

How does 
Bank of America 
do that? 
First, we do it with our own operations. We are carbon 
neutral as of this year. We are reducing paper, we focus 
on the environmental efficiency of our buildings and 
we continuously reduce waste. 

Second, of course we drive our charity, our philan-
thropy and volunteering and our nearly $5 billion in 
annual community development lending and investing 
to address the areas. You can find those in our 
annual report. 

Third, we do it with our employment and human 
resources practices, which are well laid out in our 
2019 Human Capital Management Report. We employ 
teammates, support families and their economic devel-
opment by providing funding for education and many 
other useful purposes. We provide strong and progres-
sive health and wellness benefits: All teammates get 
the same plans, and lower paid teammates pay a lot 
less for them. Other benefits include paid family leave 
of 16 weeks, industry-leading bereavement benefits 
and a minimum starting salary of $20 an hour, about 
$42,000 a year. We make available to our teammates 
the reskilling resources and opportunities as work 

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Bank of America is working with the World Economic 
Forum (WEF) and the accounting firms Deloitte, 
EY, KPMG and PwC to develop a framework to provide 
all stakeholders, including shareholders, a consistent 
method to evaluate the progress companies are making 
to advance SDG priorities in the areas of human capital, 
environmental sustainability, governance and other 
sustainable development objectives. 

changes. We hired 10,000 veterans over the last five 
years. Our hiring in low- and moderate-income neigh-
borhoods has produced more than 8,000 hires in the 
last two years. 

Fourth, we do it with our client financing capabilities — 
our core activities. We provide examples of that in our 
annual report. For example, Bank of America is one of 
the largest underwriters of green bonds, and we have 
helped companies raise more than $40 billion on behalf 
of more than 100 clients to provide critical funding on 
environmental projects. 

Another example is in our consumer product design. 
We have one of the lowest priced checking account 
options in the industry, with a monthly maintenance 
fee of just under $5 for access to our banking channels, 
including mobile, online services, ATMs and financial 
centers. And our Advantage SafeBalance Banking, intro-
duced in 2014, was one of the first banking accounts to 
eliminate overdraft fees and non-sufficient fund fees. 
The account was the primary reason Money magazine 
named us the “Best Bank for College Students” in 
2019. We surpassed 1 million Advantage SafeBalance 
Banking accounts in June 2019. 

Fifth, we help our investor clients find opportunities 
to drive impact investing, ESG investing or blended 
finance across the SDGs. 

We dedicate all of our business operations to driving 
great returns for our shareholders AND to addressing 
these priorities. If each company focuses on delivering 
both through their individual routine business opera-
tions and practices, then we can channel the world’s 
capital to make meaningful progress on the SDGs. 

One important way to ensure we are making progress 
is to have a basic framework for measuring it. We 
need to do this so we can demonstrate progress to 
all stakeholders. With a measurement framework, 
we can reward the companies that achieve both, as 

investors can prioritize their investments and capital 
to companies making progress over those that are 
not. Remember, the BofA Global Research team has 
demonstrated that operating companies that don’t pay 
attention to these priorities are more risky and less 
predictable. 

There is no shortage of ways to measure this progress. 
This actually has been a barrier to progress, because 
there is no standard method of gaining alignment 
between the operators of companies that are doing 
so much to address these priorities and the investors 
seeking to direct capital toward them. There is a large 
and growing number of external forums and bodies 
trying to advance this work. By some estimates, there 
will be as many as 600 conferences in the U.S. alone 
this year to discuss ESG, sustainability, and sustainable 
business and finance models. 

There is a dizzying number of measurement systems 
and metrics, too. Public companies face requests 
from many stakeholders — investors, public officials, 
regulators and developers of their own proprietary 
measurement systems — that we adopt their preferred 
metric or routine to address a particular priority. The 
volume of approaches and the varied metrics and meth-
odologies make it difficult for those of us who operate 
companies to determine how best to provide consis-
tent reporting. And many of us would rather put our 
energy into actually making progress on the SDGs than 
debating the measurement of progress. 

Company management teams and the asset owners 
and asset managers who invest in these companies 
need a straightforward framework by which to compare 
non-financial information in these areas across compa-
nies in a given industry, and across industries, to 
determine which companies are making progress on 
the issues most critical toward ensuring a sustainable 
global economy. 

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The International Business Council, which I am priv-
ileged to chair, of the World Economic Forum (WEF) 
has recently addressed this need. The WEF asked 
the accounting firms Deloitte, EY, KPMG and PwC 
to develop a framework to provide all stakeholders, 
including shareholders, a consistent method to evaluate 
the progress companies are making to advance SDG 
priorities in the areas of human capital, environmental 
sustainability, governance and other sustainable devel-
opment objectives. 

Our objective is to develop a scorecard based on a 
consistent measurement framework for companies 
to disclose the progress they are making on specific 
SDGs. Our scorecard is one step toward creating some 
convergence among the many existing ESG metrics 
and measurement systems that are available. The 
experts working on this have identified a narrow and 
impactful range of metrics from some of the most 
widely acknowledged measurement systems available. 
The intent is for stakeholders to have a common set of 
metrics to measure the material impact that companies 
are having on the SDGs across and within industries, 

so that investors and other stakeholders can compare 
and evaluate progress. This is to simply show how 
capitalism is aligned generally and how each company 
is aligned specifically to delivering the progress. The 
metrics also will help investors evaluate the long-term 
value and sustainability of companies seeking to make 
progress on the SDGs. 

Just imagine how much intellectual and financial 
creativity we can harness if we 1) accept that capitalism 
is the best way to create access to opportunity for the 
most people; 2) acknowledge the shortcomings in our 
capitalist system just the same; and 3) address those 
shortcomings by harnessing the world’s capital toward 
the SDGs agreed to by nearly 200 countries. That’s a 
powerful force for progress. 

At Bank of America, we believe it is not only possible 
but it is the desired outcome for us to serve our clients, 
deliver for our shareholders AND deliver for the soci-
eties and communities we serve. That’s Responsible 
Growth and stakeholder capitalism in action. 

Bank of America Board of Directors 

Front row (from left): Michael White, David Yost, Maria Zuber, Jack Bovender,  
Brian Moynihan, Susan Bies, Linda Hudson, Lionel Nowell  
Back row (from left): Thomas Woods, Frank Bramble, Denise Ramos, Pierre de Weck,  
Monica Lozano, Thomas May, Sharon Allen, Clayton Rose, Arnold Donald  

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What would you like  
the power to do?  

At Bank of America, we ask this question every day of those 
we serve. By listening to the answers we learn what matters 
most to people. It’s how we deliver Responsible Growth. 

Bank of America  
Executive Management Team  

Front row (from left): Christine Katziff, Anne Finucane, Brian Moynihan,  
Catherine Bessant, Thong Nguyen, Sheri Bronstein  
Back row (from left): Andrew Sieg, Paul Donofrio, Dean Athanasia,  
Andrea Smith, David Leitch, Kathleen Knox, Geoffrey Greener, Thomas Montag  

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

Q: How are you driving Responsible Growth 
in Consumer & Small Business? 
Dean: We take an integrated high-tech and 
high-touch approach, offering our clients the 
convenience of our award-winning digital 
platform even as we’re investing in our network 
of 4,300 financial centers and approximately 
16,800 ATMs. We staff our centers with 
professionals who can help clients with all their 
financial needs, from transacting and borrowing 
for a home, auto or business to saving and 
investing with Merrill. And we do it all with a 
passion for client care that extends throughout 
our organization. At the same time, we’re 
focused on strengthening our communities, 
because Responsible Growth needs to be both 
shared and sustainable. And we’re investing in 
our employees’ development, because the more 
capable they become, the more we can do for 
our clients and communities. 

Q: What is your strategy for exceeding 
expectations for Consumer & Small 
Business clients? 
Dean: Bank of America and Merrill offer clients 
our full range of banking and investment 
services wherever and whenever they want, 
on our mobile app or talking with our expert 
professionals over the phone, through online 
chat, in a video conference or face-to-face in 
one of our new and upgraded financial centers. 
And then we provide extensive rewards and 
benefits across their entire relationship with us 
through programs like Preferred Rewards—  the 
more they do with us, the more their benefits 
grow. These are among the many reasons we 
have been able to grow average Consumer 
Banking deposits by more than $155 billion 
over the past five years, nearly 70% of that 
in Checking. 

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66M 

Consumer and Small 
Business clients 

38M 

Digital banking 
clients 

4,300 

25,200 

Retail financial centers 
and 16,800 ATMs 
(with about 1/3 located 
in LMI communities) 

Client professionals offering 
advice for investments, 
lending and small business 
in our financial centers 

Behind the scenes, we’re taking advantage of the latest 
advances in artificial intelligence (AI), machine learning and 
business intelligence to enable us to deliver personalized, 
client-specific insights, recommendations and resources during 
moments that matter. Our virtual AI-driven financial assistant, 
Erica®, uses all this intelligence to deliver a personalized 
experience for each and every client. 

Q: What are you doing to support the communities 
where you do business, especially low- and moderate-
income communities? 
Dean: We are helping to empower economic mobility for our 
clients and small businesses through a community-centered 
approach that offers resources tailored to meet their needs. 
Our strategy is designed to connect clients with products and 
services, employment opportunities and capital to increase 
financial resilience and help our local communities thrive. 

That means being focused on the needs of diverse commu-
nities. We serve 9.5 million Hispanic-Latino individuals and 
more than 1 million Hispanic business owners. In 2019, our 
market share as the primary bank for U.S. Hispanic-Latino 
consumers grew to 21%, maintaining our industry-leading 
position. And by the end of 2019, we had more than 2 million 
users of our Spanish-language mobile app, a 23.5% increase 
over the prior year. 

It also means being focused on underserved communities. 
Today, roughly one-third of our financial centers and ATMs are 
located in low- and moderate-income (LMI) neighborhoods, 
and 33% of our financial center employees work in these 
locations. In the rural markets where we work and serve, we 
have 235 financial centers, 820 ATMs and over 1,500 financial 
center employees. Across our network, nearly two-thirds of 
our financial centers are staffed by teammates who speak 
more than one language. Of the total number of multilingual 
associates, 81% work in our centers located in LMI areas. 

Q: How can employees develop and advance 
their careers at Bank of America? 
Dean: We’re helping our teammates in Consumer & Small 
Business, Merrill and the Private Bank build great careers at 
Bank of America through The Academy, our award-winning 
coaching and development organization. Academy programs 
provide robust coursework taught by subject matter experts, 
dedicated training time for frontline employees — each 
teammate receives a minimum of 80 hours of training when 
taking on a new role and up to 1,000 hours in the first five 
years, depending on the career path — in addition to peer 
mentoring and coaching. We also offer hands-on, high-tech 
immersion training programs using virtual reality and client 
engagement simulators, which is a first for our industry. 

More than 45,000 teammates participated in Academy 
programs in 2019, with nearly 11,000 advancing in their 
careers as a result. 

We encourage employees to consider their opportunities 
inside our company. Managers are expected to have that 
conversation with their teams, so they understand the 
opportunities they have to learn more about a different 
position in the market where they live, across all of our lines 
of business. We want employees to think about their career 
opportunities within our company, and we are empowering 
them and their managers to help them gain the training 
and the resources to do that. As a result, we’re seeing the 
highest employee engagement scores and lowest turnover 
we have ever experienced, even in an environment with 
low unemployment. 

Our investment in our teammates is helping us better serve 
our clients and the communities in which we live and work, 
providing more professional expertise and improving client 
care in every interaction. 

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Transforming 
wealth management 

Q&A with Katy Knox, President of Bank of America Private Bank 
and Andy Sieg, President of Merrill Lynch Wealth Management 

Q: How is the wealth management landscape changing? 
Andy: The demographics are shifting. More people are saving, investing and passing wealth on 
to the next generation, and the financial power of women is growing. At the same time, financial 
planning factors are evolving in a way that people want more information and greater choice in how 
they receive financial advice. These range from brokerage to online robo-advisors, to high-tech and 
high-touch full-service advisory relationships. And, clients want an integrated set of banking and 
lending services to help them meet their financial goals. The result is transformational; it’s a golden 
age for advice, with the advisor helping clients make smarter decisions. 

Q: How are your businesses aligned to 
capitalize on these opportunities? 
Katy: Our goal is to enable individuals, 
families, business owners and institutions 
to preserve and share their wealth, build 
legacies and plan for growth and success. 
We bring together business lines across Bank 
of America — Consumer Banking, Business 
Banking, Global Commercial Banking, Global 
Corporate & Investment Banking and Global 
Markets — to harness all of our resources 
designed to meet our clients’ needs. It’s a 
tremendous advantage to be able to holistically 
address both business and personal needs. 
From growing a business for the next gener-
ation, to unlocking capital in an art collection, 
to giving with passion and purpose, we help 
clients with their connected priorities. 

Andy: Last year was a record year for Merrill in 
client balances, revenue and net income. We’re 
in an era where Merrill advisors can serve as 
indispensable partners over their clients’ entire 
financial lives. We can provide clients the finest 
advice and service — investment management 
and access to banking, credit and lending — all 
through their advisor or the other channels we 
offer clients to interact with us. In today’s world, 
even the most astute families feel challenged 
by high-stakes financial decisions. That’s why 
you see more and more people looking for 
comprehensive advice from a single relationship. 
That’s what we offer our clients in a way no 
one else can. 

Q: How is the company helping clients 
looking to transition wealth to the 
next generation? 
Katy: We’ve helped individuals and families pass 
down their values across generations for more 
than 200 years. To meet a family’s financial 

goals, our Private Bank specialists draw upon 
their experience and expertise in wealth struc-
turing, investment management and credit and 
banking to create a thoughtful, comprehensive 
wealth plan. For business owners, we offer 
strategies to plan for a business transfer while 
keeping clients’ personal and family needs top 
of mind. For families with significant wealth, 
complex assets and ownership structures, 
the Bank of America Private Bank Family 
Office provides the highest level of expertise 
and service. 

Q: How are your digital capabilities 
enhancing the wealth management 
client experience? 
Andy: Clients, especially those with complex 
wealth needs, want a personal connection plus 
the convenience that technology offers. In the 
age of smartphones and mobile apps, Merrill 
clients can easily see their investment and cash 
accounts across the company, keep track of their 
financial goals and engage their advisor teams 
when and how they choose. Also, Merrill’s digital 
tools save our clients precious time by enabling 
them to quickly scan and sign documents and 
securely chat with their advisors through text. 

Katy: The Private Bank offers that same 
digital experience, with features such as 
seamless money transfers, document scanning, 
educational podcasts and integration of 
charitable gift fund accounts. As we look toward 
an increasingly digital future, we’ve made it 
easier for clients to have online access to their 
accounts across wealth and banking. Secure 
messaging between our advisors and clients 
facilitates a new type of relationship, including 
real-time engagement when that is what 
clients want. 

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Personalized banking, 
digitally delivered 

Digital is more important than ever. Today, clients expect the best 
mobile and digital technology in their financial relationships, just as 
they do in other areas of their lives. Our award-winning high-tech 
capabilities — our digital services earned 34 industry accolades in 
2019 alone — together with our high-touch approach are making 
banking better and delivering a more intuitive and efficient 
experience for our clients across all channels. 

Three core principles guide how we develop and deliver each digital 
experience: The information and advice we provide should be in the 
best interest of the client, timely and relevant, and offer a choice of 
the next best step. 

Our digital platforms bring never-before-possible convenience to 
our more than 38 million digital clients, including more than 80% 
of our small business owner clients. Significant investments in our 
user interface (UI) and artificial intelligence (AI) allow us to deliver 
a digital experience with powerful simplicity and groundbreaking 
personalization. 

Our virtual AI-driven assistant, Erica®, is the engine that enables this 
personalization at scale, delivering valuable client-specific insights 
and advice at key moments. Clients interact with Erica through voice, 
text chat or on-screen gesture, receiving help with their banking 
needs and proactive insights to help make managing finances easier 
and meet savings goals. For instance, Erica detects duplicate charges 
on an account and notifies clients if their spending is higher than 
usual or their checking account balance is trending toward $0. Erica 
can also assist with common inquiries, including billing disputes, fees, 
deposit holds and transaction-related questions. Since launching in 
2018, Erica has already helped more than 10 million clients complete 
over 100 million requests. 

In 2019, clients logged into our digital platforms more than 8 billion 
times, deposited more than 140 million checks through Mobile Check 
Deposit, and sent and received over $78 billion using Zelle®. More 
than one-quarter of all new products are provided through digital 
channels, including auto loans and home mortgages. 

In February 2019, we launched Business Advantage 360, our one-stop 
digital dashboard for business owners, and we recently enhanced 
the platform with the ability to integrate data from key third-party 
business applications. Since the launch, more than 1 million business 
owner clients have used Business Advantage 360, and Barlow 
Research recently named Bank of America No. 1 in Small Business 
Mobile Banking Adoption among the top 10 U.S. banks. 

Our digital and mobile capabilities are aligned with the capabilities 
clients receive in a financial center, too. For example, clients can 
use our mobile app to easily book an appointment with an employee 
to discuss a specific matter in a financial center. Alternatively, an 
employee in the financial center can discuss and save products 
to a client’s digital shopping cart, and the client can complete the 
application digitally at a later date. 

18  |  BANK OF AMERICA 2019 

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Building rewarding 
relationships 

The more clients do with us, the more their 
benefits grow. Our approach to deepening 
the relationships we have with our clients 
rewards them by recognizing the value of 
their entire relationship. This sets us apart 
from our competitors. Preferred Rewards 
is a first-of-its-kind relationship-based 
approach that provides members with 
extensive rewards and benefits across 
their deposit accounts, investments, credit 
cards, mortgages and auto loans, along 
with exclusive discounts. 

Launched in September 2014, the Preferred 
Rewards program has over 6 million mem-
bers, representing $501 billion in assets as 
of Dec. 31, 2019. The program allows and 
encourages members to get more from their 
banking relationship. On average, members 
hold about twice the number of banking 
products as nonmembers and show higher 
levels of satisfaction with their banking 
experience. Our retention rate for Preferred 
Rewards members was close to 99% at 
the end of last year and, in a 2019 bank 
survey, 8 out of 10 members told us they 

are “highly likely” to recommend Bank of 
America to friends and family. 

Preferred Rewards for Business is having 
a significant impact, as well. During the 
program’s inaugural year, we rewarded 
participating small business clients with 
approximately $175 million in benefits, in 
recognition of the tremendous value of their 
relationships with us. Preferred Rewards for 
Business was recognized in 2019 by Barlow 
Research with a Monarch Innovation Award 
in the “Business Banking Most Innovative 
Product” category. 

Clients can also use My Rewards, an easy-
to-use tool that tracks the rewards they 
have earned across Preferred Rewards, 
credit cards, BankAmeriDeals® and Preferred 
Rewards for Wealth Management. This 
information is conveniently presented in 
our Mobile Banking app. Since My Rewards 
launched in 2018, 17 million unique users 
have reviewed their rewards, with 65% being 
repeat users. 

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Making financial 
lives better  
in underserved 
communities 

Core to how we drive Responsible 
Growth is ensuring it is sustainable. We 
do that through operational excellence, 
which creates the savings we generate 
to reinvest in serving our clients and in 
our capabilities. We ensure sustainability 
by being a great place to work for our 
teammates, which we discuss in more 
detail throughout this report. And 
sustainability is driven by the ways we 
share success with the communities in 
which we operate. 

Our approach to serving low- and 
moderate-income (LMI) neighborhoods 
reflects all these elements of sustain-
ability. LMI neighborhoods include more 
than 8.4 million unbanked households 
and 24.2 million underbanked house-
holds.1 Today, about one-third of our 
financial centers and ATMs are located 
in LMI neighborhoods and 33% of 
our financial center teammates work 
in these locations. With the anchor 
of that physical presence, we serve 
these communities in several ways 
by providing: 

• Access to secure, transparent and 

affordable products, including credit 

• Personalized financial education 

and tools 

• Employment and business 

opportunities 

Secure, transparent and  
affordable products 
Through our digital banking platform and 
strong community presence, we offer all 
our clients access to secure, transparent 
and affordable products that can be 
personalized to meet their unique needs. 
For example, Bank of America Advantage 
SafeBalance Banking® is a checkless 
bank account that helps clients avoid 
overdraft fees. SafeBalance Banking 
includes a debit card and has unlimited 
access online and mobile services, 
financial centers and more than 16,800 
Bank of America ATMs. 

To help increase access to affordable 
and sustainable homeownership, 
in April 2019, we announced the 
$5 billion Bank of America Community 
Homeownership Commitment™ to 
benefit LMI homebuyers over the next 
five years. The initiative will help more 
than 20,000 individuals and families 
achieve homeownership through grants 
that directly assist homebuyers with 
their down payments and closing costs. 
At the end of 2019, the program helped 
over 9,000 new homeowners with 
$2.3 billion in mortgage lending. 

Personalized financial  
education and tools 
Through Better Money Habits®, we 
support people in becoming more 
financially resilient by connecting them 
to the tools, resources and education 
they need to help achieve their financial 
goals. This includes content to assist 
with budgeting and saving, homeowner-
ship, reducing debt, and retirement 
goals. Better Money Habits empowers 
people to evaluate their life priorities, 
such as family, health and home, and 
helps them determine how they should 
approach their finances. All content is 
available in both English and Spanish. 

Consumers have accessed this free 
platform over 2.7 billion times. And 
it has had an impact on the habits of 
those who use it: 1 in 4 users (1 in 3 LMI 
users) of Better Money Habits and the 
Spending & Budgeting content grew 
their savings by 20% or more.2 

Additionally, we’ve trained over 4,000 
teammates who work in approximately 
700 community financial centers on how 
to help consumers build their financial 
skills and pursue their goals, delivering 
quarterly educational workshops in 
English and Spanish. 

Employment and  
business opportunities 
We also are focused on helping people 
who live in our communities find mean-
ingful employment. Externally — through 
our Supplier Diversity Program — we 
spend $2 billion each year with diverse-, 
veteran- and women-owned businesses. 
In 2018, we committed to hiring and 
training 10,000 teammates in LMI 
neighborhoods within five years. We are 
well ahead of that pace; our Consumer 
& Small Business team has hired more 
than 8,000 employees from these 
communities in just two years. 

Those teammates benefit from our 
commitment to be a great place to work, 
which includes offering fair and compet-
itive pay. We are an industry leader in 
establishing an internal minimum rate 
of pay above all mandated minimums 
for our U.S. hourly teammates, and have 
made regular increases over the past 
several years. Our minimum hourly wage 
for U.S. teammates is $20, as of the first 
quarter of 2020. 

20  |  BANK OF AMERICA 2019 

1 Source: 2017 FDIC National Survey of Unbanked and Underbanked Households 
2 Refer to footnote 1 on page 39 for Better Money Habits research study information 

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Market presidents 
deliver the bank 
Los Angeles Market President Raul Anaya 

Bank of America operates locally in communities all across the 
United States. Having a strong local presence with deep connections 
in our communities drives performance in each of our lines of 
business. Leading the way in these communities are Bank of America 
market presidents who oversee integrated business teams to 
ensure we’re delivering the full capabilities of our company to each 
client in every community, and lead our interactions with countless 
nonprofit partners. 

This coast-to-coast network of more than 90 local executives — 
each of whom also serves in full-time roles as division leaders, client 
managers, financial advisors and more—connects the banking and 
investment resources offered through our eight lines of business to 
companies, families and individuals in each market, from the largest 
cities in the country to suburban and rural communities. They also 
lead our work in sharing our success by deploying Bank of America 
resources—including philanthropy and employee volunteerism—to 
address social and economic concerns and build strong communities. 

One example is Los Angeles Market President Raul Anaya, who 
has spent the past eight years leading in one of the country’s most 
vibrant and dynamic cities. 

“As market president, I work with members of my team to bring the 
expertise and resources of our company to our clients, serve as a 
civic leader on community and social issues, and keep employees 
connected to reach their personal and career goals — all of which 
enhance the strength of our 100-plus year heritage here in Los 
Angeles,” said Raul. “I’m incredibly proud.” 

Recently, to promote business integration, the market 
hosted its first-ever “Power of Inclusion Summit,” an 
event designed to engage with business leaders on 
the strategic value of building a diverse and inclusive 
workforce. Existing and prospective clients were invited 
to attend and hear from leaders on how they are using 
inclusion as a competitive advantage, creating an ideal 
opportunity to build relationships and create momentum 
on an important issue. 

In 2019, the L.A. team also helped address a critical issue 
in the city — housing and homelessness — partnering 
with groups such as the Central City Association and 
United Way to hold deep conversations about stemming 
the tide of homelessness through lending and investing 
in underserved areas and advocating for public-private 
solutions to complex housing issues. Coupled with the 
bank’s community development lending and investing 
of over $315 million to help create more than 500 units 
of affordable housing in L.A., as well as local philan-
thropy of over $7 million to local groups, these efforts 
demonstrate that we’re not only talking the talk, we’re 
walking the walk to improve the economic mobility of 
all Angelenos. 

To help make the bank a great place to work, the Los 
Angeles team established a number of ways to develop 
local talent, including creating mentoring programs, 
holding career events in partnership with groups such as 
the National Black MBA Association and offering training 
programs for those who serve on nonprofit boards. 

These are just a few examples of the work market 
presidents are doing across the country to ensure Bank 
of America drives progress in every community where 
our clients and employees live and work. 

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Global Banking and Global Markets 
Q&A with Tom Montag on deepening local client coverage 
and driving Responsible Growth 

Q: Who does your business serve, and what’s 
your vision for delivering for those clients? 
Tom: Our Global Banking businesses serve companies of varying 
sizes. In Business Banking, we work with clients with more than 
$5 million in revenue; our Global Commercial Banking clients are 
mid-sized companies with revenues of $50 million to $2–$3 billion; 
and through Global Corporate & Investment Banking, we serve 
the largest companies and corporations in the world. Our Global 
Markets businesses serve institutional investors with sales and 
trading services, liquidity, hedging strategies and ideas and 
insights they draw from our top-ranked Global Research platform. 

Our strategy is straightforward: deliver the full benefits of our company to 
our clients. We do this by deepening relationships and connecting our clients 
with the capabilities and solutions they need to drive their businesses forward. 
Every relationship and every market matters. From a first credit card to a first 

line of credit, to raising capital or advising 
on the sale of a company, we support our 
clients as their needs and aspirations evolve. 

Q: How are Global Banking and Global 
Markets evolving to serve clients? 
Tom: This year, we are continuing to 
build our capabilities in Global Banking to 
create more opportunity for middle market 
clients, who increasingly are global in their 
perspective. We are hiring and assigning 
additional client relationship bankers to 
serve clients through our local market teams, 
so they live and work in the same commu-
nities as those clients. Being local with an 
unparalleled global platform is a strength 
that differentiates us. 

Tom Montag, Chief Operating Officer of 
Bank of America and President of Global Banking 
and Global Markets 

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Powerful 
CashPro® platform 

Our mobile and digital capabilities extend beyond 
our retail client offerings. Our business clients 
also seek solutions to help them work faster and 
more efficiently. Our commitment to providing 
those solutions has earned the business of 
approximately 35,000 companies and institutions 
across 175 countries. Each year, we manage 
$72 trillion in payments, receivables and deposit 
transactions through CashPro®, our award-
winning platform accessed by approximately 
500,000 users. 

Through ongoing digitization of processes and 
expansion of online, application-programming 
interfaces and mobile capabilities, including 
electronic signature, real-time payments and loan 
information, clients can now access the platform 
anytime, anywhere. Last summer, one of our 
business clients used our mobile app to send a 
$1.6 billion payment, the biggest transaction ever 
on our CashPro app. CashPro ranks first in the 
Mobile category of Greenwich Associates latest 
Digital Banking Benchmarking study. 

Client feedback helps make all of our capabilities 
better. The CashPro Client Advisory Boards, 
made up of clients of all sizes, help ensure that 
we are delivering for our clients through our 
digital platform and deepening our relationships 
with them. 

95%  

We have relationships  
with 95% of the 2019 U.S.  
Fortune 1,000; and 77% of  
the 2019 Global Fortune 500  

We are also expanding the types of unique 
solutions available to our clients, including 
the leading capabilities we have in environ-
mental, social and governance (ESG) and 
sustainable finance. Through BofA Securities, 
we have led more green bond deals than 
anyone else and we continue to provide 
clients with options that help finance a more 
environmentally sound planet. Our Investment 
Bank showed tremendous momentum in 
2019, with increased market share in key 
countries across the world where we operate, 
including our U.S. middle market clients with 
which we already hold primary core banking 
relationships. 

In Global Markets, we recently realigned 
our business to cover clients more efficiently 
and are making strategic investments in 
technology and people to continue to innovate 
across every asset class. 

Q: What makes Global Banking 
and Global Markets at Bank 
of America unique? 
Tom: We serve our clients by delivering 
market-leading solutions across consumer 
banking, wealth management, commercial 
banking, corporate and investment banking, 
sales and trading, and research. No one can 
offer the range of services and capabilities at 
the level that Bank of America can. By building 
relationships, being in the local market and 
consistently bringing the full value of our 
company for our clients, we are delivering on 
our commitment to Responsible Growth. 

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Addressing society’s  
biggest challenges  

Q&A with Vice Chairman Anne Finucane 

The Sustainable Development Goals (SDGs) are the world’s roadmap to a 
sustainable future. The SDGs give governments, the private sector, foundations, 
and others a framework to prioritize resources and policies toward goals we 
all share: prosperity, equality, human rights, and a sustainable, clean energy 
future. Brian Moynihan lays out in these pages the ways that the private 
sector can align business operating models with investors seeking to drive 
capital toward companies that are making progress on the SDGs. 

At Bank of America, sustainability is a central characteristic of our operating 
model. This includes our core financing and advisory capabilities for our 
clients, how we manage our own operations — our New York headquarters 
at One Bryant Park was the first Platinum certified LEED skyscraper in 
the world — our global workplace practices and our philanthropy. By aligning 
all of our capabilities, we create the scale needed to drive capital toward 
the world’s most important priorities as defined in the SDGs: climate 
change, affordable housing, clean water and equal access to opportunities 
for prosperity. 

Q: How are we driving progress 
on the United Nations Sustainable 
Development Goals? 
Anne: To sharpen our focus on bringing even more 
business solutions to this work, we recently estab-
lished a Sustainable Markets Committee, co-chaired 
by Chief Operating Officer Tom Montag and me, to 
accelerate our progress, identify new opportunities 
and build upon our work in sustainable finance 
in particular. While we already are making great 
progress — we are the largest underwriter of green 
bonds in the world for instance — the Sustainable 
Markets Committee will help us expand on that to 
identify even more opportunities to develop products, 
capabilities and services in support of our clients as 
we work together to help realize the achievement 
of the SDGs. 

Q: How have we accelerated 
progress on specific SDGs? 
Anne: Last year, Bank of America directed more 
than $50 billion in capital toward activities that 
support achievement of the SDGs. I’ll highlight a few: 

Affordable and Clean Energy (SDG7) and Clean Water 
and Sanitation (SDG6): From 2007 through the end 
of 2030, we will have financed more than $445 billion 
to low-carbon, sustainable business activities in 
support of energy efficiency, renewable energy 
and sustainable transportation, and in other areas 
including water conservation, land use and waste. 
In our own operations, we are carbon neutral as 
of 2020. 

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Sustainable Cities and Communities (SDG11): 
Between 2005 and 2019, we financed 202,800 
affordable housing units. In 2019 alone, our 
Community Development Banking unit provided a 
record $4.88 billion in capital for affordable housing 
and community development, including financing 
more than 8,300 affordable housing units. 

Good Health and Wellbeing (SDG3) and Decent Work 
and Economic Growth (SDG8): We are increasing 
our U.S. minimum wage to $20 per hour in 2020, 
and have strong and progressive health and wellness 
benefits. For example, for U.S. employees making 
less than $50,000, we reduced annual family coverage 
medical premiums by 50% in 2011, and have kept 
those premiums flat since 2012. We have paid family 
leave of 16 weeks for maternity, paternity and 
adoption, and generous bereavement benefits for 
those who have lost a loved one. And externally, since 
2014, we have partnered with (RED)® to achieve an 
AIDS-free generation, pledging more than $35 million 
by 2025 to the Global Fund to Fight AIDS. 

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Gender Equality (SDG5): We support equal pay for 
equal work. At our company, compensation received 
by women on average is greater than 99% of that 
received by men, and compensation received by 
people of color on average is greater than 99% of 
non-people of color, as validated by third-party 
analysis. In addition to compensation, our ongoing 
work to invest in women as they make meaningful 
contributions within our company and in our commu-
nities includes our focus on being a great place to 
work for our female employees, making the financial 
lives of our female clients better, and advancing the 
economic empowerment of women around the world. 

Zero Hunger (SDG2), Quality Education (SDG4) and 
Reduced Inequalities (SDG10): We invested nearly 
$250 million in 2019 in global philanthropic giving 
to advance economic mobility — with $2 billion in 
giving since 2009. For example, since 2015, across 
the globe we’ve invested nearly $50 million in 
support of hunger relief, and $243 million to advance 
skill building and jobs for young adults and those 
with barriers to employment, including addressing 
issues affecting social justice and racial and 
gender inequality. 

These are just some of many examples of how 
we bring our full company and broader influence 
to address these 17 critical goals. 

Q: How are you engaging with others 
externally to drive this work? 
Anne: We drive global collaboration to address these 
major societal challenges by engaging with external 
stakeholders. Brian Moynihan discusses in his letter 
the work he is doing at the International Business 
Council of the World Economic Forum to develop 
standardized metrics that define sustainable business 
practices. We also are working with the World Bank 
and Stanford University to develop financial vehicles 
that will deploy greater capital to support the SDGs 
and close the funding gap. We are working with 
the Vatican, the United Nations and the Prince of 
Wales to help harness the power of the capitalist 
system to be able to address society’s needs. In the 
U.S., our National Community Advisory Council 
(NCAC) consists of senior leaders from social justice, 
consumer advocacy, community development, 
environmental, research and advocacy organizations 
who provide external perspectives, guidance and 
feedback on our business policies and practices. Our 
work in these areas is recognized by others: In 2019, 
we were named to the CDP A list for leadership in 
addressing climate change. This was our ninth year 
as a CDP-recognized leader. And for the sixth straight 
year, we were recognized for ESG leadership on the 
Dow Jones Sustainability Index (DJSI) World Index. 

In addition to the work I’m describing here, please see 
the following pages for additional examples of the 
progress we are making. 

We are addressing some of society’s greatest challenges 
by helping align the various sources of capital — from the 

“ business community, the public sector, and philanthropy — 

with all of Bank of America’s financial capabilities and talent, 
calling on the expertise of our teams and the passion of our 

employees around the globe. ” 

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A world of ESG 
innovation 

We have achieved carbon neutrality in our own 
operations* one year ahead of schedule. 

How did we get there? We reduced Scope 1 and 2 
emissions in our facilities by more than 52% since 
2010 and met our goal to purchase 100% of our 
electricity from renewable sources. We installed 
on-site solar at our facilities, completed multiple 
long-term renewable agreements to add new wind 
and solar electricity to the grid, and purchased 
Renewable Energy Credits. 

To compensate for unavoidable emissions, we pur-
chased carbon offsets by supporting four projects in 
impoverished areas around the globe, which help to 
preserve biodiversity and drive reforestation, while 
furthering local economic mobility. 

In Indonesia, we supported peatland protection 
through Cool Effect. The project is restoring 157,000 
hectares of damaged vital peatland. It also directly 
supports 34 communities, has 100% Indonesian 
staff and has provided 948 micro-loans for sustain-
able small business development. 

In the Mississippi River Valley, we supported an 
Arbor Day tree planting as part of the largest refor-
estation program in North America — already over 

120,000 acres have been reforested with more than 
500 landowners participating and 42 million trees 
planted. This ultimately helps communities in some 
of the poorest counties in the U.S. to build resiliency 
against climate change and flooding. 

In Peru, we supported a conservation program that 
helps protect the Andes and Amazon forests by 
establishing sustainable livelihoods for communities 
living around the Cordillera Azul National Park. The 
project created 624 jobs, 30% of which are held by 
women. It also returned $1.43 million to the local 
economy through the production of fair trade, 
organic cocoa, coffee and honey. 

Finally, in Kenya and Uganda, we supported an 
endeavor that empowers small farmer communities 
to learn to plant and maintain trees, for which 
they receive cash stipends. They also receive 
health training on HIV/AIDS, malaria, typhoid and 
tuberculosis, as well as vocational education and 
leadership training. 

We have achieved carbon 
neutrality in our own 
operations* one year ahead 
of schedule. 

*pending third-party validation 

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Investing to improve  
the environment 

Our financial commitment to improving the environment 
helps inform our global business strategy, including how 
we work with partners, support our employees, make our 
operations more sustainable, manage issues and govern 
our activities. These efforts are critical to our efforts to 
achieve U.N. Sustainable Development Goals focused on 
Clean Water and Sanitation (SDG6), Affordable and Clean 
Energy (SDG7) and more. 

Our $125 billion commitment to mobilize capital to 
low-carbon, sustainable business activities was achieved 
in 2019, six years ahead of schedule, and we’re not done 
yet. In 2019, we announced an additional $300 billion 
environmental business commitment, which we will meet 
by 2030, in support of energy efficiency, renewable energy 
and sustainable transportation, as well as important 
areas like water conservation, land use and waste. 

We are the first U.S. financial institution to issue five 
corporate green bonds, which raised a total of $6.35 billion 
for renewable energy projects since 2013. And we have 
been a leader in green bond underwriting globally. BofA 
Securities has underwritten more than $49 billion on 
behalf of over 100 clients, supporting more than 288 deals 
and providing critical funding to environmental projects 
since 2007. We have also been the top investor in tax 
equity projects in the U.S. since 2015. Our current portfolio 
holds approximately $9.4 billion of renewable energy tax 
equity projects supporting wind and solar facilities. 

We have achieved carbon neutrality in our own operations* 
one year ahead of schedule. 

$158B  

Deployed to low-carbon 
sustainable business activities 

$49B  

Green bonds underwritten 
since 2007 supporting 
environmental projects 

$9.4B  

Renewable energy tax 
equity projects for wind and 
solar facilities 

*pending third-party validation 

28  |  BANK OF AMERICA 2019 

Driving 
economic 
mobility: 
one  
community’s 
story 

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$1.5B   Community Development Financial 

Our investment across 255 

Institutions to finance economic 
development, small businesses, 
affordable housing and community 
facilities and services 

$2B 

Philanthropic investments 
since 2009 to drive economic 
mobility and social progress in 
the communities we serve 

$5B  

Part of our affordable home 
ownership initiative for low- and 
moderate-income homebuyers 
and communities across the U.S. 

2M  

Volunteer hours by Bank of 
America employees in their local 
communities in 2019 

workforce, committing $1 million of $6 million raised from 
the private sector over five years. This private sector 
investment leveraged $229 million in Mecklenburg County 
-
-
funding for pre  K and childcare subsidies over the same 
period of time. 

To create pathways to job opportunities, we support 
youth apprenticeship and other workforce development 
initiatives. Participating CELC members, including Bank 
of America, expect to hire 1,000 employees through local 
training programs and offer 1,500 work based learning 
experiences for K 12 students in the coming year. 

-
-

-
-

’

 —  
 —  

We have partnered with other financial institutions to 
commit more than $135 million to affordable housing 
the largest private sector investment in affordable 
housing in Charlotte s history. To help the project work 
financially, our commitment includes below  market loans, 
a donation of land, an investment in the Charlotte  
Housing Opportunity Investment Fund, and economic 
mobility grants and programs. In total, public and private 
partners in Charlotte have committed over $270 million 
to affordable housing. 

-
-

Economic inequality is one of the 
fundamental challenges of our time. 
Bank of America has a responsibility to 
use our resources — including capital, 
ideas, and the talent and passion of 
our team members — to help create 
solutions to this challenge. 

Our approach starts with a basic fact: Economic opportunity 
often depends on where a person lives. Some neighborhoods 
offer a path to a quality education, a decent home, a good job 
and financial security; but others do not. 

In our headquarters city, Charlotte, North Carolina, we joined 
with other business leaders, government agencies and 
nonprofit organizations to address this disparity and improve 
economic mobility for our fellow citizens. Local corporations 
and academic institutions came together in 2015 to form the 
Charlotte Executive Leadership Council (CELC) to tackle struc 
-
-
tural obstacles to economic opportunity. Bank of America s 
’
’  
CEO, Brian Moynihan, has chaired the CELC since 2018. 
Following the detailed recommendations of a local task force 
to address the roots of economic inequality, we are working 
through the CELC to make an impact in education, workforce 
development, affordable housing, community engagement 
and economic development. 

Investing in education, jobs and housing 
Because early education is vital to economic mobility, extend 
-
-
ing free, public pre  K to all 4  year olds in Charlotte was a top 
-
-
priority. We contributed to the initial studies and helped fund 
scholarships and related expenses to expand the pre  K teacher 

-
-

-
-

-
-

’
’

What s happening in Charlotte is not an isolated effort. 
Many of the initiatives first used in Charlotte are now 
being piloted in other Bank of America markets, with 
a goal of creating greater economic mobility for all our 
communities  and the people who live and work in them. 

 —  
 —  

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Diversity at work and  
in our communities 

Diversity — in thought, style, age, sexual orientation, gender 
identity, race, ethnicity, culture and experience — makes us 
stronger and is essential to our ability to serve our clients, 
fulfill our purpose and drive Responsible Growth. We have 
a longstanding commitment to invest in diverse communi-
ties, including supporting strong diversity in representation 
across our company, reflecting the clients and communities 
we serve. We’re proud of the progress we’ve made, partic-
ularly our efforts in support of Black/African American and 
Hispanic-Latino communities, which we feature below. A broad 
discussion of our diversity commitment, how we execute on 
it and our results are discussed in detail throughout our 2019 
Human Capital Report, which is available on our Investor 
Relations website. 

We are sharply focused on building a diverse workforce, which 
is currently 13% Black/African American and 18% Hispanic-
Latino, exceeding EEOC financial services and Department 
of Labor benchmarks; and last year, the number of executive 
and senior-level officials and managers drawn from these 
populations increased more than 14%. 

In our efforts to further increase our diverse representation, 
we’re partnering with more than 200 external organizations 
to identify diverse talent. And, we have networking groups to 
provide professional development, mentoring and leadership 

opportunities. Employee Networks such as our Hispanic-
Latino Organization for Leadership & Advancement (HOLA) 
and Black Professional Group (BPG) have more than 14,500 
memberships each. 

We’re committed to making the financial lives of our clients 
better. Approximately 1 in every 3 checking accounts opened 
at Bank of America is by Hispanic-Latino clients, and 15% 
of checking accounts opened at Bank of America are by 
Black/African American clients. We deliver a full spectrum 
of products and services for these clients, whether they are 
looking to invest or just starting their financial journey. We 
offer Spanish-language capabilities across multiple products 
and services including our free Better Money Habits® website, 
which helps people build their financial know-how. In 2020, 
we celebrate 30 years of our corporate Supplier Diversity & 
Development Program, which supports minority-, women- and 
other diverse-owned suppliers, spending nearly $2 billion with 
diverse suppliers each year. 

Partnerships and programs are helping to drive our focus 
on economic mobility. In 2019 alone, we invested more than 
$55 million to advance issues of economic mobility and social 
justice affecting Blacks/African Americans and Hispanic-Latino 
individuals. We partner with change-making organizations 
like the NAACP, National Urban League and UnidosUS, all of 

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whom serve on our National Community Advisory Council, a 
group that helps inform our approach to serving our clients 
and communities. We use our voice to advocate for progress 
on societal challenges that disproportionately affect diverse 
communities. For example, we signed the CEO Action Pledge 
for Diversity & Inclusion, continuing our leadership role 
in making our sector more diverse and inclusive, expanding 
unconscious bias education and sharing best practices. In 
2019, we became the first financial services organization to 
sign the Hispanic Promise, pledging our commitment to hire, 
promote, retain and celebrate Hispanic-Latino individuals in 
the workplace. And last year, we renewed our commitment to 
Unlocked Futures, which invests in social entrepreneurs who 
have been impacted by the criminal justice system. 

Helping break barriers to economic mobility and drive progress 
on social issues for diverse populations is important to our 
employees, our clients, our investors and our communities, 
and we will continue driving this work. 

Employee Networks 

Our 11 Employee Networks, which include more than 
300 chapters and 160,000 memberships worldwide, help 
teammates develop leadership skills, build ties with local 
communities and advance diversity recruitment. 

Our Employee Networks include: 
• Asian Leadership Network 
• Black Professional Group 
• Disability Advocacy Network 
• Hispanic/Latino Organization for Leadership and 

Advancement (HOLA) 

• Inter-Generational Employee Network 
• Leadership, Education, Advocacy and Development (LEAD) 

for Women 

• Lesbian, Gay, Bisexual and Transgender (LGBT+) Pride 
• Military Support and Assistance Group 
• Multicultural Leadership Network 
• Native American Professional Network 
• Parents and Caregivers Network 

200+ 

Number of external 
organizations we’re 
partnering with to 
identify diverse talent 

$55M+ 

160,000+ 

Amount invested in 2019 
to advance issues of 
economic mobility and social 
justice affecting Blacks/ 
African Americans and 
Hispanic-Latino individuals 

Memberships 
in our 11 Employee 
Networks 

Our diversity makes us stronger, and the value we deliver as a company is strengthened when 
we bring broad perspectives together to meet the needs of our diverse stakeholders. 

over 50% 

of our management 
team are women or 
people of color 

over 50% 

of our global workforce 
are women 

over 45% 

of our U.S.-based 
workforce are people 
of color 

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Creating opportunities through 
employee development 

“A key element of sustainable growth is being a great place to 
work for our more than 200,000 employees. That means creating 
opportunities for our teammates to grow and develop so they 
can deliver great service to our clients while having a rewarding 
career at our company.” 
Sheri Bronstein, Chief Human Resources Officer 

CORDELL JACKSON (Right) 

Cordell Jackson started in the Consumer Banking 
call center and has grown professionally over the 
years thanks to his talent, support from managers 
and teammates, and our career resources. As 
part of his career progression, Cordell recently 
transitioned roles, from a risk analysis senior 
manager to a strategic consumer product analyst. 
“If you aren’t learning, you aren’t growing,” Cordell 
explains, and the bank has been with him every 
step of the way. To help Cordell further develop 
his skills, he was nominated to participate in our 
Diverse Leader Sponsorship Program, a highly 
selective 10-month development program that pairs 
candidates with more senior executive sponsors 
who will help them build skills, gain exposure and 
broaden their network. In addition, our tuition 
reimbursement program helped Cordell finance his 
master’s certificate. Through our online Learning 
Hub platform, he can access an extensive library 
of career development resources, including white 
papers, videos and articles from industry experts. 
Now, Cordell continues to develop his skills, grow his 
professional network and mentor other employees 
as co-chair of the bank’s Black Professional Group 
chapter in Delaware. 

32  |  BANK OF AMERICA 2019 

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JUDY RETANA (Below) 

Judy Retana started her career as an intern with Bank of 
America through long-time bank partner Year Up® before 
becoming a full-time teammate through our Pathways 
program. Through Pathways, we work with nonprofit partners 
like Year Up to provide skills training and career pathways 
to Consumer & Small Business teammates from low- and 
moderate-income communities. “Year Up provided me with 
the tools to help me create a professional brand to advance 
my corporate career. Its mission is to close the opportunity 
divide between those who have a college education and 
work experience, and those who don’t but who have high 
potential,” Judy explained. Today she’s thriving in her role as a 
Merrill ongoing support specialist. “Our business is constantly 
changing, with a lot of new opportunities. There are many 
talented people who deserve the same chance in life I’ve had. 
Programs like Year Up and Pathways enable people to start 
their careers.” 

DANIEL BURTON-MORGAN (Above) 

London-based Daniel Burton-Morgan was in 
his final year at university when he was offered 
his first full-time job with our company as a 
UK mergers and acquisitions analyst. Fourteen 
years later, he’s a managing director in Global 
Corporate & Investment Banking with deep 
experience serving our global clients across 
Europe, the Middle East and Africa. According 
to Daniel, the opportunity to move into new 
roles across business units and in different 
locations is one of many reasons that Bank 
of America is such a great place to work 
and build a long-term career. Another is our 
commitment to developing employees. Daniel is 
an alumnus of our Emerging Leaders Program, 
which brings together leaders to enhance their 
effectiveness. “It was a fantastic opportunity 
to meet teammates across the company and 
exchange ideas around growing our business,” 
he said. “Professional development is critically 
important because it keeps work interesting and 
rewarding,” Daniel added. “Even more, clients 
expect us to grow with them, and they want 
financial advice and solutions delivered through 
a global lens.” 

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Supporting  
teammates in  
moments that  
matter 

Part of being a great place to work is supporting 
our employees in the moments that matter most. 
This includes helping our teammates navigate 
significant life events — connecting them to internal 
and external resources, benefits, counseling and 
other support options. In 2014, we established our 
Life Event Services (LES) group — an internal and 
highly specialized team that has provided more 
than 100,000 team members with empathetic and 
personalized support for needs related to terminal 
illness, taking a leave of absence, the death of a 
loved one, domestic violence, medical accommoda-
tions, transgender and gender identity, retirement 
and military service. 

Additionally, when disasters occur, LES provides 
support for employees who are affected by an 
event, such as a natural disaster, violence or 
house fire. This can include providing paid time 
off to handle the impacts of the event, temporary 
housing and referrals to community organizations, 
or arranging emotional support for the teammate 
and family members. 

Chief Human Resources Officer Sheri Bronstein 
said, “Being a great place to work means having a 
culture of caring. By supporting our teammates 
through difficult moments, we help them to be their 
best both at work and at home so they can deliver 
for their families, our clients and our communities.” 

LES was there for Alison Harding, an employee in 
Global Technology & Operations, when a hurricane 
threatened her home in Charleston, South Carolina. 
The area was under mandatory evacuation; however, 
Alison’s family did not have a vehicle large enough 
to accommodate her special-needs child, his medical 
equipment, nurse and the family. LES took action to 
help and within 20 minutes, secured a large vehicle 
to meet their needs enabling the family to safely 
evacuate. “I felt instant relief, followed by how proud 
I was to work for a company that helped me in a 
time of need,” said Alison. “With a special-needs 
child, we have to consider and worry about so many 
things and this obstacle was removed so we could 
focus on caring for our family.” 

100,000+  

Employees supported 
during the moments 
they and their families 
needed it the most 

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Courageous 
conversations 

Our commitment to being a great place to work is 
rooted in celebrating diversity and inclusion (D&I). 
Women make up 50% of our workforce, and over 
45% of our U.S. workforce are people of color. 
Over the past few years, we have developed a new 
forum for bringing us all together, called coura-
geous conversations. These candid dialogues, 
focused on topics like race and gender equality, 
social justice, emotional wellness and domestic 
violence, engage teammates and drive inclusivity. 
More than 60,000 teammates have participated 
in these sessions. 

We have incorporated courageous conversations 
into our broad D&I learning, including our “Let’s 
Get Real” program, a quarterly series sponsored 
by the Global Diversity & Inclusion Council. 

Due to the positive feedback we received about 
these internal discussions, we began hosting 
conversations with our clients and communities, 
including a recent Boston-based session on 
substance misuse disorders and ways to support 
those in recovery. 

photo 
FPO 

60,000+  

Teammates  
have participated  
in courageous  
conversations  

BANK OF AMERICA 2019  |  35 

Partnering  
to end AIDS  

Since 2014, we have partnered with (RED)® 
to achieve an AIDS-free generation. As of 
December 31, 2019, our partnership has generated 
nearly $19 million in contributions to the Global 
Fund to Fight AIDS. In October 2019, we extended 
our commitment to pledge more than $35 million 
by 2025. 

In partnership with brands worldwide, (RED) raises 
money and awareness in the fight against AIDS. 
Its partners contribute to Global Fund grants 
that provide treatment, testing and preventative 
care and counseling services, with a focus on 
ending mother-to-child HIV transmission in eight 
sub-Saharan African countries. 

Currently, 38 million people are living with HIV 
globally, with 26 million in sub-Saharan Africa. 
Thanks in large part to (RED) and the Global Fund, 
more than 24.5 million people now have access to 
life-saving treatment. Additionally, AIDS-related 
illnesses have decreased by more than half since 
peaking in 2004. 

Our work with (RED) is an example of how we 
are partnering to help address local, national and 
global social priorities—including Good Health 
and Wellbeing (SDG3) — to deliver Responsible 
Growth. By furthering our commitment and 
working together, we will help end AIDS. 

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Total rewards  

We listen and learn from our teammates 
about what matters most as we continue 
to deliver on our commitment to be a 
great place to work. Our teammates 
-
emphasize that they want the opportu 
-
nity to have rewarding, long-term careers; 
to be supported in physical, emotional 
-
and financial wellness; and to make a dif 
-
ference in our local communities. 

-
To support our employees with their per 
-
sonal and professional goals, we pay our 
teammates competitively and provide 
broad and diverse benefits to meet their 
needs both today and in the future. 

In the first quarter of 2020, we are 
increasing our minimum hourly wage 
for U.S. teammates to $20. As a result 
of this change, our yearly minimum 
rate of pay for a full  time employee 
will increase to more than $41,000. 
In addition to this yearly wage, we 
provide a variety of health care and 
wellness benefits, which are significant, 
additional components of the total 
rewards that all employees receive. 

-

As an example, an employee making 
just over our minimum hourly wage 
with a base salary of $45,572 who also 
receives company contributions for 
-
retirement, health and insurance cover 
-
age and childcare, would have total 

annual pay and benefits of over $77,000 
per year. And this number could increase 
further depending on the other benefits 
 —  
such 
an employee may choose to use 
 —  
-
as tuition assistance, free confiden 
-
tial counseling through our Employee 
Assistance Program, company  provided 
matching gifts for charitable donations 
and more. 

-
-

Each year, eligible U.S. employees have 
the opportunity to review a summary of 
what they earned, what they saved and 
how much the company contributed to 
their benefits for the prior year  all part 
of our approach to total rewards and 
investing in our teammates. 

— 
 —  

Assuming an 
employee with a 
base salary of 
$45,572* 

Company 
contributions to 
family health and 
insurance coverage 
would be 
$25,133 

Company 
contributions to 
401(k) would be 
$3,190 

Company-
provided child care 
reimbursements 
would be 
$3,595 

Company 
contributions would 
bring total annual pay 
and benefits to 

$77,490 

36  |  BANK OF AMERICA 2019 

* Example is based on employee with a base salary of $45,572 and benefits profile, living in one of our markets in the U.S., who is enrolled 
in a representative set of Bank of America employee benefit programs (including 401(k) plan, medical, dental, disability, life insurance, 
accidental death & dismemberment insurance, and child care reimbursement). For the 401(k), it assumes the employee has at least 1 year 
of service, and is receiving 2% Annual Company Contribution and 5% Company Match (based on a contribution rate of at least 5%). 

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Funding the  
power to dream 

In 2019, we asked employees from across the globe “What would you like the power to do?” and 
how they would put a financial grant to work in their communities. We responded with nearly 
$1 million in funding for 42 employee ideas that focused on economic mobility, the environment, 
and arts and culture. These ideas were selected to receive a $50,000 or $10,000 grant and 
support from within the bank, in partnership with an eligible local nonprofit. 

Among those selected was Ashton 
Ngwena, an employee in Investment 
Banking. Ashton knows firsthand 
that a quality education is not afford-
able or accessible for everyone. His 
journey from a small farming village in 
Zimbabwe inspired his desire to assist 
other children who are in a similar posi-
tion. His idea will help build a community 
school for Education Matters Africa 
in Zimbabwe. “Getting accepted into 
Education Matters Africa was a key turn-
ing point in my life. I am grateful to Bank 
of America for helping this organization 
to further their impact through this 
opportunity for the students to learn, to 
hope and to dream of a brighter future 
for their communities,” said Ashton. 

Similarly, Merrill Lynch Wealth 
Management Advisor Sue Harmon 
was inspired to help young adults with 
developmental disabilities achieve their 
dreams by ensuring they have trans-
portation to get to work. She is tackling 
this common problem by partnering 
with The Arc of Greater Williamsburg 
in Virginia to launch Wheels4Work, a 
transportation and employment project. 

This program is just one way we are 
building on our progress to support 
our teammates, their families and the 
communities where we work and live. 

Photo courtesy of Education Matters Africa 

Being a Great
Place to Work 

2019 HUMAN CAPITAL MANAGEMENT REPORT 

Published November 2019 

2019 Human Capital   
Management Report  

We are committed to being a great place to work and investing in the 
people who serve our clients and live and work in our communities. 
In 2019, we published our first human capital management report 
detailing all we do to support our more than 200,000 teammates and 
their families. The importance our stakeholders place on transparency 
and how we engage our employees on key issues — such as talent 
management, employee engagement and diversity — is an increasingly 
common theme. To provide additional clarity on our company’s actions, 
the 2019 Human Capital Management Report — available on our Investor 
Relations website — illustrates how we promote a diverse and inclusive 
workforce, recognize and reward performance, attract and develop 
talent, and support our teammates’ physical, emotional and financial 
wellness. Going forward, we will continue to report on these items and 
the progress we’re making as part of our focus on making this the best 
place for our employees to work. 

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2019 ESG highlights 

At Bank of America, we are driving Responsible Growth with a strong focus on environmental, 
social and governance (ESG) leadership. This helps us to serve clients, deliver attractive returns 
for our shareholders and address some of society’s greatest challenges.  

Green bonds 
We have been a leader in green bond 
underwriting globally since 2007. BofA 
Securities has underwritten more than 
$49 billion on behalf of 100+ clients, 
supporting more than 288 deals and 
providing critical funding to environ-
mental projects, since 2007. 

We are the first U.S. financial institution 
to issue five corporate green bonds. 
These five corporate green bonds raised 
a total of $6.35 billion for renewable 
energy projects since 2013. 

Blended Finance 
Catalyst Pool 
In 2018, we launched our Blended 
Finance Catalyst Pool to mobilize 
additional private capital to help address 
the U.N. Sustainable Development 
Goals. This financing initiative provides 
$60 million of capital for Affordable 
and Clean Energy (SDG7), Sustainable 
Cities and Communities (SDG11), Clean 
Water and Sanitation (SDG6), and 
Climate Action (SDG13), among others. 

Climate risk and 
ESG disclosure 
We understand climate change presents 
risks to the business community, and it 
is important for companies to articulate 
how these risks are being managed. 
We will be issuing our Task Force on 
Climate-related Financial Disclosures 
(TCFD) report in 2020 to ensure our 
shareholders, clients and communities 
are aware of the financial risks of 
climate change to our business and how 
we are managing those risks. We also 
continue to focus on transparency and 
driving data with organizations like the 
World Economic Forum, Sustainability 
Accounting Standards Board, the Global 
Reporting Initiative and others, and how 
best to align those metrics to the U.N. 
Sustainable Development Goals. 

Affordable homeownership 
In April 2019, we announced our new 
$5 billion Bank of America Community 
Homeownership Commitment™ to 
benefit low- and moderate-income (LMI) 
homebuyers and communities across the 
country over the next five years. 

Community 
Development Banking 
Bank of America Community 
Development Banking (CDB) provided 
a record $4.88 billion in loans, tax 
credit equity investments and other 
real estate development solutions. 

CDB deployed $3.1 billion in debt 
commitments and $1.78 billion in 
investments to help build strong, 
sustainable communities by financing 
affordable housing, charter schools 
and economic development across 
the country. 

Between 2005 and 2019, Bank of 
America financed 202,800 affordable 
housing units. 

Sustainable finance 
Each year, we mobilize, conservatively, 
more than $50 billion that impacts a 
key subset of the SDGs. 

Environmental business 
commitment 
Our Environmental Business Initiative 
will direct an additional $300 billion 
to low-carbon, sustainable business 
activities over the next 10 years. Since 
2007 when it was launched, we have 
already deployed $158 billion to these 
efforts across the globe. 

Tax equity for 
renewables 
We have been the top tax equity 
investor in the U.S. since 2015. Our 
portfolio at the end of 2019 was 
approximately $9.4 billion of Tax 
Equity renewable energy investment. 

Carbon neutrality 
We achieved carbon neutrality by 
reducing Scope 1 and 2 emissions 
from our facilities, purchasing 100% 
renewable electricity and buying 
carbon offsets for our remaining 
unavoidable emissions. 

38  |  BANK OF AMERICA 2019 

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Bank of America 2019 Annual Report

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Bank of America 2019 Annual Report

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Community Development 
Financial Institutions 
(CDFI) lending 
We originated more than $325 million 
in loans as part of our more than 
$1.5 billion investment in 255 CDFIs to 
finance affordable housing, economic 
development projects, small businesses, 
health care centers, charter schools, and 
other community facilities and services. 

Bank of America Art 
Conservation Project 
Since 2010, the Bank of America Art 
Conservation Project has provided 
grants to fund 170 conservation 
projects in 33 countries to conserve 
paintings, sculptures, and art and 
cultural treasures that are important 
to cultural heritage. We are a leader 
in helping the arts flourish across the 
globe, supporting more than 2,000 
nonprofit cultural institutions 
each year. 

Small business lending 
We provide advice, tools, solutions 
and dedicated support to meet the 
unique needs of our 12 million small 
business owners. We are a top lender 
in the Small Business Administration’s 
(SBA’s) 504 and 7(a) programs, and 
according to the FDIC, we are the top 
small business lender with $37.6 billion 
total outstanding small business loan 
balances as of third quarter 2019. More 
than half (57%) of all small business 
loans booked in 2019 were LMI loans 
for a total amount of $6.3 billion. 

ESG client balances 
We have $25.11 billion in assets in 
our wealth management business 
with a clearly defined ESG investment 
approach as of Dec. 31, 2019. 

Employee giving 
and volunteering 
Last year, employees volunteered 
2 million hours and directed 
$77 million to communities through 
individual giving and the bank’s 
matching gifts program. 

Women’s economic 
empowerment 
In 2019, we doubled our investment 
in the Tory Burch Foundation Capital 
Program, committing $100 million in 
capital to connect women small business 
owners to affordable loans. Since the 
program’s launch five years ago, more 
than 3,200 women entrepreneurs have 
received $54 million in loans through 
CDFIs to help them grow and refine 
their businesses. 

After launching the Bank of America 
Institute for Women’s Entrepreneurship 
at Cornell in 2018, we announced in 2019 
that we are doubling our commitment 
and will provide access for 20,000 women 
entrepreneurs to participate in the only 
online Ivy League, certificate program 
for women business owners in the world. 
Representing over 65 countries including 
Bangladesh, Egypt, Ghana, Uruguay and 
the United States, more than 15,700 
women are currently enrolled. 

Philanthropic giving 
We have delivered $2 billion in 
philanthropic investments since 2009. 
In 2019, we delivered approximately 
$250 million in philanthropic invest-
ments to drive economic mobility and 
social progress in the communities 
we serve. 

Pathways 
We are helping individuals of all 
socioeconomic backgrounds find 
meaningful employment, including 
through Pathways, our community 
hiring and development program that 
provides entry-level jobs and career 
training in Consumer & Small Business 
for individuals from LMI neighborhoods. 
To date, the bank has hired more than 
8,000 employees from these commu-
nities, putting the company at over 80% 
of its five-year 10,000 hiring goal in 
just two years. 

Better Money Habits® 
Since launching the Better Money Habits 
program, we’ve reached consumers over 
2.7 billion times. 

1 in 4 users of Better Money Habits 
content and tools grew their savings by 
20% or more.1 

In 2019, visitors to Better Money Habits 
home loans content were 37 times 
more likely to obtain a home loan within 
30 days.1 

71% of active Better Money Habits 
users have used the Spending & 
Budgeting tool. 

1 Represents Bank of America Consumer households for entire 12-months under study who used the Saving and Budgeting Tool during March 2017. Analysis 
based on average balances for the 6 months prior to March 2017 (“pre” period) and the 6 months after March 2017 (“post” period). 

BANK OF AMERICA 2019  |  39 

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Bank of America 2019 Annual Report

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Bank of America Corporation — Financial highlights 
Bank of America Corporation (NYSE: BAC) is headquartered in Charlotte, North Carolina. As of December 31, 2019, we operated 
across the United States, its territories 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’ equity1 

Efficiency 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 share1 

Market price per common share 

Common shares issued and outstanding 

Tangible common equity ratio1 

$ 

2019 
91,244 
27,430 
2.77 
2.75 
0.66 
1.14% 

14.86 
60.17 
9,443 

2019 
$  983,426 
2,434,079 
1,434,803 
264,810 
27.32 
19.41 
35.22 
8,836 
7.3 

$ 

2018 
91,020 

28,147 

$ 

2017 
87,126 

18,232 

2.64 

2.61 

0.54 

1.21% 

15.55 

58.40 

10,237 

2018 
$  946,895 

2,354,507 

1,381,476 

265,325 

25.13 

17.91 

24.64 

9,669 

7.6 

1.63 

1.56 

0.39 

0.80% 

9.41 

62.57 

10,778 

2017 
$  936,749 

2,281,234 

1,309,545 

267,146 

23.80 

16.96 

29.52 

10,287 

7.9 

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 48 and Non-GAAP Reconciliations on page 101 of the 2019 Financial Review section. 

Total Cumulative Shareholder Return2 

BAC Five-Year Stock Performance 

$250 

$200 

$150 

$100 

$50 

$0 

2014 

2015 

2016 

2017 

2018 

2019 

December 31 

2014 

2015 

2016 

2017 

2018  2019

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

$100 
100 
100 

$95 
101 
100 

$127 
113 
129 

$172 
138 
153 

$146  $214
174
132 
172 
126 

2This 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, 2014 through 2019. The graph assumes an initial investment of $100 
at the end of 2014 and the reinvestment of all dividends during the years indicated. 

KBW

S&P

B of A

$40 
$35 
$30 
$25 
$20 
$15 
$10 
$5 
$0 

2015 

2016 

2017 

2018 

HIGH  $18.45 

$23.16 

$29.88 

$32.84 

LOW 

15.15 

CLOSE  16.83 

11.16 

22.10 

22.05 

29.52 

22.73 

24.64 

2019 
$35.52 
24.56 
35.22 

Book Value Per Share/ 
Tangible Book Value Per Share 

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
$

.

2
3
7
2
$

.

1
4
9
1
$

2015 

2016 

Book Value Per Share 

2017 

2018 
Tangible Book Value Per Share³ 

2019 

40  |  BANK OF AMERICA 2019 

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

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2019 Financial Review
 

Bank of America 2019  41  

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 
Non-GAAP Reconciliations 
Statistical Tables 

Page 
43  
44  
45  
46  
48  
53  
54  
56  
58  
60  
61  
62  
63  
66  
66  
71  
74  
75  
81  
87  
89  
89  
92  
93  
95  
97  
97  
98  
98  
101  
102  

42 42

Bank of America 2019 

Bank of America 2019

       
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 2019 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; the possibility that 
the Corporation's future liabilities may be in excess of its recorded 
liability and estimated range of possible loss for litigation, regulatory 
and representations and warranties exposures; the possibility that 
the  Corporation  could  face  increased  servicing, fraud, indemnity, 
contribution  or  other  claims  from  one  or  more  counterparties, 
including  trustees,  purchasers  of  loans,  underwriters,  issuers, 
monolines,  private-label  and  other  investors,  or  other  parties 
involved  in  securitizations;  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  and  tensions, including  tariffs, and  potential  geopolitical 
instability;  the  impact  of  the  interest  rate  environment  on  the 
Corporation’s business,financial condition and results of operations; 
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, provision for credit losses, net charge-offs, effective 
tax rate, 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  or 
borrowing costs; estimates of the fair value and other accounting 
values,  subject  to  impairment  assessments,  of  certain  of  the 
Corporation’s assets and liabilities; the estimated or actual impact 
of  changes  in  accounting  standards  or  assumptions  in  applying 
those  standards;  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 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 or disruption 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  or  campaigns;  the 
impact on the Corporation’s business, financial condition and results 
of operations from the United Kingdom's exit from the European 
Union; the impact of any future federal government shutdown and 
uncertainty regarding the federal government’s debt limit; the impact 
of  natural  disasters,  the  emergence  of  widespread  health 
emergencies  or  pandemics,  military  conflict,  terrorism  or  other 
geopolitical events; and other 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,”  “we,”  “us”  and  “our”  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, 2019, the Corporation had $2.4 trillion in assets 
and a headcount of approximately 208,000 employees. 

As  of  December  31,  2019,  we  served  clients  through 
operations across the U.S., its territories and approximately 35 
countries.  Our  retail  banking  footprint  covers  approximately  90 
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 16,800 ATMs, and 
leading digital banking platforms (www.bankofamerica.com) with 
more than 38 million active users, including over 29 million active 
mobile users. We offer industry-leading support to approximately 

Bank of America 2019  43 
Bank of America 2019  43   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
three  million  small  business  owners.  Our  wealth  management 
businesses, with client balances of $3.0 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  2019,  we  repurchased  $28.1  billion  of  common  stock 
pursuant  to  the  Corporation's  Board  of  Directors’  (the  Board) 
repurchase  authorizations.  For  more  information,  see  Capital 
Management on page 66. 

Merchant Services Joint Venture 
A  significant  portion  of  our  merchant  processing  activity  is 
performed by a joint venture, formed in 2009, in which we own a 
49 percent ownership interest. The joint venture is accounted for 
as an equity method investment. As previously disclosed in the 
Corporation's Quarterly Report on Form 10-Q for the quarter ended 
June 30, 2019, we gave notice on July 29, 2019 to the joint venture 
partner of the termination of the joint venture upon the conclusion 
of  its  current  term,  after  which  we  expect  to  pursue  our  own 
merchant services strategy. In addition, the Corporation and the 
joint venture partner have an agreement to provide uninterrupted 
delivery of products and services to the joint venture merchants 
through at least June 2023. As a result of the above actions, we 
incurred  a  non-cash,  pretax  impairment  charge  of  $2.1  billion 
included in other general operating expense in the three months 
ended  September  30, 2019.  As  stated  above, the  Corporation 
expects to pursue its own merchant services strategy, which is 
expected to begin in the third quarter of 2020. Under this strategy, 
we  will  begin  to  record  the  revenues  and  expenses  from  those 
operations in the Consolidated Statement of Income instead of 
recognizing our proportionate share of the joint venture's income 
under  the  equity  method.  For  more  information, see  Note  13  – 
Commitments  and  Contingencies  to  the  Consolidated  Financial 
Statements. 

U.K. Exit from the EU 
On January 31, 2020, the U.K. formally exited the European Union 
(EU). Upon exit, a transition period began during which time the 
U.K. and the EU expect to negotiate a trade agreement and other 
terms  associated  with  their  future  relationship.  The  transition 
period is scheduled to end on December 31, 2020. 

We conduct business in Europe, the Middle East and Africa 
primarily through our subsidiaries in the U.K., Ireland and France. 
For information on the changes we have implemented to enable 
us to continue to operate in the region, including establishing a 
bank and broker-dealer in the EU, see the Corporation’s Quarterly 
Report on Form 10-Q for the quarter ended March 31, 2019. While 
we have taken measures to minimize operational disruption and 
prepare for various potential outcomes of the U.K.’s withdrawal 
from  the  EU,  the  preparedness  of  our  counterparties  and  the 
relevant  financial  markets  infrastructure  remain  outside  our 
control. The global economic impact of the U.K.’s withdrawal from 
the EU remains uncertain and could result in regional and global 

financial  market  disruptions.  We  continue  to  assess  potential 
risks, including operational, regulatory and legal risks. 

LIBOR and Other Benchmark Rates 
Following the 2017 announcement by the U.K.’s Financial Conduct 
Authority  (FCA)  that  it  will  no  longer  persuade  or  require 
participating  banks  to  submit  rates  for  the  London  Interbank 
Offered  Rate  (LIBOR)  after  2021, central  banks  and  regulators 
around  the  world  have  commissioned  working  groups  to  find 
suitable  replacements  for  Interbank  Offered  Rates  (IBOR), 
including  LIBOR, and  other  benchmark  rates  and  to  implement 
financial  benchmark 
future 
discontinuance of IBORs is a complex process that has resulted 
in  significant  uncertainty  regarding  the  transition  to  suitable 
alternative reference rates (ARRs) and could cause disruptions in 
a variety of global financial markets, as well as adversely impact 
our business, operations and financial results. 

reforms  more  generally.  The 

IBORs, including LIBOR, are used in many of the Corporation’s 
including  mortgages,  consumer, 
products  and  contracts, 
commercial and corporate loans, derivatives, floating-rate notes 
and other adjustable-rate products and financial instruments. The 
aggregate  notional  amount  of  these  products  and  contracts  is 
material to our business. As previously disclosed, to facilitate an 
orderly transition from IBORs and other benchmark rates to ARRs, 
the Corporation has established an enterprise-wide initiative led 
by senior management. As part of this initiative, the Corporation 
continues to identify, assess and monitor risks associated with 
the expected discontinuation or unavailability of LIBOR and other 
benchmarks  and  evaluate  and  address  documentation  and 
contractual mechanics of outstanding IBOR-based products and 
contracts that mature after 2021 and new and potential future 
ARR-based  products  and  contracts  to  achieve  operational 
readiness.  Additionally, the Corporation is continuing to evaluate 
potential regulatory, tax and accounting impacts of the transition, 
including  guidance  published  and/or  proposed  by  the  Internal 
Revenue  Service  and  Financial  Accounting  Standards  Board, 
engage impacted clients in connection with the transition to ARRs 
and work actively with global regulators, industry working groups 
and  trade  associations  to  develop  strategies  for  an  effective 
transition to ARRs. 

The  Corporation  is  also  modifying  its  operational  models, 
systems, procedures and  internal infrastructure to transition to 
ARRs. In 2019, the Corporation launched capabilities to support 
issuance  and  trading  in  products  indexed  to  the  new  Secured 
Overnight  Financing  Rate  (SOFR),  which  is  the  alternative 
benchmark  rate  to  U.S.  dollar  LIBOR  recommended  by  the 
Alternative Reference Rates Committee, a group of private-market 
participants and official-sector entities convened by the Board of 
Governors of the Federal Reserve System (Federal Reserve) and 
the Federal Reserve Bank of New York, and a broad measure of 
the cost of borrowing cash overnight collateralized by U.S. Treasury 
securities. Also, in 2019, the Corporation issued debt linked to 
SOFR,  and  the  Corporation  co-arranged  one  of  the  first  credit 
facilities linked to SOFR and has implemented fallback provisions 
into  certain  new  IBOR-based  products  and  contracts.  The 
Corporation continues to monitor the development and usage of 
ARRs,  including  SOFR.  For  more  information  on  the  expected 
replacement of LIBOR and other benchmark rates, see Item 1A. 
Risk Factors of our 2019 Annual Report on Form 10-K. 

44 44

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Financial Highlights 
In  the  Consolidated  Statement  of  Income,  amounts  related  to 
certain asset and liability management (ALM) activities have been 
reclassified  from  other  income  to  market  making  and  similar 
activities,  which  was  previously  referred  to  as  trading  account 
income. All prior periods presented reflect this change, which has 
no impact on the Corporation's total noninterest income or net 
income, and has no impact on business segment results. For more 
information,  see  Note  1  –  Summary  of  Significant  Accounting 
Principles to the Consolidated Financial Statements. 

Table 1  Summary Income Statement and Selected 

Financial Data 

(Dollars in millions, except per share information) 

2019 

2018 

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 

$ 

$ 

48,891 
42,353 
91,244 
3,590 
54,900 
32,754 
5,324 
27,430 
1,432 

48,162 
42,858 
91,020 
3,282 
53,154 
34,584 
6,437 
28,147 
1,451 

Net income applicable to common 

shareholders 

$ 

25,998 

$ 

26,696 

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 liabilities 
Total common shareholders’ equity 
Total shareholders’ equity 

$ 

$ 

2.77 
2.75 
0.66 

2.64 
2.61 
0.54 

1.14% 

1.21% 

10.62 

14.86 

60.17 

11.04 

15.55 

58.40 

$ 

983,426 
2,434,079 
1,434,803 
2,169,269 
241,409 
264,810 

$  946,895 
2,354,507 
1,381,476 
2,089,182 
242,999 
265,325 

(1)   Return on average tangible common shareholders’ equity is a non-GAAP financial measure. For 
more  information  and  a  corresponding  reconciliation  to  the  most  closely  related  financial 
measures defined by accounting principles generally accepted in the United States of America, 
see Non-GAAP Reconciliations on page 101. 

Net income was $27.4 billion or $2.75 per diluted share in 
2019 compared to $28.1 billion, or $2.61 per diluted share in 
2018.  The  decrease  in  net  income  was  primarily  driven  by  an 
increase  in  noninterest  expense  as  a  result  of  the  $2.1  billion 
pretax impairment charge related to the notice of termination of 
the merchant services joint venture at the conclusion of its current 
term. Also contributing to the decrease in net income were higher 
provision for credit losses and lower noninterest income, partially 
offset by an increase in net interest income. 

For discussion and analysis of our consolidated and business 
segment results of operations for 2018 compared to 2017, see 

the  Financial  Highlights  and  Business  Segment  Operations 
sections in the MD&A of the Corporation's 2018 Annual Report 
on Form 10-K. 

Net Interest Income 
Net  interest  income  increased  $729  million  to  $48.9  billion  in 
2019  compared  2018.  Net  interest  yield  on  a  fully  taxable-
equivalent (FTE) basis decreased two basis points (bps) to 2.43 
percent for 2019. The increase in net interest income was primarily 
driven by loan and deposit growth, partially offset by lower long-
end  rates.  Assuming  a  stable  economic  and  interest  rate 
environment compared to December 31, 2019, we expect quarterly 
net interest income for the first two quarters of 2020 to be lower 
compared to the fourth quarter of 2019 driven by the impact of 
rates and one fewer day of interest accruals. Quarterly net interest 
income is expected to rise modestly in the second half of 2020 
due to one additional day of interest accruals and expected loan 
and deposit growth. For more information on net interest yield and 
the FTE basis, see Supplemental Financial Data on page 48, and 
for  more  information  on  interest  rate  risk  management,  see 
Interest Rate Risk Management for the Banking Book on page 95. 

Noninterest Income 

Table 2  Noninterest Income 

(Dollars in millions) 

Fees and commissions: 

Card income 
Service charges 
Investment and brokerage services 
Investment banking fees 

Total fees and commissions 
Market making and similar activities 
Other income 

$ 

Total noninterest income 

$ 

2019 

2018 

5,797 
7,674 
13,902 
5,642 
33,015 
9,034 
304 
42,353 

$ 

$ 

5,824 
7,767 
14,160 
5,327 
33,078 
9,008 
772 
42,858 

Noninterest  income  decreased  $505  million  to  $42.4  billion  in 
2019 compared to 2018. The following highlights the significant 
changes. 

Service charges decreased $93 million primarily driven by lower 
fees due to policy changes in 2018 and lower ATM volume in 
Consumer Banking. 
Investment and brokerage services income decreased $258 
million  primarily  due  to  lower  transactional  revenue  and  a 
decrease in assets under management (AUM) pricing, partially 
offset by the positive impact of AUM flows and higher market 
valuations. 
Investment  banking  fees  increased  $315  million  due  to 
increases in advisory fees and equity and debt underwriting 
fees. 
Other income decreased $468 million primarily due to lower 
gains  on  sales  of  non-core  consumer  loans  and  higher 
partnership  losses  associated  with  an  increase  in  tax-
advantaged  investments, partially  offset  by  higher  gains  on 
sales of debt securities. 

Bank of America 2019  45 
Bank of America 2019  45   

 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Provision for Credit Losses 
The  provision  for  credit  losses  increased  $308  million  to  $3.6 
billion in 2019 compared to 2018. The increase was primarily due 
to the energy reserve releases in the commercial portfolio in 2018, 
partially offset by the impact of recoveries recorded in connection 
with sales of previously charged-off non-core consumer real estate 
loans. For more information on the provision for credit losses, see 
Provision for Credit Losses on page 89. 

Noninterest Expense 

Table 3  Noninterest Expense 

(Dollars in millions) 

2019 

2018 

Compensation and benefits 
Occupancy and equipment 
Information processing and communications 
Product delivery and transaction related 
Marketing 
Professional fees 
Other general operating 

$ 

31,977  $ 

6,588 
4,646 
2,762 
1,934 
1,597 
5,396 

Total noninterest expense 

$ 

54,900  $ 

31,880 
6,380 
4,555 
2,857 
1,674 
1,699 
4,109 
53,154 

Noninterest  expense  increased  $1.7  billion  to  $54.9  billion  in 
2019 compared to 2018. The increase was primarily due to the 

Balance Sheet Overview 

Table 5  Selected Balance Sheet Data 

aforementioned  impairment  charge  related  to  our  merchant 
services joint venture of $2.1 billion as well as increased costs 
associated with investment in the businesses, including  brand-
related  marketing  costs,  and  higher  litigation expense. These 
were partially offset by efficiency savings, lower Federal Deposit 
Insurance Corporation (FDIC) expense and lower amortization of 
intangibles expense. 

Income Tax Expense 

Table 4  Income Tax Expense 

(Dollars in millions) 

Income before income taxes 
Income tax expense 
Effective tax rate 

2019 

2018 

$ 

$ 

32,754 
5,324 

16.3% 

34,584 
6,437 

18.6% 

The effective tax rates for 2019 and 2018 reflect the impact of 
our recurring tax preference benefits. The 2019 effective rate also 
included  net  tax  benefits  primarily  related  to  the  resolution  of 
various tax controversy matters. 

We expect the effective tax rate for 2020 to be approximately 

18 percent, absent unusual items. 

(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 

2019 

2018 

% Change 

$ 

161,560  $ 
274,597 
229,826 
472,197 
983,426 
(9,416) 
321,889 

177,404 
261,131 
214,348 
441,753 
946,895 
(9,601) 
322,577 
$  2,434,079  $  2,354,507 

$  1,434,803  $  1,381,476 
186,988 
68,220 
20,189 
229,392 
202,917 
2,089,182 
265,325 
$  2,434,079  $  2,354,507 

165,109 
83,270 
24,204 
240,856 
221,027 
2,169,269 
264,810 

(9)% 
5 
7 
7 
4 
(2) 
— 
3 

4 
(12) 
22 
20 
5 
9 
4 
— 
3 

Assets 
At  December  31,  2019,  total  assets  were  approximately  $2.4 
trillion, up $79.6 billion from December 31, 2018. The increase 
in assets was primarily due to higher loans and leases and debt 
securities primarily funded by deposit growth. 

Cash and Cash Equivalents 
Cash  and  cash  equivalents  decreased  $15.8  billion  driven  by 
investment of short-term excess cash into securities purchased 
under agreements to resell, debt securities and growth in loans 
and leases. 

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 $13.5 billion due to investment of 
excess cash levels. 

46 46

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 $15.5 billion primarily driven by 
additional inventory in Global Markets to facilitate 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 
and liquidity risk and to take advantage of market conditions that 
create economically attractive returns on these investments. Debt 
securities  increased  $30.4  billion  primarily  driven  by  the 
deployment  of  deposit  inflows.  For  more  information  on  debt 
securities, see Note 4 – Securities to the Consolidated Financial 
Statements. 

Loans and Leases 
Loans and leases increased $36.5 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 74. 

Allowance for Loan and Lease Losses 
The allowance for loan and lease losses decreased $185 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  more  information, see 
Allowance for Credit Losses on page 89. 

Liabilities 
At December 31, 2019, total liabilities were approximately $2.2 
trillion, up $80.1 billion from December 31, 2018, primarily due 
to deposit growth. 

Deposits 
Deposits increased $53.3 billion primarily due to increases in both 
retail and wholesale 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 
decreased  $21.9  billion  primarily  driven  by  balance  sheet 
efficiencies within Global Markets. 

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 increased $15.1 billion primarily 
due to higher levels of short positions in government and corporate 
bonds driven by 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 increased $4.0 billion primarily due to an increase in 
short-term FHLB advances to manage liquidity needs. For more 
information on short-term borrowings, see Note 11 – 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  $11.5  billion  primarily  driven  by  debt 
issuances and valuation adjustments, partially offset by maturities 
and  redemptions.  For  more  information  on  long-term  debt, see 
Note  12  –  Long-term  Debt  to  the  Consolidated  Financial 
Statements. 

All Other Liabilities 
All other liabilities increased $18.1 billion primarily driven by an 
increase in broker-dealer payables within Global Markets due to 
timing of unsettled trades and an increase in lease liabilities due 
to implementation of the new lease accounting standard. 

Shareholders’ Equity 
Shareholders’ equity decreased $515 million driven by returns of 
capital to shareholders through share repurchases, common and 
preferred stock dividends of $35.7 billion, as well as redemption 
of  preferred  stock,  largely  offset  by  earnings,  market  value 
increases on debt securities and issuances of preferred stock. 

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 71. 

Bank of America 2019  47 
Bank of America 2019  47   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 accounting 
principles  generally  accepted  in  the  United  States  of  America 
(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 use the 
federal statutory tax rate of 21 percent for 2019 and 2018 (35 
percent for 2017) 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 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 shareholders’ equity or common shareholders’ 

equity  reduced  by  goodwill  and  intangible  assets  (excluding 
mortgage  servicing  rights  (MSRs)),  net  of  related  deferred  tax 
("adjusted"  shareholders'  equity  or  common 
liabilities 
shareholders' equity). These measures are used to evaluate our 
use of equity. In addition, profitability, relationship and investment 
models  use  both 
tangible  common 
return  on  average 
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 net income applicable to common shareholders 
as a percentage of adjusted average common shareholders’ 
equity. The tangible common equity ratio represents adjusted 
ending common shareholders’ equity divided by total tangible 
assets. 
Return on average tangible shareholders' equity measures our 
net  income  as  a  percentage  of  adjusted  average  total 
shareholders’  equity.  The  tangible  equity  ratio  represents 
adjusted ending shareholders’ equity divided by total tangible 
assets. 
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  common  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 6 and 7. 

For more information on the reconciliation of these non-GAAP 
financial measures to the corresponding GAAP financial measures, 
see Non-GAAP Reconciliations on page 101. 

48 48

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 6  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) 

2019 

2018 

2017 

2016 

2015 

$ 

48,891 
42,353 
91,244 
3,590 
54,900 
32,754 
5,324 
27,430 
25,998 
9,390.5 
9,442.9 

$ 

48,162 
42,858 
91,020 
3,282 
53,154 
34,584 
6,437 
28,147 
26,696 
10,096.5 
10,236.9 

$ 

45,239 
41,887 
87,126 
3,396 
54,517 
29,213 
10,981 
18,232 
16,618 
10,195.6 
10,778.4 

$ 

41,486 
42,012 
83,498 
3,597 
54,880 
25,021 
7,199 
17,822 
16,140 
10,248.1 
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 

1.14% 

1.21% 

10.62 
14.86 
10.24 
13.85 
10.88 
11.14 
23.65 

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 

$ 

2.77 
2.75 
0.66 
27.32 
19.41 
$  311,209 

$  958,416 
2,405,830 
1,380,326 
201,623 
244,853 
267,889 

$ 

2.64 
2.61 
0.54 
25.13 
17.91 
$  238,251 

$  933,049 
2,325,246 
1,314,941 
200,399 
241,799 
264,748 

$ 

1.63 
1.56 
0.39 
23.80 
16.96 
$  303,681 

$  918,731 
2,268,633 
1,269,796 
194,882 
247,101 
271,289 

$ 

1.57 
1.49 
0.25 
23.97 
16.89 
$  222,163 

$  900,433 
2,190,218 
1,222,561 
204,826 
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 

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) 

$ 

10,229 
3,837 

$ 

10,398 
5,244 

$ 

11,170 
6,758 

$ 

11,999 
8,084 

$ 

12,880 
9,836 

0.97% 

1.02% 

1.12% 

1.26% 

1.37% 

265 

194 

161 

149 

130 

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

$ 

3,648 

$ 

3,763 

$ 

3,979 

$ 

3,821 

$ 

4,338 

0.38% 

0.41% 

0.44% 

0.43% 

0.50% 

Capital ratios at year end (5) 

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

11.2% 
12.6 
14.7 
7.9 
6.4 
8.2 
7.3 

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% 

11.2 
12.8 
8.4 
n/a 
8.9 
7.8 

(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 48 and Non-GAAP Reconciliations on page 101. 

(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 non-U.S. consumer credit card business was sold 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 80 and corresponding Table 29 and Commercial Portfolio Credit Risk Management 
– Nonperforming Commercial Loans, Leases and Foreclosed Properties Activity on page 84 and corresponding Table 36. 

(5)  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 more 

information, including which approach is used to assess capital adequacy, see Capital Management on page 66. 

n/a = not applicable 

Bank of America 2019  49 

Bank of America 2019  49   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 7  Selected Quarterly 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 
Four-quarter trailing return on average assets (1) 
Return on average common shareholders’ equity 
Return on average tangible common shareholders’ equity (2) 
Return on average shareholders’ equity 
Return on average tangible shareholders’ equity (2) 
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 (2) 

Market capitalization 
Average balance sheet 

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

Asset quality 

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) 

2019 Quarters 

2018 Quarters 

Fourth 

Third 

Second 

First 

Fourth 

Third 

Second 

First 

$  12,140 
10,209 
22,349 
941 
13,239 
8,169 
1,175 
6,994 
6,748 
9,017.1 
9,079.5 

$  12,187 
10,620 
22,807 
779 
15,169 
6,859 
1,082 
5,777 
5,272 
9,303.6 
9,353.0 

$  12,189 
10,895 
23,084 
857 
13,268 
8,959 
1,611 
7,348 
7,109 
9,523.2 
9,559.6 

$  12,375 
10,629 
23,004 
1,013 
13,224 
8,767 
1,456 
7,311 
6,869 
9,725.9 
9,787.3 

$  12,504 
10,173 
22,677 
905 
13,074 
8,698 
1,420 
7,278 
7,039 
9,855.8 
9,996.0 

$  12,061 
10,663 
22,724 
716 
13,014 
8,994 
1,827 
7,167 
6,701 
10,031.6 
10,170.8 

$  11,828 
10,721 
22,549 
827 
13,224 
8,498 
1,714 
6,784 
6,466 
10,181.7 
10,309.4 

$  11,769 
11,301 
23,070 
834 
13,842 
8,394 
1,476 
6,918 
6,490 
10,322.4 
10,472.7 

1.13% 
1.14 
11.00 
15.43 
10.40 
14.09 
10.88 
10.89 
23.90 

0.95% 
1.17 
8.48 
11.84 
8.48 
11.43 
11.06 
11.21 
31.48 

1.23% 
1.24 
11.62 
16.24 
11.00 
14.88 
11.33 
11.17 
19.95 

1.26% 
1.22 
11.42 
16.01 
11.14 
15.10 
11.23 
11.28 
21.20 

1.24% 
1.21 
11.57 
16.29 
10.95 
14.90 
11.27 
11.30 
20.90 

1.23% 
1.00 
10.99 
15.48 
10.74 
14.61 
11.21 
11.42 
22.35 

1.17% 
0.93 
10.75 
15.15 
10.26 
13.95 
11.53 
11.42 
18.83 

1.21% 
0.86 
10.85 
15.26 
10.57 
14.37 
11.43 
11.41 
19.06 

$ 

0.75 
0.74 
0.18 
27.32 
19.41 
$  311,209 

$  973,986 
450,005 
2,
410,439 
1,
206,026 
243,439 
266,900 

$ 

0.57 
0.56 
0.18 
26.96 
19.26 
$  264,842 

$  964,733 
12,223 
2,4
75,052 
1,3
02,620 
2
46,630 
2
70,430 
2

$ 

0.75 
0.74 
0.15 
26.41 
18.92 
$  270,935 

$  950,525 
99,051 
2,3
75,450 
1,3
01,007 
2
45,438 
2
67,975 
2

$ 

0.71 
0.70 
0.15 
25.57 
18.26 
$  263,992 

$  944,020 
60,992 
2,3
59,864 
1,3
96,726 
1
43,891 
2
66,217 
2

$ 

0.71 
0.70 
0.15 
25.13 
17.91 
$  238,251 

$  934,721 
34,586 
2,3
44,951 
1,3
01,056 
2
41,372 
2
63,698 
2

$ 

0.67 
0.66 
0.15 
24.33 
17.23 
$  290,424 

$  930,736 
17,829 
2,3
16,345 
1,3
03,239 
2
41,812 
2
64,653 
2

$ 

0.64 
0.63 
0.12 
24.07 
17.07 
$  282,259 

$  934,818 
22,678 
2,3
00,659 
1,3
199,448 
241,313 
265,181 

$ 

0.63 
0.62 
0.12 
23.74 
16.84 
$  305,176 

$  931,915 
25,878 
2,3
97,268 
1,2
97,787 
1
42,713 
2
65,480 
2

$ 

10,229 
3,837 

$ 

10,242 
3,723 

$ 

10,333 
4,452 

$ 

10,379 
5,145 

$ 

10,398 
5,244 

$ 

10,526 
5,449 

$ 

10,837 
6,181 

$ 

11,042 
6,694 

0.97% 

0.98% 

1.00% 

1.02% 

1.02% 

1.05% 

1.08% 

1.11% 

Net charge-offs 
Annualized net charge-offs as a percentage of average loans 

$ 

and leases outstanding (4) 

Capital ratios at period end 

Common equity tier 1 capital 
Tier 1 capital 
Total capital 
Tier 1 leverage 
Supplementary leverage ratio 
Tangible equity (2) 
Tangible common equity (2) 

265 

959 

$ 

271 

811 

$ 

228 

887 

$ 

197 

991 

$ 

194 

924 

$ 

189 

932 

$ 

170 

996 

$ 

161 

911 

0.39% 

0.34% 

0.38% 

0.43% 

0.39% 

0.40% 

0.43% 

0.40% 

11.2% 
12.6 
14.7 
7.9 
6.4 
8.2 
7.3 

11.4% 
12.9 
15.1 
8.2 
6.6 
8.4 
7.4 

11.7% 
13.3 
15.4 
8.4 
6.8 
8.7 
7.6 

11.6% 
13.1 
15.2 
8.4 
6.8 
8.5 
7.6 

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 

Total loss-absorbing capacity and long-term debt metrics (5) 
Total loss-absorbing capacity to risk-weighted assets 
Total loss-absorbing capacity to supplementary leverage 

exposure 

Eligible long-term debt to risk-weighted assets 
Eligible long-term debt to supplementary leverage 

24.6% 

24.8% 

25.5% 

24.8% 

12.5 

11.5 
5.8 

12.7 

11.4 
5.8 

13.0 

11.8 
6.0 

12.8 

11.4 
5.9 

(1)  Calculated as total net income for four consecutive quarters divided by annualized average assets for four consecutive quarters. 
(2)   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 48 and Non-GAAP Reconciliations on page 101. 
Includes the allowance for loan and lease 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 80 and corresponding Table 29 and Commercial Portfolio Credit Risk Management 
– Nonperforming Commercial Loans, Leases and Foreclosed Properties Activity on page 84 and corresponding Table 36. 

(5)  Effective January 1, 2019, we became subject to minimum total loss-absorbing capacity and long-term debt requirements. For more information, see Capital Management on page 66. 

50 50

Bank of America 2019 
Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 8  Average Balances and Interest Rates - FTE Basis 

(Dollars in millions) 

Earning assets 

Interest-bearing deposits with the Federal Reserve, non-

Average 
Balance 

Interest 
Income/ 
Expense (1) 

2019 

Yield/ 
Rate 

Average 
Balance 

Interest 
Income/ 
Expense (1) 

2018 

Yield/ 
Rate 

Average 
Balance 

Interest 
Income/ 
Expense (1) 

2017 

Yield/ 
Rate 

U.S. central banks and other banks 

$ 

125,555 

$ 

1,823 

1.45%  $  139,848  $ 

1,926 

1.38%  $  127,431  $ 

1,122 

Time deposits placed and other short-term investments 

9,427 

207 

2.19 

9,446 

216 

2.29 

12,112 

241 

Federal funds sold and securities borrowed or purchased 

under agreements to resell 

Trading account assets 

Debt securities 

Loans and leases (2): 

Residential mortgage 

Home equity 

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 

Total earning assets 

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 

979,057 

7,188 

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 

276,432 

45,449 

201,623 

7,208 

1,249 

6,700 

Total interest-bearing liabilities 

1,502,561 

22,345 

Noninterest-bearing sources: 

Noninterest-bearing deposits 

Other liabilities (6) 

Shareholders’ equity 

401,269 

234,111 

267,889 

Total liabilities and shareholders’ equity 

$  2,405,830 

Net interest spread 

Impact of noninterest-bearing sources 

Net interest income/yield on earning assets (7) 

$  49,486 

279,610 

148,076 

450,090 

220,552 

44,600 

94,488 

— 

90,656 

450,296 

321,467 

103,918 

62,044 

20,691 

508,120 

958,416 

69,089 

2,040,263 

26,193 

339,374 

$  2,405,830 

4,843 

5,269 

11,917 

7,651 

2,194 

1.73 

3.56 

2.65 

3.47 

4.92 

10,166 

10.76 

— 

3,261 

23,272 

13,016 

3,547 

2,741 

718 

20,022 

43,294 

4,478 

71,831 

— 

3.60 

5.17 

4.05 

3.41 

4.42 

3.47 

3.94 

4.52 

6.48 

3.52 

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 

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 

1,980,231 

67,379 

25,830 

319,185 

$  2,325,246 

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 

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 

1,806 

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 

1,922,061 

58,112 

27,995 

318,577 

$  2,268,633 

$ 

52,020 

$ 

5 

0.01%  $ 

54,226  $ 

6 

0.01%  $ 

53,783  $ 

741,126 

47,577 

66,866 

907,589 

1,936 

181 

69,351 

71,468 

4,471 

471 

1,407 

6,354 

20 

— 

814 

834 

0.60 

0.99 

2.11 

0.70 

1.04 

0.05 

1.17 

1.17 

0.73 

2.61 

2.75 

3.32 

1.49 

676,382 

2,636 

39,823 

50,593 

157 

991 

821,024 

3,790 

2,312 

810 

65,097 

68,219 

39 

— 

666 

705 

889,243 

4,495 

269,748 

50,928 

200,399 

5,839 

1,358 

6,915 

1,410,318 

18,607 

0.39 

0.39 

1.96 

0.46 

1.69 

0.01 

1.02 

1.03 

0.51 

2.17 

2.67 

3.45 

1.32 

628,647 

44,794 

36,782 

5 

873 

121 

354 

764,006 

1,353 

2,442 

1,006 

62,386 

65,834 

21 

10 

547 

578 

829,840 

1,931 

274,975 

45,518 

194,882 

3,146 

1,204 

5,667 

1,345,215 

11,948 

425,698 

224,482 

264,748 

$  2,325,246 

439,956 

212,173 

271,289 

$  2,268,633 

2.03% 

0.40 

2.43% 

2.08% 

0.37 

2.45% 

$  48,772 

$  46,164 

0.88% 

1.99 

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 

0.01% 

0.14 

0.27 

0.96 

0.18 

0.85 

0.95 

0.88 

0.88 

0.23 

1.14 

2.64 

2.91 

0.89 

2.13% 

0.27 

2.40% 

(1) 

Includes the impact of interest rate risk management contracts. For more information, see Interest Rate Risk Management for the Banking Book on page 95. 
(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 $2.9 billion, $2.8 billion and $2.9 billion for 2019, 2018 and 2017, respectively. 
Includes U.S. commercial real estate loans of $57.3 billion, $56.4 billion and $55.0 billion, and non-U.S. commercial real estate loans of $4.7 billion, $4.0 billion and $3.5 billion for 2019, 2018 
and 2017, respectively. 
Includes $35.5 billion, $30.4 billion and $30.3 billion of structured notes and liabilities for 2019, 2018 and 2017, respectively. 

(4) 

(5) 

(6) 

(7)  Net interest income includes FTE adjustments of $595 million, $610 million and $925 million for 2019, 2018 and 2017, respectively. 

Bank of America 2019  51 
Bank of America 2019  51   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 9  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 

banks 

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 
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 

Due to Change in (1) 
Rate 
Volume 
From 2018 to 2019 

Net Change 

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

Net Change 

$ 

(193)  $ 

90  $ 

(103)  $ 

109  $ 

695  $ 

804 

— 
347 
563 
135 

447 
(446) 
(17) 
—
(76) 

665 
209 
75 
(28) 

(9) 
1,320 
(195) 
(55) 

(90) 
67 
604 
— 
233 

414 
118 
48 
48 

(417) 

595 

$ 

(9) 
1,667 
368 
80 

357 
(379) 
587 
— 
157 
722 
1,079 
327 
123 
20 
1,549 
2,271 
178 
4,452 

$ 

(1)  $ 

—  $ 

(1)  $ 

254 
29 
320 

(6) 
— 
41 

1,581 
285 
96 

(13) 
— 
107 

1,835 
314 
416 
2,564 

(19) 
— 
148 
129 
2,693 

(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 

$ 

1  $ 

1,689 
49 
505 

—  $ 
74 
(13) 
132 

(1) 
(2) 
26 

19 
(8) 
93 

(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 

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

short-term borrowings and other interest-bearing liabilities 

160 

1,209 

1,369 

(71) 

2,764 

2,693 

Trading account liabilities 
Long-term debt 

154 
1,248 
6,659 
2,608 
(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 

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

(109) 
(215) 
3,738 
714 

14 
1,083 

(145) 
41 

36 
(256) 

140 
165 

$ 

$ 

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 decreases in FTE basis adjustments of $15 million from 2018 to 2019 and $315 million from 2017 to 2018. 

52 52

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Business Segment Operations 

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 
Markets, with the remaining operations recorded in All Other. We manage our segments and report their results on an FTE basis. The 
primary activities, products and businesses of the business segments and All Other are shown below. 

We  periodically  review  capital  allocated  to  our  businesses  and 
allocate capital annually during the strategic and capital planning 
processes. We utilize a methodology that considers the effect of 
regulatory capital requirements in addition to internal risk-based 
capital models. Our internal risk-based capital models use a risk-
adjusted  methodology  incorporating  each  segment’s  credit, 
market, interest rate, business and operational risk components. 
For more information on the nature of these risks, see Managing 
Risk on page 63. The capital allocated to the business segments 
is referred to as allocated capital. Allocated equity in the reporting 

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

For  more  information  on  our  presentation  of  financial 
information on an FTE basis, see Supplemental Financial Data on 
page 48, and for reconciliations to consolidated total revenue, net 
income and year-end total assets, see Note 24 – Business Segment 
Information to the Consolidated Financial Statements. 

Bank of America 2019  53 
Bank of America 2019  53   

 
 
 
 
 
 
 
 
 
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 

Deposits 

Consumer Lending 

2019 

2018 

2019 

2018 

Total Consumer Banking 
2018 

2019 

% Change 

$ 

16,904 

$ 

15,939 

$ 

11,254 

$ 

11,086 

$ 

28,158 

$ 

27,025 

4% 

(33) 
4,217 
832 
5,016 
21,920 

269 
10,682 
10,969 
2,687 
8,282  $ 

(33) 
4,298 
762 
5,027 
20,966 

195 
10,657 
10,114 
2,578 
7,536 

2.40% 
69 
48.73 

2.34% 
63 
50.83 

$ 

5,373 
703,444 
735,232 
702,908 
12,000 

5,233 
682,592 
710,925 
678,640 
12,000 

$ 

$ 

$ 

$ 

5,117 
2 
294 
5,413 
16,667 

3,503 
6,936 
6,228 
1,526 
4,702  $ 

5,135 
2 
429 
5,566 
16,652 

3,469 
7,015 
6,168 
1,572 
4,596 

5,084 
4,219 
1,126 
10,429 
38,587 

3,772 
17,618 
17,197 
4,213 

$ 

12,984  $ 

5,102 
4,300 
1,191 
10,593 
37,618 

3,664 
17,672 
16,282 
4,150 
12,132 

24.5% 

25.5% 

3.80% 
19 
41.61 

3.97% 
18 
42.12 

3.81 
35 
45.66 

3.77 
33 
46.98 

295,562 
296,051 
306,169 
5,368 
25,000 

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

$ 

300,935 
738,770 
780,676 
708,276 
37,000 

$  283,807 
717,189 
756,373 
684,173 
37,000 

— 
(2) 
(5) 
(2) 
3 

3 
— 
6 
2 
7 

6% 
3 
3 
4 
— 

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

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

$  294,335 
728,813 
768,881 
696,146 

5,470 
694,672 
724,019 
691,666 

5,472 
724,536 
758,385 
725,598 

311,942 
312,684 
322,717 
5,080 

317,414 
760,137 
804,019 
730,678 

8% 
4 
5 
5 

$ 

$ 

$ 

$ 

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 38 states and the District 
of Columbia. Our network includes approximately 4,300 financial 
centers, approximately  16,800  ATMs, nationwide  call  centers, 
and leading digital banking platforms with more than 38 million 
active users, including over 29 million active mobile users. 

Consumer Banking Results 
Net  income  for  Consumer  Banking  increased  $852  million  to 
$13.0 billion in 2019 compared to 2018 primarily driven by higher 
net  interest  income  and  lower  noninterest  expense,  partially 
offset by lower noninterest income. Net interest income increased 
$1.1 billion to $28.2 billion primarily due to growth in deposits 
and loans. Noninterest income decreased $164 million to $10.4 
billion  driven  by  lower  service  charges  and  lower  mortgage 
banking  income,  largely  offset  by  higher  results  from  ALM 
activities. 

The provision for credit losses increased $108 million to $3.8 
billion driven by overdrafts and portfolio seasoning in the credit 
card  portfolio.  Noninterest  expense  decreased  $54  million  to 

$17.6 billion primarily driven by lower FDIC expense and operating 
efficiencies,  partially  offset  by  continued  investment  in  the 
business. 

The return on average allocated capital was 35 percent, up 
from 33 percent, driven by higher net income. For information on 
capital  allocated  to  the  business  segments,  see  Business 
Segment Operations on page 53. 

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. 

54 54

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Net income for Deposits increased $746 million to $8.3 billion 
driven  by  higher  net  interest  income.  Net  interest  income 
increased $965 million to $16.9 billion primarily due to growth 
in deposits and pricing discipline. Noninterest income decreased 
$11  million  to  $5.0  billion  primarily  driven  by  lower  service 
charges, largely offset by higher results from ALM activities. 

The provision for credit losses increased $74 million to $269 
million in 2019. Noninterest expense increased $25 million to 
$10.7  billion  driven  by  continued  investment  in  the  business, 
partially offset by lower FDIC expense and operating efficiencies. 
Average deposits increased $24.3 billion to $702.9 billion in 
2019 driven by strong organic growth. Growth in checking and 
time deposits of $27.0 billion was partially offset by a decline in 
traditional savings and money market savings of $2.5 billion. 

Net income for Consumer Lending increased $106 million to 
$4.7  billion  driven  by  higher  net  interest  income  and  lower 
noninterest expense, partially offset by lower noninterest income. 
Net interest income increased $168 million to $11.3 billion driven 
by loan growth. Noninterest income decreased $153 million to 
$5.4 billion primarily driven by lower mortgage banking income 
and lower card income. 

The provision for credit losses increased $34 million to $3.5 
billion primarily driven by portfolio seasoning in the credit card 
portfolio.  Noninterest  expense  decreased  $79  million  to  $6.9 
billion primarily driven by operating efficiencies. 

Average  loans  increased  $17.0  billion  to  $295.6  billion 
primarily driven by increases in residential mortgages and credit 
card, partially offset by lower home equity loans. 

Key Statistics – Deposits 

Key Statistics – Consumer Lending 

Total deposit spreads (excludes noninterest costs) (1) 

2.34% 

2.14% 

Total credit card (1) 

2019 

2018 

(Dollars in millions) 

2019 

2018 

Year end 
Consumer investment assets (in millions) (2) 
Active digital banking users (units in thousands) (3) 
Active mobile banking users (units in thousands) 
Financial centers 
ATMs 
(1) 

$ 240,132 
38,266 
29,174 
4,300 
16,788 

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

Gross interest yield 
Risk-adjusted margin 
New accounts (in thousands) 
Purchase volumes 

Debit card purchase volumes 
(1) 

Includes GWIM's credit card portfolio. 

10.76% 
8.28 
4,320 
$ 277,852 
$ 360,672 

10.12% 
8.25 
4,544 
$264,706 
$338,810 

Includes deposits held in Consumer Lending. 
Includes client brokerage assets, deposit sweep balances and AUM in Consumer Banking. 

(2) 

(3)  Active digital banking users represents mobile and/or online users. 

Consumer investment assets increased $54 billion in 2019 
driven  by  strong  market  performance  and  client  flows.  Active 
mobile banking users increased 3 million reflecting continuing 
changes in our customers’ banking preferences. The number of 
financial  centers  declined  by  a  net  41  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 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. 

During  2019,  the  total  credit  card  risk-adjusted  margin 
increased 3 bps compared to 2018, primarily driven by a portfolio 
shift away from promotional-rate loans. Total credit card purchase 
volumes increased $13.1 billion to $277.9 billion, and debit card 
purchase  volumes  increased  $21.9  billion  to  $360.7  billion, 
reflecting higher levels of consumer spending. 

Key Statistics – Loan Production (1) 

(Dollars in millions) 

Total (2): 

First mortgage 
Home equity 

2019 

2018 

$  72,467 
11,131 

$  41,195 
14,869 

Consumer Banking: 
First mortgage 
Home equity 

$  27,280 
13,251 
(1)   The loan production amounts represent the unpaid principal balance of loans and, in the case 

$  49,179 
9,755 

of home equity, the principal amount of the total line of credit. 

(2)   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 increased $21.9 billion and $31.3 billion 
in  2019  primarily  driven  by  a  lower  interest  rate  environment 
driving higher first-lien mortgage refinances. 

Home equity production in Consumer Banking and for the total 
Corporation  decreased  $3.5  billion  and  $3.7  billion  in  2019 
primarily driven by lower demand. 

Bank of America 2019  55 
Bank of America 2019  55   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 

2019 

2018 

% Change 

$ 

6,504 

$ 

6,265 

4% 

11,870 
1,163 
13,033 
19,537 

82 
13,823 
5,632 
1,380 
4,252 

$ 

11,959 
1,229 
13,188 
19,453 

86 
14,015 
5,352 
1,364 
3,988 

24.5% 

25.5% 

2.33 
29 
70.75 

2.41 
28 
72.04 

$ 

$ 

168,910 
279,684 
292,003 
256,505 
14,500 

176,600 
287,212 
299,756 
263,103 

161,342 
259,808 
277,220 
241,256 
14,500 

164,854 
287,199 
305,907 
268,700 

$ 

$ 

$ 

(1) 
(5) 
(1) 
— 

(5) 
(1) 
5 
1 
7 

5% 
8 
5 
6 
— 

7% 
— 
(2) 
(2) 

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

Bank of America Private Bank, together with MLGWM’s Private 
Wealth  Management  business, 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 $264 million to $4.3 billion 
due  to  lower  noninterest  expense  and  higher  revenue.  The 
operating margin was 29 percent compared to 28 percent in 2018. 

Net interest income increased $239 million to $6.5 billion due 

to the impact of growth in deposits and loans. 

Noninterest income, which primarily includes investment and 
brokerage  services  income,  decreased  $155  million  to  $13.0 
billion.  The  decrease  was  primarily  driven  by  declines  in  AUM 
pricing and transactional revenue, partially offset by the impact of 
positive AUM flows and higher market valuations. 

Noninterest expense decreased $192 million to $13.8 billion, 
as investments for business growth were more than offset by lower 
amortization of intangibles and FDIC expense. 

The  return  on  average  allocated  capital  was  29  percent, up 

from 28 percent, due to higher net income. 

MLGWM  revenue  of  $16.1  billion  increased  one  percent 
primarily driven by higher net interest income and the impact of 
positive AUM flows and higher market valuations, partially offset 
by lower transactional volumes and AUM pricing. 

Bank of America Private Bank revenue of $3.4 billion decreased 

one percent primarily due to lower net interest income. 

56 56

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Key Indicators and Metrics 

(Dollars in millions, except as noted) 

Revenue by Business 
Merrill Lynch Global Wealth Management 
Bank of America Private Bank 

Total revenue, net of interest expense 

Client Balances by Business, at year end 
Merrill Lynch Global Wealth Management 
Bank of America Private Bank 

Total client balances 

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

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 
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 (in thousands) 

Bank of America Private Bank Metric, at year end 
Primary sales professionals 
(1) 

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

2019 

2018 

16,111 
3,426 
19,537 

2,558,102 
489,690 
3,047,792 

1,275,555 
1,372,733 
263,103 
179,296 
(42,895) 
3,047,792 

1,072,234 
24,865 
178,456 
1,275,555 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

15,998 
3,455 
19,453 

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

1,072,234 
1,162,997 
268,700 
167,938 
(51,013) 
2,620,856 

1,121,383 
44,607 
(93,756) 
1,072,234 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

17,458 
19,440 
20,586 

17,518 
19,459 
20,586 

$ 

1,082  $ 

1,034 

1,766 

1,748 

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  increased  $426.9  billion, or  16  percent, to 
$3.0 trillion at December 31, 2019 compared to December 31, 
2018. The increase in client balances was primarily due to higher 
market valuations and positive net flows over the last year. 

Bank of America 2019  57 
Bank of America 2019  57   

 
 
 
 
 
 
 
 
 
 
 
 
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 
n/m = not meaningful 

2019 

2018 

% Change 

$ 

10,675 

$ 

10,993 

(3)% 

3,015 
3,137 
3,656 
9,808 
20,483 

414 
9,017 
11,052 
2,984 
8,068 

$ 

3,027 
2,891 
3,090 
9,008 
20,001 

8 
8,745 
11,248 
2,923 
8,325 

27.0% 

26.0% 

2.75 
20 
44.02 

3.01 
20 
43.72 

$ 

$ 

374,304 
388,152 
443,083 
362,731 
41,000 

379,268 
407,180 
464,032 
383,180 

354,236 
364,748 
425,675 
336,337 
41,000 

365,717 
377,812 
442,330 
360,248 

$ 

$ 

$ 

— 
9 
18 
9 
2 

n/m 
3 
(2) 
2 
(3) 

6 % 
6 
4 
8 
— 

4 % 
8 
5 
6 

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 decreased $257 million to $8.1 
billion  in  2019  compared  to  2018  primarily  driven  by  higher 
provision for credit losses and noninterest expense partially offset 
by higher revenue. 

Revenue  increased  $482  million  to  $20.5  billion  driven  by 
higher  noninterest  income, partially  offset  by  lower  net  interest 
income.  Net  interest  income  decreased  $318  million  to  $10.7 
billion  primarily  due  to  the  allocation  of  ALM  results  and  credit 
spread compression, partly offset by growth in loan and deposit 
balances. 

Noninterest  income  increased  $800  million  to  $9.8  billion 
primarily  due  to  higher  leasing-related  revenue  and  investment 
banking  fees.  The  provision  for  credit  losses  increased  $406 
million to $414 million primarily driven by reserve releases in 2018 
primarily from energy exposures. Noninterest expense increased 
$272 million primarily due to continued investment in the business 
partially offset by lower FDIC expense. 

The return on average allocated capital was 20 percent in 2019 
and 2018. For information on capital allocated to the business 
segments, see Business Segment Operations on page 53. 

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. 

58 58

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 

Global Corporate Banking 

Global Commercial Banking 

Business Banking 

Total 

2019 

2018 

2019 

2018 

2019 

2018 

2019 

2018 

Business Lending 
Global Transaction Services 

Total revenue, net of interest expense 

$ 

$ 

3,994  $ 
3,994 
7,988  $ 

3,904  $ 
3,832 
7,736  $ 

4,132  $ 
3,499 
7,631  $ 

4,330  $ 
3,346 
7,676  $ 

363  $ 

1,064 
1,427  $ 

431  $ 
987 
1,418  $ 

8,489  $ 
8,557 

17,046  $ 

8,665 
8,165 
16,830 

Balance Sheet 

Average 
Total loans and leases 
Total deposits 

Year end 
Total loans and leases 
Total deposits 

$  177,713  $  163,516  $  181,485  $  174,279  $ 

177,924 

163,559 

144,620 

135,337 

15,058  $ 
40,196 

16,432  $  374,256  $  354,227 
362,740 
336,358 
37,462 

$  181,409  $  174,378  $  182,727  $  175,937  $ 

185,352 

173,183 

157,322 

149,118 

15,152  $ 
40,504 

15,402  $  379,288  $  365,717 
383,178 
360,274 
37,973 

Business  Lending  revenue  decreased  $176  million  in  2019 
compared  to  2018.  The  decrease  was  primarily  driven  by  the 
allocation of ALM results, partly offset by higher leasing-related 
revenue. 

Global Transaction Services revenue increased $392 million in 
2019 compared to 2018 driven by the impact of higher deposit 
balances. 

Average  loans  and  leases  increased  six  percent  in  2019 
compared  to  2018  driven  by  growth  in  the  commercial  and 
industrial portfolio. 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 

2019 

2018 

Total Corporation 
2019 
2018 

$  1,336  $  1,153  $  1,460  $  1,258 
3,084 
1,183 

1,326 
412 

3,107 
1,259 

1,348 
453 

3,137 

2,891 

(62) 

(68) 

5,826 

(184) 

5,525 

(198) 

$  3,075  $  2,823  $  5,642  $  5,327 

Total Corporation investment banking fees, excluding self-led 
deals, of $5.6 billion, which are primarily included within Global 
Banking  and  Global  Markets,  increased  six  percent  due  to 
increases in advisory fees as well as higher equity issuance fees. 

Bank of America 2019  59 
Bank of America 2019  59   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Global Markets 

(Dollars in millions) 

Net interest income 
Noninterest income: 

Investment and brokerage services 
Investment banking fees 
Market making and similar activities 
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 
n/m = not meaningful 

2019 

2018 

% Change 

$ 

3,915 

$ 

3,857 

2% 

1,738 
2,288 
7,065 
608 
11,699 
15,614 

(9) 
10,722 
4,901 
1,397 
3,504 

$ 

1,780 
2,296 
7,260 
990 
12,326 
16,183 

— 
10,835 
5,348 
1,390 
3,958 

28.5% 

26.0% 

10 
68.67 

11 
66.96 

$ 

$ 

246,335 
116,883 
83,216 
43,271 
489,705 
71,334 
476,225 
679,297 
31,380 
35,000 

452,496 
72,993 
471,701 
641,806 
34,676 

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

447,998 
73,928 
457,224 
641,923 
37,841 

$ 

$ 

$ 

(2) 
— 
(3) 
(39) 
(5) 
(4) 

n/m 
(1) 
(8) 
1 
(11) 

15% 
(7) 
5 
(6) 
5 
(2) 
1 
2 
1 
— 

1% 
(1) 
3 
— 
(8) 

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 59. 

internal 

The following explanations for year-over-year changes in results 
for  Global  Markets,  including  those  disclosed  under  Sales  and 
Trading Revenue, exclude net DVA, but the explanations would be 
the same if net DVA was included. 

Net income for Global Markets decreased $454 million to $3.5 
billion  in  2019  compared  to  2018.  Net  DVA  losses  were  $222 
million compared to losses of $162 million in 2018. Excluding net 
DVA, net income decreased $408 million to $3.7 billion. These 
decreases were primarily driven by a decrease in revenue, partially 
offset by lower noninterest expense. 

Revenue declined $569 million to $15.6 billion as sales and 
trading revenue decreased $492 million, and excluding net DVA, 
decreased $432 million. These decreases were primarily driven 
by a decline in Equities revenue. Noninterest expense decreased 
$113 million to $10.7 billion, primarily driven by lower revenue-
related expenses. 

Average total assets increased $13.3 billion to $679.3 billion, 
primarily  due  to  increased  levels  of  inventory  in  fixed-income, 
currencies  and  commodities  (FICC)  to  facilitate  expected  client 
demand. Year-end total assets were largely unchanged at $641.8 
billion. 

The return on average allocated capital was 10 percent, down 
from 11 percent, reflecting lower net income. For information on 

60 60

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
capital  allocated  to  the  business  segments,  see  Business 
Segment Operations on page 53. 

Sales and Trading Revenue (1, 2, 3) 

Sales and Trading Revenue 
Sales and trading revenue includes unrealized and realized gains 
and  losses  on  trading  and  other  assets  which  are  included  in 
market making and similar activities, 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 
obligations,  commercial  MBS,  residential  mortgage-backed 
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 48. 

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) 

(Dollars in millions) 

Sales and trading revenue (2) 

2019 

2018 

Fixed-income, currencies and commodities 
Equities 

Total sales and trading revenue 

$ 

$ 

8,188 
4,491 
12,679 

$ 

$ 

8,271 
4,900 
13,171 

Sales and trading revenue, excluding net DVA (4) 
Fixed-income, currencies and commodities 
Equities 

8,413 
4,920 
13,333 
(1)   For more information on sales and trading revenue, see Note 3 – Derivatives to the Consolidated 

Total sales and trading revenue, excluding net DVA 

8,396 
4,505 
12,901 

$ 

$ 

$ 

$ 

Financial Statements. 
Includes FTE adjustments of $189 million and $248 million for 2019 and 2018. 

(2) 

(3)   Includes Global Banking sales and trading revenue of $533 million and $421 million for 2019 

and 2018. 

(4)   FICC and Equities sales and trading revenue, excluding net DVA, is a non-GAAP financial measure. 
FICC net DVA losses were $208 million and $142 million for 2019 and 2018. Equities net DVA 
losses were $14 million and $20 million for 2019 and 2018. 

FICC  revenue  decreased  $17  million.  Equities  revenue 
decreased  $415  million  driven  by  under  performance  in  equity 
derivatives compared to a strong prior year which benefited from 
higher client activity and a more volatile market environment. 

2019 

2018 

% Change 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

234 
(2,616) 
(2,382) 

(669) 
3,720 
(5,433) 
(4,055) 
(1,378) 

42,933 
210,771 
21,434 

37,151 
224,466 
23,166 

632 
(2,257) 
(1,625) 

(476) 
1,887 
(3,036) 
(2,780) 
(256) 

61,013 
199,978 
21,966 

48,061 
195,466 
18,541 

(63)% 
16 
47 

41 
97 
79 
46 
n/m 

(30)% 
5 
(2) 

(23)% 
15 
25 

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 544.2 billion and $517.0 billion for 2019 and 2018, and year-end allocated assets were $565.3 billion and $540.8 
billion at December 31, 2019 and 2018. 

n/m = not meaningful 

All Other consists of ALM activities, equity investments, non-core 
mortgage  loans  and  servicing  activities, liquidating  businesses 
and  certain  expenses  not  otherwise  allocated  to  a  business 
segment.  ALM  activities  encompass  certain 
residential 
mortgages, debt securities, and interest rate and foreign currency 
risk management activities. Substantially all of the results of ALM 
activities  are  allocated  to  our  business  segments.  For  more 
information on our ALM activities, see Note 24 – 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  information  on  our  merchant  services  joint 
venture, see  Note  13  –  Commitments  and  Contingencies  to  the 
Consolidated Financial Statements. 

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 
2019,  residential  mortgage  loans  held  for  ALM  activities 
decreased  $3.2  billion  to  $21.7  billion  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 2019, total non-core loans decreased $7.8 
billion  to  $15.7  billion  due  primarily  to  payoffs, paydowns  and 
sales,  as  well  as  Federal  Housing  Administration  (FHA)  loan 
conveyances, partially offset by repurchases. For more information 
on  the  composition  of  the  core  and  non-core  portfolios,  see 
Consumer Portfolio Credit Risk Management on page 75. 

Bank of America 2019  61 
Bank of America 2019  61   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The net loss for All Other increased $1.1 billion to a net loss 
of  $1.4  billion,  primarily  driven  by  the  $2.1  billion  pretax 
impairment  charge  disclosed  in  Executive  Summary  –  Recent 
Developments – Merchant Services Joint Venture, as well as lower 
revenue, partially  offset  by  a  higher  benefit  in  the  provision  for 
credit losses. 

Revenue  decreased  $757  million  due  to  lower  net  interest 
income and an increase in the loss in noninterest income. Net 
interest income decreased $398 million due to the impact of non-
core consumer real estate loan sales and portfolio run-off. The 
loss in noninterest income increased $359 million primarily due 
to lower gains on sales of non-core consumer loans and higher 
partnership losses associated with an increase in tax-advantaged 
investments, partially offset by a $729 million charge related to 
the redemption of certain trust preferred securities in 2018. 

Noninterest  expense  increased  $1.8  billion  to  $3.7  billion 
primarily due to the aforementioned $2.1 billion pretax impairment 
charge. 

The income tax benefit was $4.1 billion compared to a benefit 
of $2.8 billion in 2018. The increase in the tax benefit was primarily 
driven by the tax effect of the higher pretax loss, the positive impact 
from the resolution of various tax controversy matters and a higher 
level of income tax credits. Both years included income tax benefit 
adjustments to eliminate the FTE treatment of certain tax credits 
recorded in Global Banking. 

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 

Table 10  Contractual Obligations 

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 12 – Long-term Debt 
and Note 13 – 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 2019 and 2018, we contributed 
$135 million and $156 million to the Plans, and we expect to make 
$128 million of contributions during 2020. The Plans are more 
fully  discussed  in  Note  18  –  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  13  –  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 10 includes certain contractual obligations at December 

31, 2019 and 2018. 

(Dollars in millions) 

December 31, 2019 

Due in One 
Year or Less 

Due After 
One Year 
Through 
Three Years 

Due After 
Three Years 
Through 
Five Years 

December 31 
2018 

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) 

229,392 
15,770 
4,048 
61,039 
3,933 
56,852 
371,034 
(1)  Represents forecasted net interest expense on long-term debt and time deposits based on interest rates at December 31, 2019 and 2018. Forecasts are based on the contractual maturity dates 

1,966 
1,272 
68,351 
1,670 
5,571 
102,981  $ 

123,560  $ 
4,225 
731 
247 
659 
23,871 

11,794 
3,530 
74,673 
4,099 
44,385 

2,338 
401 
1,463 
714 
6,870 

3,265 
1,126 
4,612 
1,056 
8,073 

Total contractual obligations 

153,293  $ 

240,856  $ 

379,337  $ 

24,151  $ 

46,049  $ 

47,096  $ 

58,882  $ 

64,181  $ 

$ 

$ 

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

62 62

Bank of America 2019 

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Representations and Warranties Obligations 
For information on representations and warranties obligations in 
connection  with  the  sale  of  mortgage  loans,  see  Note  13  – 
Commitments  and  Contingencies  to  the  Consolidated  Financial 
Statements. 

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 53. 

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, oversee 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 66 through 98. 

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 2019  63 
Bank of America 2019  63   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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. 

(1)  Reports to the CEO and CFO with oversight by the Audit Committee 

Board of Directors and Board Committees 
The Board is composed of 17 directors, all but one of whom are 
independent. The Board authorizes management to maintain an 
effective Risk Framework, and oversees compliance with safe and 
sound banking practices. In addition, the Board or its committees 
conduct  inquiries  of, and  receive  reports  from  management  on 
risk-related matters to assess scope or resource limitations that 
could impede the ability of Independent Risk Management (IRM) 
and/or Corporate Audit to execute its responsibilities. The Board 
committees discussed below have the principal responsibility for 
enterprise-wide  oversight  of  our  risk  management  activities. 
Through these activities, the Board and applicable committees are 
provided with information on our risk profile and oversee executive 
management  addressing  key  risks  we  face.  Other  Board 
committees, as described below, provide additional oversight of 
specific risks. 

Each of the committees shown on the above chart regularly 
reports to the Board on risk-related matters within the committee’s 
responsibilities, which is intended to collectively provide the Board 
with integrated insight about our management of enterprise-wide 
risks. 

Audit Committee 
The Audit Committee oversees the qualifications, performance and 
independence of the Independent Registered Public Accounting 
Firm, the performance of our corporate audit function, the integrity 
of our consolidated financial statements, our compliance with legal 
and regulatory requirements, and makes inquiries of management 
or the Chief Audit Executive (CAE) to determine whether there are 
scope or resource limitations that impede the ability of Corporate 
Audit to execute its responsibilities. The Audit Committee is also 
responsible for overseeing compliance risk pursuant to the New 
York Stock Exchange listing standards. 

Enterprise Risk Committee 
The  ERC  has  primary  responsibility  for  oversight  of  the  Risk 
Framework and key risks we face and of the Corporation’s overall 
risk appetite. It approves the Risk Framework and the Risk Appetite 
Statement and further recommends these documents to the Board 
for  approval.  The  ERC  oversees  senior  management’s 
responsibilities  for  the  identification,  measurement,  monitoring 
and control of key risks we face. The ERC may consult with other 
Board committees on risk-related matters. 

Other Board Committees 
Our  Corporate  Governance, ESG, and  Sustainability  Committee 
oversees  our  Board’s  governance  processes,  identifies  and 
reviews 
the  qualifications  of  potential  Board  members, 
recommends  nominees  for  election  to  our  Board,  recommends 
committee  appointments  for  Board  approval  and  reviews  our 
Environmental,  Social  and  Governance  and  stockholder 
engagement activities. 

Our  Compensation and  Human Capital  Committee  oversees 
establishing,  maintaining  and  administering  our  compensation 
programs  and  employee  benefit  plans,  including  approving  and 
recommending our Chief Executive Officer’s (CEO) compensation 
to  our  Board  for  further  approval  by  all  independent  directors; 
reviewing  and  approving  all  of  our  executive  officers’ 
compensation,  as  well  as  compensation  for  non-management 
directors; and reviewing certain other human capital management 
topics. 

Management Committees 
Management  committees  may  receive  their  authority  from  the 
Board, a  Board  committee, another  management  committee  or 
from one  or  more executive  officers.  Our primary management-
level risk committee is the Management Risk Committee (MRC). 
Subject  to  Board  oversight,  the  MRC  is  responsible  for 
management oversight of key risks facing the Corporation. This 
includes providing management oversight of our compliance and 
risk  programs,  balance  sheet  and  capital 
operational 
management, funding activities and other liquidity activities, stress 
testing, trading activities, recovery and resolution planning, model 
risk, subsidiary governance and activities between member banks 
and their nonbank affiliates pursuant to Federal Reserve rules and 
regulations, among other things. 

Lines of Defense 
We have clear ownership and accountability across three lines of 
defense:  Front  Line  Units  (FLUs),  IRM  and  Corporate  Audit.  We 
also have control functions outside of FLUs and IRM (e.g., Legal 
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. 

64 64

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 
for 
Technology  and  Operations  Group,  are 
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 first, the 
Chief Financial Officer (CFO) Group; second, Environmental, Social 
and Governance (ESG), Capital Deployment (CD) and Public Policy 
(PP); and third, the Chief Administrative Officer (CAO) Group. 

Independent Risk Management 
IRM  is  part  of  our  control  functions  and  includes  Global  Risk 
Management. 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 CFO Group; ESG, CD and PP; and CAO Group. 
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 that cover a specific risk area 
and vertical CRO teams that cover a particular front line unit or 
control  function.  These  teams  work  collaboratively  in  executing 
their respective duties. 

Corporate Audit 
Corporate Audit and the CAE maintain their independence from 
the FLUs, IRM and other control functions by reporting directly to 
the Audit Committee or the Board. The CAE 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 
the  Corporation, with  a  goal  of  ensuring  risks  are  appropriately 
considered, evaluated and responded to in a timely manner. 

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  is  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 2019  65 
Bank of America 2019  65   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 
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  more  information,  see  Business  Segment 
Operations on page 53. 

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  Comprehensive  Capital  Analysis  and 
Review (CCAR) capital plan. 

On  June  27,  2019,  following  the  Federal  Reserve’s  non-
objection to our 2019 CCAR capital plan, the Board authorized the 
repurchase of approximately $30.9 billion in common stock from 
July 1, 2019 through June 30, 2020, which includes approximately 
$900  million  to  offset  shares  awarded  under  equity-based 
compensation  plans  during  the  same  period.  During  2019, 
pursuant to the Board’s authorizations, including those related to 
our  2018  CCAR  capital  plan  that  expired  June  30,  2019,  we 
repurchased  $28.1  billion  of  common  stock,  which  includes 
common stock repurchases to offset equity-based compensation 
awards. At December 31, 2019, our remaining stock repurchase 
authorization was $15.6 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 

66 66

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 (Exchange Act). 

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's depository institution subsidiaries are also 
subject  to  the  Prompt  Corrective  Action  (PCA)  framework.  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 PCA framework. As of December 31, 
2019, the 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. 

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. 

requirements 

ratio 

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  11 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, 2019 
and 2018. As of the periods presented herein, the Corporation 
met  the  definition  of  well  capitalized  under  current  regulatory 
requirements. 

Bank of America 2019  67 
Bank of America 2019  67   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 11  Bank of America Corporation Regulatory Capital under Basel 3 

(Dollars in millions, except as noted) 

Risk-based capital metrics: 

Common equity tier 1 capital 
Tier 1 capital 
Total capital (2) 
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) (3) 
Tier 1 leverage ratio 

SLR leverage exposure (in billions) 
SLR 

Risk-based capital metrics: 

Common equity tier 1 capital 
Tier 1 capital 
Total capital (2) 
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) (3) 
Tier 1 leverage ratio 

SLR leverage exposure (in billions) 
SLR 

Standardized 
Approach 

Advanced 
Approaches 
December 31, 2019 

Regulatory 
Minimum (1) 

$ 

$ 

166,760 
188,492 
221,230 
1,493 

166,760 
188,492 
213,098 
1,447 

11.2% 
12.6 
14.8 

11.5% 
13.0 
14.7 

9.5% 

11.0 
13.0 

4.0 

5.0 

$ 

2,374 

$ 

2,374 

7.9% 

7.9% 

$ 

2,946 

6.4% 

December 31, 2018 

$ 

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

$ 

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

11.6% 
13.2 
15.4 

11.9% 
13.4 
15.1 

8.25% 
9.75 
11.75 

$ 

2,258 

$ 

2,258 

8.4% 

8.4% 

$ 

2,791 

6.8% 

4.0 

5.0 

(1)   The capital conservation buffer and G-SIB surcharge were 2.5 percent at December 31, 2019 and 1.875 percent at December 31, 2018. The countercyclical capital buffer for both periods was zero. 

The SLR minimum includes a leverage buffer of 2.0 percent. 

(2)  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. 
(3)  Reflects total average assets adjusted for certain Tier 1 capital deductions. 

At December 31, 2019, CET1 capital and Total capital under 

primarily due to loan growth and increased client activity in Global 

the Advanced approaches were relatively unchanged compared to  Markets and Global Banking. 
December 31, 2018. Risk-weighted assets under the Standardized 
approach, which yielded the lower CET1 capital ratio at December 
31, 2019, increased $56.3 billion during 2019 to $1,493 billion 

and 2018. 

Table 12 shows the capital composition at December 31, 2019 

Table 12  Capital Composition under Basel 3 

(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 

Total capital under the Advanced approaches 

December 31 

2019 

2018 

241,409  $ 
(68,570) 
(5,193) 
(1,328) 
442 
166,760 
22,329 
(597) 
188,492 
22,538 
2,097 
(29) 
213,098  $ 

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

$ 

$ 

68 68

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 13 shows the components of risk-weighted assets as measured under Basel 3 at December 31, 2019 and 2018. 

Table 13  Risk-weighted Assets under Basel 3 

(Dollars in billions) 

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

Total risk-weighted assets 

n/a = not applicable 

Standardized 
Approach 

Advanced 
Approaches 

Standardized 
Approach 

Advanced 
Approaches 

2019 
1,437  $ 
56 
n/a 
n/a 

1,493  $ 

$ 

$ 

December 31 

858  $ 

55 
500 
34 
1,447  $ 

2018 
1,384  $ 
53 
n/a 
n/a 

1,437  $ 

827 
52 
500 
30 
1,409 

Bank of America, N.A. Regulatory Capital 
Table 14 presents regulatory capital information for BANA in accordance with Basel 3 Standardized and Advanced approaches as 
measured at December 31, 2019 and 2018. BANA met the definition of well capitalized under the PCA framework at both year ends. 

Table 14  Bank of America, N.A. Regulatory Capital under Basel 3 

(Dollars in millions, except as noted) 

Risk-based capital metrics: 

Common equity tier 1 capital 
Tier 1 capital 
Total capital (2) 
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) (3) 
Tier 1 leverage ratio 

SLR leverage exposure (in billions) 
SLR 

Risk-based capital metrics: 

Common equity tier 1 capital 
Tier 1 capital 
Total capital (2) 
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) (3) 
Tier 1 leverage ratio 

SLR leverage exposure (in billions) 
SLR 

Standardized 
Approach 

Advanced 
Approaches 

Regulatory 
Minimum (1) 

December 31, 2019 

$ 

$ 

154,626 
154,626 
166,567 
1,241 

12.5% 
12.5 
13.4 

154,626 
154,626 
158,665 
991 
15.6% 
15.6 
16.0 

$ 

1,780 

$ 

1,780 

8.7% 

8.7% 

$ 

2,177 

7.1% 

December 31, 2018 

$ 

$ 

149,824 
149,824 
161,760 
1,195 

12.5% 
12.5 
13.5 

149,824 
149,824 
153,627 
959 
15.6% 
15.6 
16.0 

$ 

1,719 

$ 

1,719 

8.7% 

8.7% 

$ 

2,112 

7.1% 

7.0% 
8.5 
10.5 

5.0 

6.0 

6.5% 
8.0 
10.0 

5.0 

6.0 

(1)   Risk-based capital regulatory minimums at December 31, 2019 are the minimum ratios under Basel 3 including a capital conservation buffer of 2.5 percent. The regulatory minimums for the leverage 

ratios as of both period ends and risk-based capital ratios as of December 31, 2018 are the percent required to be considered well capitalized under the PCA framework. 

(2)  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. 
(3)  Reflects total average assets adjusted for certain Tier 1 capital deductions. 

Total Loss-Absorbing Capacity Requirements  
Effective January 1, 2019, the Corporation is subject to the Federal 
Reserve’s final rule requiring G-SIBs to maintain minimum levels 
of total loss-absorbing capacity (TLAC) and long-term debt. TLAC 
consists of the Corporation’s Tier 1 capital and eligible long-term 
debt issued directly by the Corporation. Eligible long-term debt for 
TLAC ratios is comprised of unsecured debt that has a remaining 

maturity of at least one year and satisfies additional requirements 
as prescribed in the TLAC final rule. As with the risk-based capital 
ratios and SLR, the Corporation is required to maintain TLAC ratios 
in  excess  of  minimum  requirements  plus  applicable  buffers  to 
avoid restrictions on capital distributions and discretionary bonus 
payments.  Table  15  presents  the  Corporation's  TLAC  and  long-
term debt ratios and related information as of December 31, 2019. 

Bank of America 2019  69 
Bank of America 2019  69   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 15  Bank of America Corporation Total Loss-Absorbing Capacity and Long-Term Debt 

(Dollars in millions) 

Total eligible balance 
Percentage of risk-weighted assets (3) 
Percentage of SLR leverage exposure 

TLAC 

Regulatory 
Minimum (1) 

Long-term 
Debt 

Regulatory 
Minimum (2) 

$ 

367,449 

$ 

171,349 

December 31, 2019 

24.6% 
12.5 

22.0% 
9.5 

11.5% 
5.8 

8.5% 
4.5 

(1)   The TLAC risk-weighted assets regulatory minimum consists of 18.0 percent plus a TLAC risk-weighted assets buffer comprised of 2.5 percent plus the method 1 G-SIB surcharge of 1.5 percent. 
The countercyclical buffer is zero for this period. The TLAC SLR leverage exposure regulatory minimum consists of 7.5 percent plus a 2.0 percent TLAC leverage buffer. The TLAC risk-weighted assets 
and leverage buffers must be comprised solely of CET1 capital and Tier 1 capital, respectively. 

(2)   The long-term debt risk-weighted assets regulatory minimum is comprised of 6.0 percent plus an additional 2.5 percent requirement based on the Corporation’s method 2 G-SIB surcharge. The long­

term debt leverage exposure regulatory minimum is 4.5 percent. 

(3)  The approach that yields the higher risk-weighted assets is used to calculate TLAC and long-term debt ratios, which was the Standardized approach as of December 31, 2019. 

Regulatory Capital and Securities Regulation 
The  Corporation’s  principal  U.S.  broker-dealer  subsidiaries  are 
BofA Securities, Inc. (BofAS), Merrill Lynch Professional Clearing 
Corp.  (MLPCC)  and  Merrill  Lynch,  Pierce,  Fenner  &  Smith 
Incorporated  (MLPF&S).  BofAS  was  formed  as  a  result  of  the 
reorganization of MLPF&S which was completed in May 2019. The 
Corporation's  principal  European  broker-dealer  subsidiaries  are 
Merrill Lynch International (MLI) and BofA Securities Europe SA 
(BofASE). 

The  U.S.  broker-dealer  subsidiaries  are  subject  to  the  net 
capital  requirements  of  Rule  15c3-1  under  the  Exchange  Act. 
BofAS  computes  its  minimum  capital  requirements  as  an 
alternative  net  capital  broker-dealer  under  Rule  15c3-1,  and 
MLPCC and MLPF&S compute their minimum capital requirements 
in accordance with the alternative standard under Rule 15c3-1. 
BofAS  and  MLPCC  are  also  registered  as  futures  commission 
merchants  and  are  subject  to  U.S.  Commodity  Futures  Trading 
Commission (CFTC) Regulation 1.17. 

BofAS provides institutional services, and in accordance with 
the alternative net capital requirements, is required to maintain 
tentative net capital in excess of $1.0 billion and net capital in 
excess of the greater of $500 million or a certain percentage of 
its reserve requirement. BofAS must also notify the Securities and 
Exchange Commission (SEC) in the event its tentative net capital 
is less than $5.0 billion. BofAS is also required to hold a certain 
percentage  of  its  risk-based  margin  in  order  to  meet  its  CFTC 
minimum net capital requirement. At December 31, 2019, BofAS 
had tentative net capital of $12.5 billion. BofAS also had regulatory 
net  capital  of  $10.4  billion  which  exceeded  the  minimum 
requirement of $2.4 billion. 

MLPCC is a fully-guaranteed subsidiary of BofAS and provides 
clearing and settlement services. At December 31, 2019, MLPCC’s 
regulatory  net  capital  of  $5.3  billion  exceeded  the  minimum 
requirement of $1.3 billion. 

MLPF&S  provides  retail  services.  At  December  31,  2019, 
MLPF&S' regulatory net capital was $4.1 billion which exceeded 
the minimum requirement of $102 million. 

Our  European  broker-dealers  are  regulated  by  non-U.S. 
regulators.  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, 2019, 
MLI’s capital resources were $34.8 billion, which exceeded the 
minimum Pillar 1 requirement of $13.9 billion. BofASE, a French 
investment firm, is regulated by the Autorité de Contrôle Prudentiel 
et de Résolution and the Autorité des Marchés Financiers, and is 
subject to certain regulatory capital requirements. At December 
31,  2019,  BofASE's  capital  resources  were  $5.5  billion  which 
exceeded the minimum Pillar 1 requirement of $1.3 billion. 

Regulatory Developments 

Revisions to Basel 3 to Address Current Expected Credit 
Loss Accounting 
On January 1, 2020, the Corporation adopted the new accounting 
standard that requires the measurement of the allowance for credit 
losses to be based on management’s best estimate of lifetime 
expected  credit  losses  inherent  in  the  Corporation's  relevant 
financial assets. For more information, see Note 1 - Summary of 
Significant  Accounting  Principles  to  the  Consolidated  Financial 
Statements. Our adoption of the standard resulted in a decrease 
to the CET1 capital ratio of 17 bps, which will be phased in evenly, 
or approximately four bps per year, at the beginning of each year 
from January 1, 2020 through January 1, 2023 in accordance with 
transition provisions issued by the U.S. banking regulators. 

Security-Based Swap Dealer Capital, Margin and 
Segregation Requirements 
On  June  21, 2019, the  SEC  published  a  final  rule  establishing 
capital, margin and segregation requirements for security-based 
swap dealers (SBSDs). The final rule increases the minimum net 
capital requirements for broker-dealers authorized to use internal 
models to compute alternative net capital (ANC broker-dealers). 
For  ANC  broker-dealers,  the  minimum  tentative  net  capital 
requirement increased from $1.0 billion to $5.0 billion, and the 
net capital requirement was raised to the greater of $1.0 billion 
or two percent of the applicable risk-margin amount (initial margin 
maintained for cleared and non-cleared security-based swaps) plus 
two percent of certain customer-related assets. For stand-alone 
SBSDs  that  use  models  to  calculate  haircuts,  the  minimum 
tentative net capital requirement is $100 million and the minimum 
net capital requirement is the greater of $20 million or two percent 
of the risk-margin amount. 

Capital Requirements for Swap Dealers 
On December 10, 2019, the CFTC re-opened the comment period 
on its 2016 proposal to establish capital requirements for swap 
dealers and major swap participants that are not subject to existing 
U.S.  prudential  regulation.  Under  the  proposal,  applicable 
subsidiaries of the Corporation would be permitted to elect one 
of two approaches to compute their regulatory capital. The first 
approach is a bank-based capital approach which requires that 
firms maintain CET1 capital greater than or equal to the larger of 
8.0 percent of the entity’s RWA as calculated under Basel 3, or 
8.0 percent of the margin of the entity’s cleared and uncleared 
swaps,  security-based  swaps,  futures  and  foreign  futures 
positions. The second approach is based on net liquid assets and 
requires that a firm maintain net capital greater than or equal to 
8.0 percent of the margin as described above. The proposal also 
includes liquidity and reporting requirements. 

70 70

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Single-Counterparty Credit Limits 
The Federal Reserve established 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 
central 
counterparties, are exempt from the credit limits. 

qualifying 

entities 

and 

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 63. 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 16 presents average GLS for the three months ended 

December 31, 2019 and 2018. 

Table 16  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 

2019 

2018 

$ 

$ 

59  $ 

454 
63 

576  $ 

76 
420 
48 
544 

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 

Bank of America 2019  71 
Bank of America 2019  71   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
obtained by borrowing against this pool of specifically-identified 
eligible assets was $372 billion and $344 billion at December 31, 
2019 and 2018. 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 17 presents the composition of average GLS for the three 

months ended December 31, 2019 and 2018. 

Table 17  Average Global Liquidity Sources Composition 

Three Months Ended 
December 31 

2019 

2018 

(Dollars in billions) 

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

securities 

Non-U.S. government securities 

$ 

103  $ 

98 

358 

17 

Total Average Global Liquidity Sources 

$ 

576  $ 

113 
81 

340 

10 
544 

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 $464 billion and $446 billion for the three months 
ended December 31, 2019 and 2018. For the same periods, the 
average consolidated LCR was 116 percent and 118 percent. Our 
LCR 
fluctuates  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 

72 72

Bank of America 2019 

Bank of America 2019

markets; potential deposit withdrawals; increased draws on loan 
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  $1.43  trillion  and  $1.38  trillion  at 
December 31, 2019 and 2018. 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 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 

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 11 
–  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  18  presents  our  long-term  debt  by  major  currency  at 

December 31, 2019 and 2018. 

Table 18  Long-term Debt by Major Currency 

(Dollars in millions) 

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

December 31 

2019 

2018 

$ 

191,284  $ 

32,781 
5,067 
4,310 
3,857 
1,957 
1,600 
240,856  $ 

180,724 
34,328 
5,450 
3,038 
2,936 
1,722 
1,194 
229,392 

Total long-term debt 

$ 

Total  long-term  debt  increased  $11.5  billion  during  2019, 
primarily  due  to  debt  issuances  and  valuation  adjustments, 
partially offset by 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. 

During 2019, the Corporation issued $52.5 billion of long-term 
debt consisting of $29.3 billion of notes issued by Bank of America 
Corporation, substantially all of which was TLAC compliant, $10.9 
billion of notes issued by Bank of America, N.A. and $12.3 billion 
of other debt, substantially all of which was structured liabilities. 
During 2018, the Corporation issued  $64.4  billion  of long-term 
debt consisting of $30.7 billion of notes issued by Bank of America 
Corporation, substantially all of which was TLAC compliant, $18.7 
billion of notes issued by Bank of America, N.A. and $15.0 billion 
of other debt, substantially all of which was structured liabilities. 
During  2019,  the  Corporation  had  total  long-term  debt 
maturities  and  redemptions  in  the  aggregate  of  $50.6  billion 
consisting of $21.1 billion for Bank of America Corporation, $19.9 
billion for Bank of America, N.A. and $9.6 billion of other debt. 
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. 

At December 31, 2019, Bank of America Corporation's senior 
notes  of  $159.8  billion  included  $107.7  billion  of  outstanding 
notes that are both TLAC eligible and callable at least one year 
before their stated maturities. Of these senior notes, $7.4 billion 
will be callable and become TLAC ineligible during 2020, and $11.7 

billion, $14.8 billion, $10.7 billion and $9.2 billion will do so during 
each  of  2021  through  2024,  respectively,  and  $53.9  billion 
thereafter. 

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 95. 

We may issue unsecured debt in the form of structured notes 
for client purposes, certain of which qualify as TLAC-eligible debt. 
During 2019, we issued $9.6 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.  For  more 
information on long-term debt funding, including issuances and 
maturities and redemptions, see Note 12 – Long-term Debt to the 
Consolidated Financial Statements. 

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 

Bank of America 2019  73 
Bank of America 2019  73   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
agencies could make adjustments to our ratings at any time, and 
they provide no assurances that they will maintain our ratings at 
current levels. 

Lynch  International  Designated  Activity  Company,  which  Fitch 
upgraded by one notch to AA-/F1+. The rating outlook for all long-
term ratings is currently stable. 

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 June 12, 2019, Fitch Ratings (Fitch) completed its periodic 
review of the 12 large, complex securities trading and universal 
banks, including Bank of America Corporation. The agency affirmed 
the long-term and short-term senior debt ratings of the Corporation 
and all of its rated subsidiaries, except Bank of America Merrill 

On  March  6,  2019,  Moody’s  Investors  Service  (Moody’s) 
upgraded the long-term and short-term ratings of the Corporation 
by one notch to A2/P-1 from A3/P-2 for senior debt, as well as the 
long-term ratings of its rated subsidiaries, including BANA, which 
the agency upgraded to Aa2 from Aa3 for senior debt. Moody’s 
concurrently affirmed the short-term ratings of the Corporation’s 
rated  subsidiaries, 
the 
Corporation’s strengthening profitability, continued adherence to 
a conservative risk profile and stable capital ratios as rationale 
for  the  upgrade.  The  rating  outlook  for  all  long-term  ratings  is 
currently stable. 

including  BANA.  Moody’s  cited 

The ratings from Standard & Poor’s Global Ratings (S&P) for 
the Corporation and its subsidiaries did not change during 2019. 
The long-term and short-term debt ratings of BofAS and BofASE, 
which  were initially  rated  by  S&P  during  the  first  quarter  2019, 
also remained unchanged during the rest of 2019. 

Table 19 presents the Corporation’s current long-term/short-
term  senior  debt  ratings  and  outlooks  expressed  by  the  rating 
agencies. 

Table 19  Senior Debt Ratings 

Bank of America Corporation
Bank of America, N.A.
Bank of America Merrill Lynch International 

Designated Activity Company

Merrill Lynch, Pierce, Fenner & Smith 

Incorporated

BofA Securities, Inc.
Merrill Lynch International
BofA Securities Europe SA
NR = not rated 

 A2
 Aa2

 NR

 NR

 NR
 NR
 NR

 P-1
 P-1

 NR

 NR

 NR
 NR
 NR

Moody’s Investors Service 
Short-term 

Long-term 

Standard & Poor’s Global Ratings 
Short-term 

Long-term 

Outlook 
 Stable
 Stable

 NR

 NR

 NR
 NR
 NR

A-
A+

A+

A+

A+
A+
A+

A-2
 A-1

 A-1

 A-1

 A-1
 A-1
 A-1

Outlook 
 Stable
 Stable

 Stable

 Stable

 Stable
 Stable
 Stable

Long-term 

Fitch Ratings 
Short-term 

 A+
 AA-

 AA-

 AA-

 AA-
 A+
 A+

 F1
F1+

F1+

F1+

F1+
 F1
 F1

Outlook 

 Stable  
 Stable  

 Stable 

 Stable 

 Stable 
 Stable 
 Stable 

in 

those 

businesses  where 

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 revenues, 
particularly 
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 72. 

74 74

Bank of America 2019 

Bank of America 2019

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 2019 Annual Report on Form 10-K. 

Common Stock Dividends 
For  a  summary  of  our  declared  quarterly  cash  dividends  on 
common stock during 2019 and through February 19, 2020, see 
Note  14  –  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 
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 13 – 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 81, Non-
U.S. Portfolio on page 87, Provision for Credit Losses on page 89, 
Allowance for Credit Losses on page 89, and Note 5 – Outstanding 
Loans and Leases and Note 6 – Allowance for Credit Losses to the 
Consolidated Financial Statements. 

Table 20  Consumer Credit Quality 

(Dollars in millions) 

Residential mortgage (1) 
Home equity 
Credit card 
Direct/Indirect consumer (2) 
Other consumer 

Consumer loans excluding loans accounted for under the fair value option 

Loans accounted for under the fair value option (3) 

Total consumer loans and leases 

Percentage of outstanding consumer loans and leases (4) 
Percentage of outstanding consumer loans and leases, excluding fully-insured 

loan portfolios (4) 

$ 

$ 

$ 

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 2019 resulting in 
improved credit quality compared to 2018. Net recoveries in the 
consumer real estate portfolio due primarily to non-core loan sales 
were  partially  offset  by  seasoning  in  the  credit  card  portfolio 
compared to 2018. 

Improved  credit  quality  and  continued  loan  balance  runoff 
primarily in the non-core consumer real estate portfolio, partially 
offset by seasoning within the credit card portfolio, drove a $260 
million decrease in the consumer allowance for loan and lease 
losses in 2019 to $4.5 billion. For more information, see Allowance 
for Credit Losses on page 89. 

For  more  information  on  our  accounting  policies  regarding 
delinquencies,  nonperforming  status,  charge-offs  and  troubled 
debt restructurings (TDRs) for the consumer portfolio, see Note 1 
–  Summary  of  Significant  Accounting  Principles  and  Note  5  – 
Outstanding  Loans  and  Leases  to  the  Consolidated  Financial 
Statements. 

Table 20 presents our outstanding consumer loans and leases, 
consumer nonperforming loans and accruing consumer loans past 
due 90 days or more. 

Outstandings 

Nonperforming 

December 31 

Accruing Past Due 
90 Days or More 

2018 

40,208 
97,608 
90,998 
192 

2019 
236,169  $  208,557 
48,286 
98,338 
91,166 
202 
465,175  $  446,549 
682 
465,769  $  447,231 
n/a 

594 

n/a 

2019 

2018 

2019 

2018 

$ 

$ 

1,470 
536 
n/a 
47 
— 
2,053 

$ 

$ 

1,893 
1,893 
n/a 
56 
— 
3,842 

$ 

$ 

1,088 
— 
1,042 
33 
— 
2,163 

$ 

$ 

1,884 
— 
994 
38 
— 
2,916 

0.44% 

0.86% 

0.47% 

0.65% 

n/a 

n/a 

0.46 

0.90 

0.24 

0.24 

(1)   Residential mortgage loans accruing past due 90 days or more are fully-insured loans. At December 31, 2019 and 2018, residential mortgage includes $740 million and $1.4 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 $348 million and $498 million of loans on which interest was 
still accruing. 

(2)   Outstandings primarily include auto and specialty lending loans and leases of $50.4 billion and $50.1 billion, U.S. securities-based lending loans of $36.7 billion and $37.0 billion and non-U.S. 

consumer loans of $2.8 billion and $2.9 billion at December 31, 2019 and 2018. 

(3)   Consumer loans accounted for under the fair value option include residential mortgage loans of $257 million and $336 million and home equity loans of $337 million and $346 million at December 

31, 2019 and 2018. For more information on the fair value option, see Note 22 – Fair Value Option to the Consolidated Financial Statements. 

(4)  Excludes consumer loans accounted for under the fair value option. At December 31, 2019 and 2018, $6 million and $12 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 

Bank of America 2019  75 
Bank of America 2019  75   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 21 presents net charge-offs and related ratios for consumer loans and leases. 

Table 21  Consumer Net Charge-offs and Related Ratios 

(Dollars in millions) 

Residential mortgage 
Home equity 
Credit card 
Direct/Indirect consumer 
Other consumer 

Total  

Net Charge-offs 

2019 

2018 

Net Charge-off Ratios (1) 
2019 
2018 

$ 

(47)  $ 

(358) 
2,948 
209 
234 

$ 

2,986  $ 

28 
(2) 
2,837 
195 
182 
3,240 

(0.02)% 
(0.81) 
3.12 
0.23 

n/m 

0.66 

0.01% 
— 
3.00 
0.21 
n/m 
0.72 

(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. 
n/m = not meaningful 

Table 22 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 22 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 22, outstanding core consumer real estate 
loans increased $27.3 billion during 2019 driven by an increase 
of $32.1 billion in residential mortgage, partially offset by a $4.8 
billion decrease in home equity. 

During  2019, we  sold  $4.7  billion  of  consumer  real  estate 

loans, primarily non-core, compared to $11.6 billion in 2018. 

Table 22  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 

Outstandings 

Nonperforming 

2019 

2018 

2019 

2018 

2019 

2018 

December 31 

Net Charge-offs 

$ 

225,770  $ 

193,695  $ 

35,226 
260,996 

40,010 
233,705 

883  $ 
363 
1,246 

1,010  $ 
955 
1,965 

7  $ 

51 
58 

10,399 
4,982 
15,381 

14,862 
8,276 
23,138 

236,169 
40,208 

208,557 
48,286 

587 
173 
760 

1,470 
536 

883 
938 
1,821 

(54) 
(409) 
(463) 

1,893 
1,893 
3,786  $ 

(47) 
(358) 
(405)  $ 

11 
78 
89 

17 
(80) 
(63) 

28
(2) 
26 

Total consumer real estate portfolio 

$ 

276,377  $ 

256,843  $ 

2,006  $ 

Core portfolio 

Residential mortgage 
Home equity 

Total core portfolio 

Non-core portfolio 

Residential mortgage 
Home equity 

Total non-core portfolio  
Consumer real estate portfolio

Allowance for Loan 
and Lease Losses 

December 31 

Provision for Loan 
and Lease Losses 

2019 

2018 

2019 

2018 

$ 

$ 

229 
120 
349 

96 
101 
197 

$ 

214 
228 
442 

208 
278 
486 

$ 

22 
(58) 
(36) 

(134) 
(510) 
(644) 

7 
(60) 
(53) 

(104) 
(335) 
(439) 

 Residential mortgage 
 Home equity 

(97)
(395) 
(492) 
(1)   Outstandings and nonperforming loans exclude loans accounted for under the fair value option. Consumer loans accounted for under the fair value option include residential mortgage loans of $257 
million and $336 million and home equity loans of $337 million and $346 million at December 31, 2019 and 2018. For more information, see Note 22 – Fair Value Option to the Consolidated Financial 
Statements. 

Total consumer real estate portfolio  

422 
506 
928  $ 

(112) 
(568) 
(680)  $ 

325 
221 
546  $ 

$ 

76  Bank of America 2019 

Bank of America 2019

76

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
We  believe  that  the  presentation  of  information  adjusted  to 
exclude  the  impact  of 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 fully-insured loan portfolio in certain 
credit quality statistics. 

Residential Mortgage 
The residential mortgage portfolio made up the largest percentage 
of our consumer loan portfolio at 51 percent of consumer loans 
and leases at December 31, 2019. Approximately 50 percent of 
the residential mortgage portfolio was in Consumer Banking and 
36 percent was in GWIM. The remaining portion was in All Other 
and was comprised of loans used in our overall ALM activities, 

delinquent  FHA  loans  repurchased  pursuant  to  our  servicing 
agreements with the Government National Mortgage Association 
as well as loans repurchased related to our representations and 
warranties. 

Outstanding  balances  in  the  residential  mortgage  portfolio 
increased $27.6 billion in 2019 as retention of new originations 
was partially offset by loan sales of $2.7 billion and runoff. 

At December 31, 2019 and 2018, the residential mortgage 
portfolio included $18.7 billion and $20.1 billion of outstanding 
fully-insured loans, of which $11.2 billion and $14.0 billion had 
FHA insurance with the remainder protected by long-term standby 
agreements. 

Table  23  presents  certain  residential  mortgage  key  credit 
statistics on both a reported basis and excluding the fully-insured 
loan portfolio. The following discussion presents the residential 
mortgage portfolio excluding the fully-insured loan portfolio. 

Table 23  Residential Mortgage – Key Credit Statistics 

(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) 

Excluding Fully-insured Loans (1) 

$ 

2019 
236,169 
3,108 
1,088 
1,470 

$ 

December 31 

2018 
208,557 
3,945 
1,884 
1,893 

2019 
$  217,479 
1,296 
— 
1,470 

$ 

2018 
188,427 
1,155 
— 
1,893 

2% 
1 
3 
4 

2% 
1 
4 
6 

2% 
1 
2 
4 

2% 
1 
2 
6 

(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 $365 million, or 25 percent, and $536 million, or 28 percent, of nonperforming residential mortgage loans at December 31, 2019 and 2018. 

Nonperforming  residential  mortgage  loans  decreased  $423 
million  in  2019 primarily  driven by  sales.  Of  the  nonperforming 
residential mortgage loans at December 31, 2019, $616 million, 
or  42  percent,  were  current  on  contractual  payments.  Loans 
accruing past due 30 days or more increased $141 million. 

Net charge-offs improved $75 million to a net recovery of $47 
million in 2019 compared to net charge-offs of $28 million in 2018 
primarily due to recoveries from the sales of previously charged-
off loans and continued improvement in credit quality. 

Of  the  $217.5  billion  in  total  residential  mortgage  loans 
outstanding  at  December  31, 2019, as  shown  in  Table  23, 26 
percent were originated as interest-only  loans.  The  outstanding 
balance  of  interest-only  residential  mortgage  loans  that  have 
entered the amortization period was $7.4 billion, or 13 percent, 
at  December  31, 2019.  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, 2019, $124 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 $1.3 billion, or one percent, for the entire residential 
mortgage  portfolio.  In  addition,  at  December  31,  2019,  $260 
million, or  four  percent, of  outstanding  interest-only  residential 
mortgage  loans  that  had  entered  the  amortization  period  were 
nonperforming, of which $108 million were contractually current, 
compared to $1.5 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 94 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. 

Table 24 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, 2019 and 2018. 
In  the  New  York  area,  the  New  York-Northern  New  Jersey-Long 
Island MSA made up 13 percent of outstandings at both December 
31, 2019 and 2018. 

Bank of America 2019  77 
Bank of America 2019  77   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 24  Residential Mortgage State Concentrations 

(Dollars in millions) 

California 
New York 
Florida 
Texas 
New Jersey 
Other 

Residential mortgage loans 

Fully-insured loan portfolio  

Total residential mortgage loan portfolio 

Outstandings (1) 

Nonperforming (1) 

2019 

2018 

2019 

2018 

2019 

2018 

December 31 

Net Charge-offs 

88,998  $ 
22,385 
12,833 
8,943 
8,734 
75,586 

76,323  $ 
19,219 
11,624 
7,820 
7,051 
66,390 

274  $ 
196 
143 
65 
77 
715 

217,479  $ 

188,427  $ 

1,470  $ 

314  $ 
222 
221 
102 
98 
936 
1,893  $ 

(22)  $ 

5 
(12) 
1 
(4) 
(15) 
(47)  $ 

(22) 
10 
(6) 
4 
8 
34 
28 

18,690 

236,169  $ 

20,130 
208,557 

$ 

$ 

$ 

(1)  Outstandings and nonperforming loans exclude loans accounted for under the fair value option. 

Home Equity 
At December 31, 2019, the home equity portfolio made up nine 
percent  of  the  consumer  portfolio  and  was  comprised  of  home 
equity  lines of  credit (HELOCs), home  equity  loans  and  reverse 
mortgages. We no longer originate home equity loans or reverse 
mortgages. 

At December 31, 2019, our HELOC portfolio had an outstanding 
balance of $37.5 billion, or 93 percent of the total home equity 
portfolio, compared to $44.3 billion, or 92 percent, at December 
31, 2018.  HELOCs  generally  have  an  initial  draw  period  of  10 
years, and after the initial draw period ends, the loans generally 
convert to 15- or 20-year amortizing loans. 

At December 31, 2019, our home equity loan portfolio had an 
outstanding balance of $1.2 billion, or three percent of the total 
home equity portfolio, compared to $1.8 billion, or four percent, 
at  December  31,  2018.  At  December  31,  2019,  our  reverse 
mortgage portfolio had an outstanding balance of $1.5 billion, or 
four percent of the total home equity portfolio, compared to $2.2 
billion, also four percent, at December 31, 2018. 

At December 31, 2019, 80 percent of the home equity portfolio 
was in Consumer Banking, 12 percent was in All Other  and the 
remainder  of  the  portfolio  was  primarily  in  GWIM.  Outstanding 
balances in the home equity portfolio decreased $8.1 billion in 
2019  primarily due to  paydowns  and  loan  sales  of  $2.0  billion 
outpacing new originations and draws on existing lines. Of the total 
home equity portfolio at December 31, 2019 and 2018, $15.0 
billion, or 37 percent, and $17.3 billion, or 36 percent, were in 
first-lien positions. At December 31, 2019, 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 
$6.9 billion, or 17 percent of our total home equity portfolio. 

Unused  HELOCs  totaled  $43.6  billion  and  $43.1  billion  at 
December 31, 2019 and 2018. The increase was primarily driven 
by the impact of lower utilization of open lines and new production 
partially  offset  by  customers  choosing  to  close  accounts.  The 
HELOC utilization rate was 46 percent and 51 percent at December 
31, 2019 and 2018. 

Table  25  presents  certain  home  equity  portfolio  key  credit 

statistics. 

Table 25  Home Equity – Key Credit Statistics (1) 

(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) 

December 31 

$ 

2019 
40,208 
218 
536 

$ 

2018 

48,286 
363 
1,893 

1% 
2 
3 
18 

2% 
3 
5 
22 

(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 $30 million and $48 million and nonperforming loans include $57 million and $218 million of loans where we serviced the underlying first lien at December 

31, 2019 and 2018. 

(3)  These vintages of loans accounted for 34 percent and 49 percent of nonperforming home equity loans at December 31, 2019 and 2018. 

Nonperforming  outstanding  balances  in  the  home  equity 
portfolio  decreased  $1.4  billion  in  2019  as  outflows, primarily 
sales, outpaced new inflows. Of the nonperforming home equity 
loans at December 31, 2019, $241 million, or 45 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,  $162  million,  or  30  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 $145 million in 2019. 

Net charge-offs decreased $356 million to a net recovery of 
$358 million in 2019 compared to a net recovery of $2 million in 
2018 primarily driven by recoveries from the sales of previously 
charged off non-core home equity loans. 

Of the $40.2 billion in total home equity portfolio outstandings 
at December 31, 2019, as shown in Table 25, 17 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 $11.5 billion at December 31, 2019. The 
HELOCs  that  have  entered  the  amortization  period  have 
experienced a higher percentage of early stage delinquencies and 

78 78

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
nonperforming status when compared to the HELOC portfolio as 
a whole. At December 31, 2019, $149 million, or one percent, of 
outstanding HELOCs that had entered the amortization period were 
accruing past due 30 days or more. In addition, at December 31, 
2019, $472 million, or four percent, 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 

Table 26  Home Equity State Concentrations 

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 2019, 13 percent of these customers 
with  an  outstanding  balance  did  not  pay  any  principal  on  their 
HELOCs. 

Table 26 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, 2019 and 2018. The Los 
Angeles-Long Beach-Santa Ana MSA within California made up 11 
percent of the outstanding home equity portfolio at both December 
31, 2019 and 2018. 

(Dollars in millions) 

California 
Florida 
New Jersey 
New York 
Massachusetts 
Other 

Total home equity loan portfolio 

Outstandings (1) 

Nonperforming (1) 

2019 

2018 

2019 

2018 

2019 

2018 

December 31 

Net Charge-offs 

$ 

$ 

11,232  $ 

4,327 
3,216 
2,899 
2,023 
16,511 
40,208  $ 

13,515  $ 

5,418 
3,871 
3,590 
2,400 
19,492 
48,286  $ 

101  $ 

71 
56 
85 
29 
194 
536  $ 

536  $ 
315 
150 
194 
65 
633 
1,893  $ 

(117)  $ 
(74) 
(8) 
(1) 
(5) 
(153) 
(358)  $ 

(54)  
1  
25  
23  
5  
(2)  
(2) 

(1)  Outstandings and nonperforming loans exclude loans accounted for under the fair value option. 

Credit Card 
At December 31, 2019, 97 percent of the credit card portfolio was 
managed  in  Consumer  Banking  with  the  remainder  in  GWIM. 
Outstandings in the credit card portfolio decreased $730 million 
in 2019 to $97.6 billion. In 2019, net charge-offs increased $111 
million to $2.9 billion compared to net charge-offs of $2.8 billion 
in 2018.  Credit  card  loans  30  days  or  more  past  due  and  still 

accruing interest increased $46 million and loans 90 days or more 
past due and still accruing interest increased $48 million. These 
increases were driven by portfolio seasoning. 

Unused lines of credit for credit card increased to $336.9 billion 
at December 31, 2019 from $334.8 billion at December 31, 2018. 
Table 27 presents certain state concentrations for the credit 

card portfolio. 

Table 27  Credit Card State Concentrations 

(Dollars in millions) 

California 
Florida 
Texas 
New York 
Washington 
Other 

Total credit card portfolio 

Outstandings 

Accruing Past Due 
90 Days or More 

2019 

2018 

2019 

2018 

2019 

2018 

December 31 

Net Charge-offs 

$ 

$ 

16,135  $ 

9,075 
7,815 
5,975 
4,639 
53,969 
97,608  $ 

16,062  $ 

8,840 
7,730 
6,066 
4,558 
55,082 
98,338  $ 

178  $ 
135 
93 
80 
26 
530 

1,042  $ 

163  $ 
119 
84 
81 
24 
523 
994  $ 

526  $ 
363 
241 
243 
71 
1,504 
2,948  $ 

479 
332 
224 
268 
63 
1,471 
2,837 

Direct/Indirect Consumer 
At December 31, 2019, 56 percent of the direct/indirect portfolio 
was included in Consumer Banking (consumer auto and specialty 
lending  –  automotive, recreational  vehicle, marine, aircraft  and 
consumer personal loans) and 44 percent was included in GWIM 
(principally securities-based lending loans). 

Outstandings  of  $91.0  billion  in  the  direct/indirect  portfolio 

were relatively unchanged at December 31, 2019. 

Table 28 presents certain state concentrations for the direct/ 

indirect consumer loan portfolio. 

Bank of America 2019  79 
Bank of America 2019  79   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 28  Direct/Indirect State Concentrations 

(Dollars in millions)  

California 
Florida 
Texas 
New York 
New Jersey 
Other 

Total direct/indirect loan portfolio  

Outstandings 

Accruing Past Due 
90 Days or More 

2019 

2018 

2019 

2018 

2019 

2018 

December 31 

Net Charge-offs 

$ 

$ 

11,912  $ 
10,154 
9,516 
6,394 
3,468 
49,554 
90,998  $ 

11,734  $
10,240 
9,876 
6,296 
3,308 
49,712 
91,166  $ 

4  $
4 
5 
1 
1 
18 
33  $ 

4  $ 
4 
6 
2 
1 
21 
38  $ 

49  $ 
27 
29 
12 
4 
88 

209  $ 

21 
36 
30 
9 
2 
97 
195 

Nonperforming Consumer Loans, Leases and Foreclosed 
Properties Activity 
Table  29  presents  nonperforming  consumer  loans,  leases  and 
foreclosed properties activity during 2019 and 2018. During 2019, 
nonperforming  consumer  loans  decreased  $1.8  billion  to  $2.1 
billion primarily driven by loan sales of $1.5 billion. 

At  December  31,  2019,  $606  million,  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,  2019,  $901  million,  or  44 

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 decreased $15 million in 2019 to $229 

million as liquidations outpaced additions. 

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 are included in Table 29. 

Table 29  Nonperforming Consumer Loans, Leases and Foreclosed Properties Activity 

2019 

2018 

$ 

3,842 
1,407 

$ 

5,166 
2,440 

(701) 
(1,523) 
(766) 
(111) 
(95) 
— 
(1,789) 
2,053 
229 
2,282 

$ 

(958) 
(969) 
(1,283) 
(401) 
(151) 
(2) 
(1,324) 
3,842 
244 
4,086 

0.44% 

0.86% 

0.49 

0.92 

(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) 

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 $260 million and $488 million at December 31, 2019 and 2018. 
(3)  Outstanding consumer loans and leases exclude loans accounted for under the fair value option. 

Table 30 presents TDRs for the consumer real estate portfolio. Performing TDR balances are excluded from nonperforming loans 

and leases in Table 29. 

Table 30  Consumer Real Estate Troubled Debt Restructurings 

December 31, 2019 
Performing 

Total 

Nonperforming 

December 31, 2018 
Performing 

Total 

(Dollars in millions) 

Nonperforming 
$ 

Residential mortgage (1, 2) 
Home equity (3) 

6,197 
2,359 
8,556 
(1)   At December 31, 2019 and 2018, residential mortgage TDRs deemed collateral dependent totaled $1.2 billion and $1.6 billion, and included $748 million and $960 million of loans classified as 

Total consumer real estate troubled debt restructurings 

1,209  $ 
1,107 
2,316  $ 

4,988  $ 
1,252 
6,240  $ 

4,753  $ 
1,229 
5,982  $ 

921  $ 
252 

3,832  $ 

1,173  $ 

4,809  $ 

977 

$ 

nonperforming and $468 million and $605 million of loans classified as performing. 

(2)  At December 31, 2019 and 2018, residential mortgage performing TDRs include $2.1 billion and $2.8 billion of loans that were fully-insured. 
(3)   At December 31, 2019 and 2018, home equity TDRs deemed collateral dependent totaled $442 million and $1.3 billion, and include $209 million and $961 million of loans classified as nonperforming 

and $233 million and $322 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). 

80 80

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 29 
as  substantially  all  of  the  loans  remain  on  accrual  status  until 
either charged off or paid in full. At December 31, 2019 and 2018, 
our renegotiated TDR portfolio was $679 million and $566 million, 
of which $570 million and $481 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, 
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  35,  38  and  41 
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 85 and Table 38. 

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 more information, see Note 13 – Commitments and 
Contingencies to the Consolidated Financial Statements. 

Commercial Credit Portfolio 
During  2019, credit  quality  among  large  corporate  and  middle-
market  borrowers  in  our  commercial  and  industrial  portfolio 
remained  strong.  Credit  quality  of  commercial  real  estate 
borrowers in most sectors remained stable with conservative LTV 
ratios.  However,  some  of  the  real  estate  markets  experienced 
slowing tenant demand and decelerating rental income. 

Total  commercial  utilized  credit  exposure  increased  $14.3 
billion in 2019 to $635.3 billion driven by higher loans and leases. 
The  utilization  rate  for  loans  and  leases,  SBLCs  and  financial 
guarantees, and  commercial  letters  of  credit, in  the  aggregate, 
was  58  percent  at  December  31,  2019  and  59  percent  at 
December 31, 2018. 

Table  31  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. 

Bank of America 2019  81 
Bank of America 2019  81   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 31  Commercial Credit Exposure by Type 

(Dollars in millions)  

2019 

2018 

2019 

2018 

2019 

2018 

Commercial Utilized (1) 

Commercial Unfunded (2, 3, 4) 
December 31 

Total Commercial Committed 

$ 

517,657  $ 

Loans and leases 
Derivative assets (5) 
Standby letters of credit and financial guarantees 
Debt securities and other investments 
Loans held-for-sale 
Operating leases 
Commercial letters of credit 
Other 

868,946 
43,725 
35,432 
29,675 
23,902 
6,060 
1,378 
898 
389,003  $  1,062,295  $  1,010,016 
(1)   Commercial utilized exposure includes loans of $7.7 billion and $3.7 billion and issued letters of credit with a notional amount of $170 million and $100 million accounted for under the fair value 

405,834  $ 
— 
468 
5,101 
15,135 
— 
451 
— 
426,989  $ 

43,725 
34,941 
25,425 
9,090 
6,060 
1,210 
898 
621,013  $ 

40,485 
36,062 
25,546 
7,047 
6,660 
1,049 
800 
635,306  $ 

— 
491 
4,250 
14,812 
— 
168 
— 

40,485 
36,530 
30,647 
22,182 
6,660 
1,500 
800 

499,664  $ 

369,282  $ 

923,491  $ 

Total  

$ 

option at December 31, 2019 and 2018. 

(2)  Commercial unfunded exposure includes commitments accounted for under the fair value option with a notional amount of $4.2 billion and $3.0 billion at December 31, 2019 and 2018. 
(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 $10.6 billion and $10.7 billion at December 31, 2019 and 2018. 

(5)   Derivative assets are carried at fair value, reflect the effects of legally enforceable master netting agreements and have been reduced by cash collateral of $33.9 billion and $32.4 billion at December 
31, 2019 and 2018. Not reflected in utilized and committed exposure is additional non-cash derivative collateral held of $35.2 billion and $33.0 billion at December 31, 2019 and 2018, which 
consists primarily of other marketable securities. 

portfolio.  The  allowance  for  loan  and  lease  losses  for  the 
Outstanding  commercial  loans  and  leases  increased  $18.0 
billion  during  2019  primarily  in  the  commercial  and  industrial 
commercial  portfolio  increased  $75  million  to  $4.9  billion  at 
portfolio. Nonperforming commercial loans increased $397 million  December  31,  2019.  For  more  information,  see  Allowance  for 
Credit Losses on page 89. Table 32 presents our commercial loans 
and commercial reservable criticized utilized exposure increased 
$391 million driven by a small number of client downgrades across 
and  leases  portfolio  and  related  credit  quality  information  at 
industries  which  were  not  indicative  of  broader  issues  in  the  December 31, 2019 and 2018. 

Table 32  Commercial Credit Quality 

(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 (1) 

Commercial loans excluding loans accounted f

or under 

the fair value option 

Loans accounted for under the fair value option (2) 

Total commercial loans and leases 

(1) 

Includes card-related products. 

Outstandings 

Nonperforming 

December 31 

Accruing Past Due 
90 Days or More 

2019 

2018 

2019 

2018 

2019 

2018 

$ 

$ 

307,048 
104,966 
412,014 
62,689 
19,880 
494,583 
15,333 

$ 

299,277 
98,776 
398,053 
60,845 
22,534 
481,432 
14,565 

509,916 

495,997 

$ 

1,094 
43 
1,137 
280 
32 
1,449 
50 

1,499 

$ 

794 
80 
874 
156 
18 
1,048 
54 

1,102 

7,741 
517,657  $ 

3,667 
499,664  $ 

$ 

— 
1,499  $ 

— 
1,102  $ 

$ 

106 
8 
114 
19 
20 
153 
97 

250 

— 

250  $ 

197 
— 
197 
4 
29 
230 
84 

314 

— 
314 

(2)   Commercial loans accounted for under the fair value option include U.S. commercial of $4.7 billion and $2.5 billion and non-U.S. commercial of $3.1 billion and $1.1 billion at December 31, 2019 

and 2018. For more information on the fair value option, see Note 22 – Fair Value Option to the Consolidated Financial Statements. 

Table 33 presents net charge-offs and related ratios for our commercial loans and leases for 2019 and 2018. 

Table 33  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 

2019 

2018 

Net Charge-off Ratios (1) 
2019 
2018 

$ 

$ 

256  $ 

84 
340 
29 
21 
390 
272 
662  $ 

215 
68 
283 
1 
(1) 
283 
240 
523 

0.08% 
0.08 
0.08 
0.05 
0.10 
0.08 
1.83 
0.13 

0.07% 
0.07 
0.07 
— 
(0.01) 
0.06 
1.70 
0.11 

(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. 

82 82

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 34 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. At December 31, 2019 and 2018, 90 percent 
and 91 percent of commercial reservable criticized utilized exposure was secured. 

Table 34  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 

2019 

2018 

$ 

$ 

8,272 
989 
9,261 
1,129 
329 
10,719 
733 
11,452 

2.46%  $ 
0.89 
2.07 
1.75 
1.66 
2.01 
4.78 
2.09 

$ 

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 

(1)   Total commercial reservable criticized utilized exposure includes loans and leases of $10.7 billion and $10.3 billion and commercial letters of credit of $715 million and $781 million at December 

31, 2019 and 2018. 

(2)  Percentages are calculated as commercial reservable criticized utilized exposure divided by total commercial reservable utilized exposure for each exposure category. 

Commercial and Industrial 
Commercial and industrial loans include U.S. commercial and non-
U.S. commercial portfolios. 

U.S. Commercial 
At December 31, 2019, 70 percent of the U.S. commercial loan 
portfolio,  excluding  small  business,  was  managed  in  Global 
Banking,  16  percent  in  Global  Markets,  13  percent  in  GWIM 
(generally business-purpose loans for high net worth clients) and 
the  remainder  primarily  in  Consumer  Banking.  U.S.  commercial 
loans increased $7.8 billion during 2019, across lines of business. 

Non-U.S. Commercial 
At December 31, 2019, 83 percent of the non-U.S. commercial 
loan portfolio was managed in Global Banking and 17 percent in 
Global Markets. Non-U.S. commercial loans increased $6.2 billion 
during 2019, primarily in Global Banking. For information on the 
non-U.S. commercial portfolio, see Non-U.S. Portfolio on page 87. 

Commercial Real Estate 
Commercial  real  estate  primarily  includes  commercial  loans 
secured by non-owner-occupied real estate and is dependent on 
the  sale  or  lease  of  the  real  estate  as  the  primary  source  of 

repayment.  Outstanding  loans  increased  $1.8  billion,  or  three 
percent,  during  2019  to  $62.7  billion  due  to  new  originations 
slightly  outpacing  paydowns.  The  portfolio  remains  diversified 
across  property  types  and  geographic  regions.  California 
represented the largest state concentration at 24 percent and 23 
percent of the commercial real estate portfolio at December 31, 
2019  and  2018.  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. 

During 2019, 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. 

Table 35 presents outstanding commercial real estate loans 
by  geographic  region, based  on  the  geographic  location  of  the 
collateral, and by property type. 

Bank of America 2019  83 
Bank of America 2019  83   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 35  Outstanding Commercial Real Estate Loans 

(Dollars in millions) 

By Geographic Region 

California 
Northeast 
Southwest 
Southeast 
Florida 
Illinois 
Midwest 
Midsouth 
Northwest 
Non-U.S. 
Other (1) 

December 31 

2019 

2018 

$ 

$ 

14,910 
12,408 
8,408 
5,937 
3,984 
3,349 
3,203 
2,468 
1,638 
3,724 
2,660 

14,002 
10,895 
7,339 
5,726 
3,680 
2,989 
3,772 
2,919 
2,178 
4,240 
3,105 
60,845 

Total outstanding commercial real estate loans 

$ 

62,689  $ 

By Property Type 
Non-residential 

Office 
Industrial / Warehouse 
Shopping centers / Retail 
Multi-family rental 
Hotels / Motels 
Unsecured 
Multi-use 
Other 

17,246 
5,379 
8,798 
7,762 
7,248 
2,956 
2,848 
7,029 
59,266 
1,579 
60,845 
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. 

8,677 
8,183 
7,250 
6,982 
3,438 
1,788 
6,958 
61,178 
1,511 

Total outstanding commercial real estate loans  

Total non-residential 

62,689  $ 

17,902  $ 

$ 

$ 

Residential 

(1) 

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 52 percent 
and 51 percent of the U.S. small business commercial portfolio 
at  December  31, 2019  and  2018.  Of  the  U.S.  small  business 
commercial net charge-offs, 94 percent and 95 percent were credit 
card-related products in 2019 and 2018. 

Nonperforming Commercial Loans, Leases and Foreclosed 
Properties Activity 
Table 36 presents the nonperforming commercial loans, leases 
and  foreclosed  properties  activity  during  2019  and  2018. 

Nonperforming loans do not include loans accounted for under the 
fair value option. During 2019, nonperforming commercial loans 
and leases increased $397 million to $1.5 billion. At December 
31, 2019, 94 percent of commercial nonperforming loans, leases 
and  foreclosed  properties  were  secured  and  64  percent  were 
contractually  current.  Commercial  nonperforming  loans  were 
carried  at  88  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 36  Nonperforming Commercial Loans, Leases and Foreclosed Properties Activity (1, 2) 

(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 

2019 

2018 

$ 

1,102 
2,048 

$ 

1,304 
1,415 

(648) 
(215) 
(120) 
(478) 
(9) 
(181) 
397 
1,499 
56 
1,555 

0.29% 

0.30 

$ 

(771) 
(210) 
(246) 
(361) 
(12) 
(17) 
(202) 
1,102 
56 
1,158 

0.22% 

0.23 

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 $239 million and $292 million at December 31, 2019 and 2018. 
(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. 

84 84

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 37 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 37  Commercial Troubled Debt Restructurings 

Nonperforming 

December 31, 2019 
Performing 

Total 

Nonperforming 

December 31, 2018 
Performing 

Total 

(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 

$ 

617  $ 

41 
658 
212 
18 
888 
— 

Total commercial troubled debt restructurings 

$ 

888  $ 

Industry Concentrations 
Table  38  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 $52.3 billion, or five percent, during 2019 to 
$1.1 trillion. The increase in commercial committed exposure was 
concentrated in the Real estate, Utilities and Finance companies 
industry  sectors.  Increases  were  partially  offset  by  decreased 
exposure to the Pharmaceuticals and biotechnology, Technology 
hardware and equipment, and Government and public education 
industry sectors. 

Industry  limits  are  used  internally  to  manage  industry 
concentrations  and  are  based  on  committed  exposure  that  is 
allocated  on  an  industry-by-industry  basis.  A  risk  management 
framework is in place to set and approve industry limits as well 

999  $ 
193 
1,192 
14 
31 
1,237 
27 
1,264  $ 

1,616  $ 

234 
1,850 
226 
49 
2,125 
27 
2,152  $ 

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 

as to provide ongoing monitoring. The MRC oversees industry limit 
governance. 

Asset managers and funds, our largest industry concentration 
with committed exposure of $110.0 billion, increased $2.1 billion, 
or two percent, during 2019. 

Real  estate,  our  second  largest  industry  concentration  with 
committed exposure of $96.3 billion, increased $9.8 billion, or 11 
percent,  during  2019.  This  growth  occurred  primarily  in  the 
category of industrial and warehouse buildings, partially offset by 
declines in REITs. 

Capital  goods,  our  third  largest  industry  concentration  with 
committed exposure of $80.9 billion, increased $5.8 billion, or 
eight percent, during 2019 with the growth largely occurring in the 
trading companies and distributors industry categories, partially 
offset  by  a  decrease  in  industrial  conglomerates.  For  more 
information on the commercial real estate and related portfolios, 
see Commercial Portfolio Credit Risk Management – Commercial 
Real Estate on page 83. 

Bank of America 2019  85 
Bank of America 2019  85   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 38  Commercial Credit Exposure by Industry (1) 

(Dollars in millions) 

Asset managers and funds 
Real estate (3) 
Capital goods 
Finance companies 
Healthcare equipment and services 
Government and public education 
Materials 
Consumer services 
Retailing 
Food, beverage and tobacco 
Commercial services and supplies 
Energy 
Utilities 
Transportation 
Global commercial banks 
Individuals and trusts 
Technology hardware and equipment 
Media 
Vehicle dealers 
Consumer durables and apparel 
Software and services 
Pharmaceuticals and biotechnology 
Telecommunication services 
Insurance 
Automobiles and components 
Financial markets infrastructure (clearinghouses) 
Food and staples retailing 
Religious and social organizations 

Total commercial credit exposure by industry 
Net credit default protection purchased on total commitments (4) 
Includes U.S. small business commercial exposure. 

(1) 

Commercial 
Utilized 

Total Commercial 
Committed (2) 

December 31 

2019 

2018 

2019 

2018 

$ 

$ 

71,289  $ 
70,341 
41,060 
40,171 
34,353 
41,889 
26,663 
28,434 
25,868 
24,163 
23,102 
16,407 
12,383 
23,448 
26,492 
18,926 
10,645 
12,429 
18,013 
10,193 
10,432 
5,962 
9,144 
6,669 
7,345 
9,351 
6,290 
3,844 
635,306  $ 

71,756  $ 
65,328 
39,192 
36,662 
35,763 
43,675 
27,347 
25,702 
25,333 
23,586 
22,623 
13,727 
12,035 
22,814 
26,583 
18,643 
13,014 
12,132 
17,603 
9,904 
8,809 
7,430 
8,686 
8,674 
7,131 
8,317 
4,787 
3,757 
621,013  $ 
$ 

109,972  $ 

96,349 
80,871 
63,940 
55,918 
53,566 
52,128 
49,071 
48,317 
45,956 
38,943 
36,327 
36,060 
33,027 
28,670 
27,815 
24,071 
23,629 
21,435 
21,245 
20,556 
20,203 
16,103 
15,214 
14,910 
11,851 
10,392 
5,756 

107,888 
86,514 
75,080 
56,659 
56,489 
54,749 
51,865 
43,298 
47,507 
42,745 
39,349 
32,279 
27,623 
31,523 
28,627 
25,019 
26,228 
24,502 
20,446 
20,199 
19,172 
23,634 
14,166 
15,807 
13,893 
10,042 
9,093 
5,620 
1,062,295  $  1,010,016 
(2,663) 

(3,349)  $ 

(2)   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 $10.6 billion and $10.7 billion at December 31, 2019 and 2018. 

(3)   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. 

(4)  Represents net notional credit protection purchased to hedge funded and unfunded exposures for which we elected the fair value option, as well as certain other credit exposures. For more 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, 2019 and 2018, 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 $3.3 
billion and $2.7 billion. We recorded net losses of $145 million 
in 2019 compared to net losses of $2 million in 2018 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 45. For more information, see 
Trading Risk Management on page 93. 

Tables 39 and 40 present the maturity profiles and the credit 
exposure debt ratings of the net credit default protection portfolio 
at December 31, 2019 and 2018. 

Table 39  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 

2019 

2018 

54% 

45 

1 
100% 

20% 

78 

2 
100% 

86 86

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 40  Net Credit Default Protection by Credit 

Exposure Debt Rating 

Net 
Notional (1) 

Percent of 
Total 

Net 
Notional (1) 

Percent of 
Total 

December 31 

(Dollars in millions) 

2019 

2018 

Ratings (2, 3) 
A 
BBB 
BB 
B 
CCC and below 
NR (4) 

Total net credit  

default protection 

$ 

(697) 
(1,089) 
(766) 
(373) 
(119) 
(305) 

20.8%  $ 
32.5 
22.9 
11.1 
3.6 
9.1 

(700) 
(501) 
(804) 
(422) 
(205) 
(31) 

26.3% 
18.8 
30.2 
15.8 
7.7 
1.2 

$ 

(3,349) 

100.0%  $ 

(2,663) 

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 
derivative  assets,  including  our  purchased  credit  default 
protection. 

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 41 presents our 20 largest non-U.S. country exposures 
at December 31, 2019. These exposures accounted for 88 percent 
and 89 percent of our total non-U.S. exposure at December 31, 
2019  and  2018.  Net  country  exposure  for  these  20  countries 
increased  $8.5  billion  in  2019,  primarily  driven  by  increased 
sovereign and corporate exposure across multiple countries. 

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. 

Bank of America 2019  87 
Bank of America 2019  87   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 41  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 
2019 

Hedges and 
Credit Default 
Protection 

Net Country 
Exposure at 
December 31 
2019 

Increase 
(Decrease) 
from 
December 31 
2018 

$ 

29,156  $ 
21,920 
7,967 
7,243 
13,304 
7,817 
7,393 
6,100 
8,450 
6,322 
5,981 
3,749 
4,190 
4,387 
5,106 
5,077 
2,353 
3,153 
3,267 
2,142 

17,341  $ 

7,408 
8,255 
9,208 
497 
364 
716 
3,583 
896 
3,585 
758 
435 
1,733 
2,947 
353 
1,259 
2,303 
1,073 
229 
979 

7,800  $ 
1,828 
1,690 
876 
1,085 
398 
218 
415 
1,002 
330 
386 
172 
224 
213 
434 
526 
510 
258 
119 
76 

3,545  $ 
1,967 
2,879 
969 
949 
3,660 
3,683 
1,443 
1,589 
876 
1,762 
3,528 
1,814 
325 
1,194 
159 
1,386 
867 
10 
201 

57,842  $ 
33,123 
20,791 
18,296 
15,835 
12,239 
12,010 
11,541 
11,937 
11,113 
8,887 
7,884 
7,961 
7,872 
7,087 
7,021 
6,552 
5,351 
3,625 
3,398 

(1,998)  $ 
(2,295) 
(669) 
(2,041) 
(248) 
(222) 
(238) 
(439) 
(1,405) 
(786) 
(182) 
(58) 
(150) 
(487) 
(31) 
(514) 
(1,175) 
(629) 
(38) 
(31) 

55,844  $ 
30,828 
20,122 
16,255 
15,587 
12,017 
11,772 
11,102 
10,532 
10,327 
8,705 
7,826 
7,811 
7,385 
7,056 
6,507 
5,377 
4,722 
3,587 
3,367 

990 
2,171 
607 
3,604 
946 
905 
1,523 
1,172 
(9,491) 
(1,250) 
(465) 
2,309 
1,575 
(379) 
(180) 
929 
2,296 
72 
(62) 
1,206 

$ 

155,077  $ 

63,922  $ 

18,560  $ 

32,806  $ 

270,365  $ 

(13,636)  $ 

256,729  $ 

8,478  

(Dollars in millions) 

United Kingdom 
Germany 
Canada 
France 
China 
India 
Brazil 
Australia 
Japan 
Netherlands 
South Korea 
Singapore 
Mexico 
Switzerland 
Hong Kong 
Belgium 
Italy 
Spain 
United Arab Emirates 
Ireland 

Total top 20 non-U.S.  
countries exposure 

A number of economic conditions and geopolitical events have 
given rise to risk aversion in certain emerging markets. Additionally, 
in light of ongoing trade tensions, we continue to closely monitor 
our exposures to tariff-sensitive regions and industries, particularly 
to countries that account for a large percentage of U.S. trade, such 
as China. 

Our  largest  emerging  market  country  exposure  at  December 
31,  2019  was  China,  with  net  exposure  of  $15.6  billion, 
concentrated  in  large  state-owned  companies,  subsidiaries  of 
multinational corporations and commercial banks. 

The  economic  performance  in  the  EU  remains  uncertain, 
including as a result of the uncertainty surrounding the terms of 
a potential trade agreement and other terms associated with the 
future relationship between the U.K. and the EU, which could weigh 
unevenly on the economic performance of EU countries generally, 
and even more heavily on that of the U.K. For more information, 
see Item 1A. Risk Factors of our 2019 Annual Report on Form 10-
K and Executive Summary – Recent Developments – U.K. Exit from 
the EU on page 44. Our largest EU country exposure at December 

31, 2019 was the U.K. with net exposure of $55.8 billion, which 
represents a $990 million increase from December 31, 2018. Our 
second largest EU exposure was Germany with net exposure of 
$30.8 billion as of December 31, 2019, which represents a $2.2 
billion increase from December 31, 2018. The increase in Germany 
was primarily driven by an increase in  sovereign exposure. 

Table  42  presents  countries  that  had  total  cross-border 
exposure, including  the  notional  amount  of  cash  loaned  under 
secured financing agreements, exceeding one percent of our total 
assets  at  December  31,  2019.  Local  exposure,  defined  as 
exposure booked in local offices of a respective country with clients 
in the same country, is excluded. At December 31, 2019, the U.K. 
and France were the only countries where their respective total 
cross-border exposures exceeded one percent of our total assets. 
At December 31, 2019, Germany had total cross-border exposure 
of $19.4 billion representing 0.80 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, 2019. 

Table 42  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 

2019  $ 
2018 
2017 
2019 
2018 
2017 

1,859  $ 
1,505 
923 
736 
633 
2,964 

3,580  $ 
3,458 
2,984 
2,473 
2,385 
1,521 

93,232  $ 
46,191 
47,205 
23,172 
29,847 
27,903 

98,671 
51,154 
51,112 
26,381 
32,865 
32,388 

4.05% 
2.17 
2.24 
1.08 
1.40 
1.42 

88 88

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Provision for Credit Losses 
The  provision  for  credit  losses  increased  $308  million  to  $3.6 
billion in 2019 compared to 2018. The provision for credit losses 
was $58 million lower than net charge-offs for 2019, resulting in 
a decrease in the allowance for credit losses. This compared to a 
decrease  of  $481  million  in  the  allowance  for  credit  losses  in 
2018. Net charge-offs in 2019 were $3.6 billion compared to $3.8 
billion in 2018. 

The  provision  for  credit  losses  for  the  consumer  portfolio 
decreased $117 million to $2.8 billion in 2019 compared to 2018. 
The decrease was primarily driven by consumer real estate loan 
sales. 

The  provision  for  credit  losses  for  the  commercial  portfolio, 
including unfunded lending commitments, increased $425 million 
to $758 million in 2019 compared to 2018. The increase was due 
in part to energy reserve releases in the prior-year periods. 

Assuming a stable economic environment in 2020 compared 
to the end of 2019, we expect net charge-offs of approximately 
$1  billion  per  quarter  in  2020.  In  view  of  the  newly  adopted 
accounting  standard  on  the  measurement  of  the  allowance  for 
credit  losses,  we  expect  the  provision  for  credit  losses  to  be 
modestly higher than net charge-offs in 2020, assuming no change 
in  the  current  economic  outlook  and  estimates  of  loan  growth, 
including  product  mix.  For  more  information  regarding  the  new 
accounting  standard,  see  Note  1  –  Summary  of  Significant 
Accounting Principles to the Consolidated Financial Statements. 

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 and small business credit 
card 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, credit  scores 
and the amount of loss in the event of default. Our consumer real 
estate loss forecast model estimates the portion of loans that will 
default based on individual loan attributes, the most significant of 
which  are  refreshed  LTV  or  combined  loan-to-value  (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, 2019, the loss forecast process 
resulted in reductions in the allowance related to the residential 
mortgage and home equity portfolios compared to December 31, 
2018. 

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, 2019, the allowance 
for the commercial real estate portfolio increased compared to 
December 31, 2018. 

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. 

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 43, was $4.5 billion at December 
31, 2019, a decrease of $260 million from December 31, 2018. 
The decrease was primarily in the consumer real estate portfolio, 
partially  offset  by  an  increase  in  the  credit  card  portfolio.  The 

Bank of America 2019  89 
Bank of America 2019  89   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
reduction in the allowance for the consumer real estate portfolio 
was driven by improved credit quality, a decrease in loan balances 
in  our  non-core  portfolio,  proactive  credit  risk  management 
initiatives and high credit quality originations.  The improved credit 
quality  was  impacted  by  continuing  improvements  in  the  U.S. 
economy  and  strong  labor  markets  evidenced  by  low  levels  of 
unemployment  and  increases  in  home  prices.  Nonperforming 
consumer loans decreased $1.8 billion during 2019 as loan sales, 
returns to performing status and paydowns continued to outpace 
additions.  The increase in allowance for the credit card portfolio 
was primarily driven by continued portfolio seasoning. 

The allowance for loan and lease losses for the commercial 
portfolio, as presented in Table 43, was $4.9 billion at December 
31, 2019, an increase of $75 million from December 31, 2018. 
Commercial  reservable  criticized  utilized  exposure  increased  to 
$11.5 billion at December 31, 2019 from $11.1 billion (to 2.09 
percent from 2.08 percent of total commercial reservable utilized 
exposure) at December 31, 2018, and nonperforming commercial 
loans increased to $1.5 billion at December 31, 2019 from $1.1 
billion  (to  0.29  percent  from  0.22  percent  of  outstanding 
commercial  loans  excluding  loans  accounted  for  under  the  fair 
value option) at December 31, 2018 with the increases spread 
across multiple industries. See Tables 32, 33 and 34 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 0.97 percent at December 
31, 2019 compared to 1.02 percent at December 31, 2018. 

On  January  1,  2020,  the  Corporation  adopted  the  new 
accounting  standard  that  requires  the  measurement  of  the 
allowance for credit losses to be based on management’s best 
estimate  of  lifetime  expected  credit  losses  inherent  in  the 

Corporation’s  relevant  financial  assets.  Upon  adoption  of  the 
standard on January 1, 2020, the Corporation recorded a $3.3 
billion, or 32 percent, increase to the allowance for credit losses. 
After adjusting for deferred taxes and other adoption effects, a 
$2.4 billion decrease was recorded in retained earnings through 
a  cumulative-effect  adjustment.  For  more  information  regarding 
this new accounting standard, see Note 1 – Summary of Significant 
Accounting Principles to the Consolidated Financial Statements. 

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  $813 
million  at  December  31,  2019  compared  to  $797  million  at 
December 31, 2018. 

Table 43  Allocation of the Allowance for Credit Losses by Product Type 

$ 

(Dollars in millions)  

Allowance for loan and lease losses 

Residential mortgage 
Home equity 
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 
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, 2019 

December 31, 2018 

3.45% 
2.35 
39.39 
2.49 
0.55 
48.23 
32.02 
6.99 
11.07 
1.69 
51.77 
100.00% 

325 
221 
3,710 
234 
52 
4,542 
3,015 
658 
1,042 
159 
4,874 
9,416 
813 
10,229  

0.14%  $ 
0.55 
3.80 
0.26 
n/m 
0.98 
0.94 
0.63 
1.66 
0.80 
0.96 
0.97 

$ 

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 

(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 $257 million and $336 million and home equity loans of $337 million and $346 million at December 31, 2019 and 2018. 
Commercial loans accounted for under the fair value option include U.S. commercial loans of $4.7 billion and $2.5 billion and non-U.S. commercial loans of $3.1 billion and $1.1 billion at December 
31, 2019 and 2018. 
Includes allowance for loan and lease losses for U.S. small business commercial loans of $523 million and $474 million at December 31, 2019 and 2018.  
n/m = not meaningful  

(2) 

90 90

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 44 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 2019 and 2018. 

Table 44  Allowance for Credit Losses 

(Dollars in millions)  

Allowance for loan and lease losses, January 1 
Loans and leases charged off 

Residential mortgage 
Home equity 
Credit card 
Direct/Indirect consumer 
Other consumer 

Total consumer charge-offs  

U.S. commercial (1) 
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 
Credit card 
Direct/Indirect consumer 
Other consumer 

Total consumer recoveries  

U.S. commercial (2) 
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  

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  

Loan and allowance ratios: 

2019 

2018 

$ 

9,601 

$ 

10,393 

(93) 
(429) 
(3,535) 
(518) 
(249) 
(4,824) 
(650) 
(115) 
(31) 
(26) 
(822) 
(5,646) 

140 
787 
587 
309 
15 
1,838 
122 
31 
2 
5 
160 
1,998 
(3,648) 
3,574 
(111) 
9,416 
797 
16 
813 
10,229 

$ 

(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) 
3,262  
(291)  
9,601 
777  
20  
797 
10,398 

$ 

Loans and leases outstanding at December 31 (4) 
Allowance for loan and lease losses as a percentage of total loans and leases outstanding at December 31 (4) 
Consumer allowance for loan and lease losses as a percentage of total consumer loans and leases outstanding at 

December 31 (5) 

Commercial allowance for loan and lease losses as a percentage of total commercial loans and leases outstanding at  

December 31 (6)  

Average loans and leases outstanding (4) 
Net charge-offs as a percentage of average loans and leases outstanding (4) 
Allowance for loan and lease losses as a percentage of total nonperforming loans and leases at December 31 
Ratio of the allowance for loan and lease losses at December 31 to net charge-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 (7) 

$ 

975,091 

$ 

942,546 

0.97% 

1.02% 

0.98 

0.96 

1.08 

0.97 

$ 

951,583 

$ 

927,531 

0.38% 
265 
2.58 

0.41% 
194 
2.55 

$ 

4,151 

$ 

4,031 

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) 

148% 

113% 

(1) 

(2) 

Includes U.S. small business commercial charge-offs of $320 million and $287 million in 2019 and 2018. 
Includes U.S. small business commercial recoveries of $48 million and $47 million in 2019 and 2018. 

(3)  Primarily represents write-offs of purchased credit-impaired (PCI) loans, the net impact of portfolio sales, and transfers to loans held-for-sale. 
(4)   Outstanding loan and lease balances and ratios do not include loans accounted for under the fair value option of $8.3 billion and $4.3 billion at December 31, 2019 and 2018. Average loans 

accounted for under the fair value option were $6.8 billion and $5.5 billion in 2019 and 2018. 

(5)  Excludes consumer loans accounted for under the fair value option of $594 million and $682 million at December 31, 2019 and 2018. 
(6)  Excludes commercial loans accounted for under the fair value option of $7.7 billion and $3.7 billion at December 31, 2019 and 2018. 
(7)  Primarily includes amounts allocated to credit card and unsecured consumer lending portfolios in Consumer Banking. 

Bank of America 2019  91 
Bank of America 2019  91   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 95. 

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 
financial 
techniques 
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. 

responsible 

Model  risk  is  the  potential  for  adverse  consequences  from 
decisions  based  on  incorrect  or  misused  model  outputs  and 
reports. Given that models are used across the Corporation, model 
risk impacts all risk types including credit, market and operational 
(EMRC),  a 
risk.  The  Enterprise  Model  Risk  Committee 
subcommittee  of  the  MRC,  is 
for  providing 
management oversight and approval of model risk management 
and  governance.  The  EMRC  defines  model  risk  standards, 
consistent  with  the  Corporation’s  Risk  Framework  and  risk 
appetite, prevailing regulatory guidance and industry best practice. 
All models, including risk management, valuation and regulatory 
capital  models, must  meet  certain  validation  criteria, including 
effective  challenge  of  the  conceptual  soundness  of  the  model, 
independent  model  testing  and  ongoing  monitoring  through 
outcomes analysis and benchmarking. 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. 

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 97. 

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 

92 92

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 risks 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, which 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 
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 66. 
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 45 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 45 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 45 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 45 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 45 presents year-end, average, high and low daily trading 
VaR for 2019 and 2018 using a 99 percent confidence level. The 
amounts disclosed in Table 45 and Table 46 align to the view of 
covered positions used in the Basel 3 capital calculations. Foreign 

Bank of America 2019  93 
Bank of America 2019  93   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 annual average of total covered positions and less liquid  
trading positions portfolio VaR slightly increased during 2019 with  
no significant drivers.  

Table 45  Market Risk VaR for Trading Activities 

(Dollars in millions) 

2019 

2018 

Year 
End 

Average 

High (1) 

Low (1) 

Year 
End 

Average 

High (1) 

Low (1) 

$ 

$ 

$ 

Total covered positions portfolio 
Impact from less liquid exposures 

Foreign exchange 
Interest rate 
Credit 
Equity 
Commodities 
Portfolio diversification 

2 
15 
20 
11 
3 
— 
20 
— 
23 
8 
4 
— 
5 
— 
26 
(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 

36 
26 
20 
13 
(59) 
45 
5 
50 
8 
5 
(7) 
6 
(3) 
53  $ 

15  $ 
45 
31 
40 
15 
— 
45 
— 
51 
18 
17 
— 
16 
— 
57 

14 
16 
14 
4 
— 
24 
— 
27 
7 
4 
— 
5 
— 
28  $ 

Fair value option loans 
Fair value option hedges 
Fair value option portfolio diversification 

6 
24 
23 
22 
6 
(49) 
32 
3 
35 
10 
10 
(10) 
10 
(7) 
38 

4 
25 
26 
29 
4 
(47) 
41 
— 
41 
8 
10 
(9) 
9 
(5) 
45 

25 
25 
20 
8 
(55) 
31 
3 
34 
11 
9 
(11) 
9 
(5) 
38 

13 
49 
32 
33 
31 
— 
47 
— 
53 
13 
17 
— 
16 
— 
56 

Total covered positions and less liquid trading positions portfolio 

Total fair value option portfolio 

Total market-based portfolio 

Portfolio diversification 

2  $ 

9  $ 

8  $ 

$ 

$ 

$ 

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 2019, corresponding to the 

data in Table 45. 

Additional VaR statistics produced within our single VaR model are provided in Table 46 at the same level of detail as in Table 45. 
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 46 presents average trading 
VaR statistics at 99 percent and 95 percent confidence levels for 2019 and 2018. 

Table 46  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  

2019 

2018 

99 percent 

95 percent 

99 percent 

95 percent 

$ 

$ 

6  $ 

24 
23 
22 
6 
(49) 
32 
3 
35 
10 
10 
(10) 
10 
(7) 
38  $ 

3  $ 

15 
15 
11 
3 
(29) 
18 
2 
20 
5 
6 
(5) 
6 
(5) 
21  $ 

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 

94 94

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
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 intra-day 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  2019,  there  were  no  days  in  which  there  was  a 
backtesting excess for our total covered portfolio VaR, utilizing a 
one-day holding period. 

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 21 – 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 2019 and 2018. During 2019, positive trading-related revenue 
was  recorded  for  98  percent  of  the  trading  days,  of  which  80 
percent were daily trading gains of over $25 million, and the largest 
loss  was  $35  million.  This  compares  to  2018  where  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. 

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 63. 

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 

Bank of America 2019  95 
Bank of America 2019  95   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 47 presents the spot and 12-month forward rates used 

in our baseline forecasts at December 31, 2019 and 2018. 

Table 47  Forward Rates 

Federal 
Funds 

December 31, 2019 
Three-month 
LIBOR 

10-Year 
Swap 

Spot rates 
12-month forward rates 

1.75% 
1.50 

1.91% 
1.62 

Spot rates 
12-month forward rates 

December 31, 2018 

2.50% 
2.50 

2.81% 
2.64 

1.90% 
1.92 

2.71% 
2.75 

Table 48 shows the pretax impact to forecasted net interest 
income over the next 12 months from December 31, 2019 and 
2018,  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  2019,  the  asset  sensitivity  of  our  balance  sheet 
increased primarily due to decreases in interest 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 
available for sale (AFS), may adversely affect accumulated other 
comprehensive  income  (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 67. 

Table 48  Estimated Banking Book Net Interest Income 

Sensitivity to Curve Changes 

Short 
Rate 
(bps) 

Long 
Rate 
(bps) 

December 31 

2019 

2018 

+100 

+100  $ 

4,190  $ 

2,833 

-100 

-100 

(6,536) 

(4,280) 

+100 

— 

2,641 

2,158 

— 

-100 

(2,965) 

(1,618) 

-100 

— 

(3,527) 

(2,648) 

(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 

— 

+100 

1,561 

675 

The sensitivity analysis in Table 48 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 deposits 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 48 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 
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 
2019 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 
$496 million and $1.3 billion, on a pretax basis, at December 31, 
2019 and 2018. 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, 2019, the pretax net losses are expected to be reclassified 
into earnings as follows: 17 percent within the next year, 44 percent 
in years two through five, 22 percent in years six through ten, with 
the  remaining  17  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, 2019. 

Table 49 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 

96 96

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
durations of our open ALM derivatives at December 31, 2019 and 
2018.  These  amounts  do  not  include  derivative  hedges  on  our 
MSRs. During 2019, the fair value of receive-fixed interest rate  

swaps increased while pay-fixed interest rate swaps decreased,  
driven by lower swap rates.  

Table 49  Asset and Liability Management Interest Rate and Foreign Exchange Contracts 

December 31, 2019 
Expected Maturity 

(Dollars in millions, average estimated duration in 

years) 

Fair 
Value 

Receive-fixed interest rate swaps (1) 

$  12,370 

Total 

2020 

2021 

2022 

2023 

2024 

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 

(2,669) 

(290) 

$215,123 

$  16,347 

$  14,642 

$  21,616 

$  36,356 

$  21,257 

$104,905 

2.68% 

2.68% 

3.17% 

2.48% 

2.36% 

2.55% 

2.79% 

$  69,586 

$  4,344 

$  2,117 

$ 

2.36% 

2.16% 

2.15% 

— 
—% 

$  13,993 

$  8,194 

$  40,938 

2.52% 

2.26% 

2.35% 

$152,160 

$  18,857 

$  18,590 

$  4,306 

$  2,017 

$  14,567 

$  93,823 

Foreign exchange basis swaps (1, 3, 4) 

(1,258) 

Notional amount 

Foreign exchange contracts (1, 4, 5) 

Notional amount (6) 

Option products 

Notional amount 

Net ALM contracts 

414 

— 

$ 

8,567 

113,529 

23,639 

24,215 

14,611 

7,111 

3,521 

40,432 

(53,106) 

(79,315) 

4,539 

2,674 

2,340 

4,432 

12,224 

15 

—

—

—

15

—

— 

(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 

December 31, 2018 
Expected Maturity 

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 

Foreign exchange basis swaps (1, 3, 4) 

(1,716) 

Notional amount 

Foreign exchange contracts (1, 4, 5) 

Notional amount (6) 

Option products 

Notional amount 

Net ALM contracts 

82 

2 

$ 

812 

$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% 

$  49,275 

$  1,210 

$  4,344 

$  1,616 

$ 

2.50% 

2.07% 

2.16% 

2.22% 

— 
—% 

$  10,801 

$  31,304 

2.59% 

2.55% 

295 

21 

$101,203 

$  7,628 

$  15,097 

$  15,493 

$  2,586 

$  2,017 

$  58,382 

106,742 

13,946 

21,448 

19,241 

10,239 

6,260 

35,608 

(8,447) 

(27,823) 

587 

572 

13 

— 

4,196 

2,741 

2,448 

9,978 

— 

— 

15 

— 

Average 
Estimated 
Duration 

6.47 

6.99 

Average 
Estimated 
Duration 

5.17 

6.30 

(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, 2019 and 2018, the notional amount of same-currency basis swaps included $152.2 billion and $101.2 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 $(53.1) billion at December 31, 2019 was comprised of $29.0 billion in foreign currency-denominated and cross-currency receive-fixed swaps, 
$(82.4) billion in net foreign currency forward rate contracts, $(313) million in foreign currency-denominated interest rate swaps and $644 million in net foreign currency futures contracts. Foreign 
exchange contracts of $(8.4) billion at December 31, 2018 were 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 interest rate swaps and $814 million in foreign currency futures contracts. 

(6)  Reflects the net of long and short positions. Amounts shown as negative reflect a net short position. 

rates,  the  value  of  the  MSRs  will  increase  driven  by  lower 
prepayment expectations. Because the interest rate risks of these 
hedged items offset, we combine them into one overall hedged 
item with one combined economic hedge portfolio consisting of 
derivative contracts and securities. 

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  Compliance and Operational Risk Management
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 

During  2019,  2018  and  2017,  we  recorded  gains  of  $291 
million, $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
21  –  Fair  Value  Measurements  to  the  Consolidated  Financial 
Statements. 

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 

Bank of America 2019  97 
Bank of America 2019  97   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 66. 

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  third-party  dependencies,  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 
control functions in the identification of testing needs and test 
design,  and  is  accountable  for  test  execution,  reporting  and 
analysis of results. 

Corporate  Audit  provides  independent  assessment  and 
validation through testing of key compliance and operational risk 
processes and controls across the Corporation. 

The  Corporation's  Global  Compliance  Enterprise  Policy  and 
Operational  Risk  Management  - Enterprise  Policy  set  the 
requirements  for  reporting  compliance  and  operational  risk 
information  to  executive  management  as  well  as  the  Board  or 
in  support  of  Global 
appropriate  Board-level  committees 
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, including  as  a 
result  of  malicious  technological  attacks,  that  impact  the 
confidentiality,  availability  or 
third 
parties'  (including  their  downstream  service  providers,  the 
financial  services  industry  and  financial  data  aggregators) 
operations, systems  or  data, including  sensitive  corporate  and 
customer  information.  The  Corporation  manages  information 
security risk in accordance with internal policies which govern our 

integrity  of  our,  or 

comprehensive information security program designed to protect 
the Corporation by enabling preventative, detective and responsive 
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.  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 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. 

98 98

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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, 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, 2019 would have increased $18 million. 
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, 2019 would have increased $46 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 $2.6 billion at December 31, 2019. 

The allowance for loan and lease losses as a percentage of 
total loans and leases at December 31, 2019 was 0.97 percent 
and these hypothetical increases in the allowance would raise the 
ratio to 1.24 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. 

The  processes,  judgments  and  estimates  described  herein 
relate to the accounting standard in effect through December 31, 
2019.  On  January  1,  2020,  the  Corporation  adopted  the  new 
accounting  standard  that  requires  the  measurement  of  the 
allowance for credit losses to be based on management’s best 
estimate  of  lifetime  expected  credit  losses  inherent  in  the 
Corporation’s relevant financial assets. The Corporation’s lifetime 
expected  credit  losses  are  determined  using  macroeconomic 
forecast assumptions and management judgments applicable to 
and  through  the  expected  life  of  the  loan  portfolios.  For  more 

information,  see  Note  1  –  Summary  of  Significant  Accounting 
Principles to the Consolidated Financial Statements. 

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 
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 more information, see Note 21 
– Fair Value Measurements and Note 22 – Fair Value Option to the 
Consolidated Financial Statements. 

value  determination  and 

fair 

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 2019, 2018 

Bank of America 2019  99 
Bank of America 2019  99   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
and  2017,  see  Note  21  –  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. 

See  Note  20  –  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 2019 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  to  the 
Consolidated Financial Statements. 

We completed our annual goodwill impairment test as of June 
30,  2019  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, 2019, see Note 8 – Goodwill and Intangible 
Assets to the Consolidated Financial Statements. 

Certain Contingent Liabilities 
For more information on the complex judgments associated with 
certain  contingent  liabilities,  see  Note  13  –  Commitments  and 
Contingencies to the Consolidated Financial Statements. 

100 100

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Non-GAAP Reconciliations 
Tables 50 and 51 provide reconciliations of certain non-GAAP financial measures to GAAP financial measures. 

Table 50  Five-year Reconciliations to GAAP Financial Measures (1) 

(Dollars in millions, shares in thousands) 

2019 

2018 

2017 

2016 

2015 

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 

(68,951) 
(1,721) 
773 

$  267,889  $  264,748  $  271,289  $  265,843  $  251,384 
(69,772) 
(4,201) 
1,852 
$  197,990  $  194,645  $  200,814  $  194,355  $  179,263  
(21,808)  
$  174,954  $  171,696  $  176,626  $  169,699  $  157,455 

(69,750) 
(3,382) 
1,644 

(68,951) 
(2,058) 
906 

(69,286) 
(2,652) 
1,463 

(24,188) 

(22,949) 

(24,656) 

(23,036) 

(68,951) 
(1,661) 
713 

$  264,810  $  265,325  $  267,146  $  266,195  $  255,615 
(69,761) 
(3,768) 
1,716 
$  194,911  $  195,458  $  196,826  $  195,007  $  183,802  
(22,272)  
$  171,510  $  173,132  $  174,503  $  169,787  $  161,530 

(68,951) 
(2,312) 
943 

(69,744) 
(2,989) 
1,545 

(68,951) 
(1,774) 
858 

(25,220) 

(22,323) 

(22,326) 

(23,401) 

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

$ 2,434,079  $2,354,507  $2,281,234  $2,188,067  $2,144,606 
(69,761) 
(3,768) 
1,716 
$ 2,364,180  $2,284,640  $2,210,914  $2,116,879  $2,072,793 
(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 

(69,744) 
(2,989) 
1,545 

(68,951) 
(2,312) 
943 

(68,951) 
(1,774) 
858 

(68,951) 
(1,661) 
713 

Tangible assets  

Corporation, see Supplemental Financial Data on page 48. 

Table 51  Quarterly Reconciliations to GAAP Financial Measures (1) 

(Dollars in millions)  

Fourth 

Third 

Second 

First 

Fourth 

Third 

Second 

First 

2019 Quarters  

2018 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 

$  266,900  $  270,430  $  267,975  $  266,217  $  263,698  $  264,653  $  265,181  $  265,480 

(68,951) 

(1,678) 

730 

(68,951) 

(68,951) 

(68,951) 

(68,951) 

(68,951) 

(68,951) 

(68,951) 

(1,707) 

(1,736) 

(1,763) 

(1,857) 

(1,992) 

(2,126) 

(2,261) 

752 

770 

841 

874 

896 

916 

939 

$  197,001  $  200,524  $  198,058  $  196,344  $  193,764  $  194,606  $  195,020  $  195,207  

(23,461) 

(23,800) 

(22,537) 

(22,326) 

(22,326) 

(22,841) 

(23,868) 

(22,767)  

Tangible common shareholders’ equity  

$  173,540  $  176,724  $  175,521  $  174,018  $  171,438  $  171,765  $  171,152  $  172,440 

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 

$  264,810  $  268,387  $  271,408  $  267,010  $  265,325  $  262,158  $  264,216  $  266,224 

(68,951) 

(1,661) 

713 

(68,951) 

(68,951) 

(68,951) 

(68,951) 

(68,951) 

(68,951) 

(68,951) 

(1,690) 

(1,718) 

(1,747) 

(1,774) 

(1,908) 

(2,043) 

(2,177) 

734 

756 

773 

858 

878 

900 

920 

$  194,911  $  198,480  $  201,495  $  197,085  $  195,458  $  192,177  $  194,122  $  196,016  

(23,401) 

(23,606) 

(24,689) 

(22,326) 

(22,326) 

(22,326) 

(23,181) 

(24,672)  

Tangible common shareholders’ equity  

$  171,510  $  174,874  $  176,806  $  174,759  $  173,132  $  169,851  $  170,941  $  171,344 

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

Assets 

Goodwill 

Intangible assets (excluding MSRs) 

Related deferred tax liabilities 

Tangible assets  

$ 2,434,079  $ 2,426,330  $2,395,892  $ 2,377,164  $ 2,354,507  $2,338,833  $ 2,291,670  $ 2,328,478 

(68,951) 

(1,661) 

713 

(68,951) 

(68,951) 

(68,951) 

(68,951) 

(68,951) 

(68,951) 

(68,951) 

(1,690) 

(1,718) 

(1,747) 

(1,774) 

(1,908) 

(2,043) 

(2,177) 

734 

756 

773 

858 

878 

900 

920 

$ 2,364,180  $ 2,356,423  $2,325,979  $ 2,307,239  $ 2,284,640  $2,268,852  $ 2,221,576  $ 2,258,270 

(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 48. 

Bank of America 2019  101 
Bank of America 2019  101

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 

102 
103 

103 

104 
104 
105 

(Dollars in millions) 

Consumer 

Residential mortgage 
Home equity 
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 

2019 

2018 

December 31 
2017 

2016 

2015 

$ 

236,169 
40,208 
97,608 
— 
90,998 
192 
465,175 
594 
465,769 

$ 

208,557 
48,286 
98,338 
— 
91,166 
202 
446,549 
682 
447,231 

$  203,811 
57,744 
96,285 
— 
96,342 
166 
454,348 
928 
455,276 

$ 

191,797 
66,443 
92,278 
9,214 
95,962 
626 
456,320 
1,051 
457,371 

$ 

187,911 
75,948 
89,602 
9,975 
90,149 
713 
454,298 
1,871 
456,169 

U.S. small business commercial (5) 

U.S. commercial 
Non-U.S. commercial 
Commercial real estate (4) 
Commercial lease financing 

252,771 
91,549 
57,199 
21,352 
422,871 
12,876 
435,747 
5,067 
440,814 
— 
$  983,426  $  946,895  $  936,749  $  906,683  $  896,983 
(1)   Includes primarily auto and specialty lending loans and leases of $50.4 billion, $50.1 billion, $52.4 billion, $50.7 billion and $43.9 billion, U.S. securities-based lending loans of $36.7 billion, $37.0 
billion, $39.8 billion, $40.1 billion and $39.8 billion and non-U.S. consumer loans of $2.8 billion, $2.9 billion, $3.0 billion, $3.0 billion and $3.9 billion at December 31, 2019, 2018, 2017, 2016 
and 2015, respectively. 

270,372 
89,397 
57,355 
22,375 
439,499 
12,993 
452,492 
6,034 
458,526 
(9,214) 

299,277 
98,776 
60,845 
22,534 
481,432 
14,565 
495,997 
3,667 
499,664 
— 

284,836 
97,792 
58,298 
22,116 
463,042 
13,649 
476,691 
4,782 
481,473 
— 

307,048 
104,966 
62,689 
19,880 
494,583 
15,333 
509,916 
7,741 
517,657 
— 

Total commercial loans excluding loans accounted for under th

Commercial loans accounted for under the fair value option (3) 

Less: Loans of business held for sale (6) 

Total loans and leases 

e fair value option 

Total commercial 

(2)   Substantially all of other consumer at December 31, 2019, 2018 and 2017 is consumer overdrafts. Other consumer at December 31, 2016 and 2015 also includes consumer finance loans of $465 

million and $564 million, respectively. 

(3)   Consumer loans accounted for under the fair value option include residential mortgage loans of $257 million, $336 million, $567 million, $710 million and $1.6 billion, and home equity loans of 
$337 million, $346 million, $361 million, $341 million and $250 million at December 31, 2019, 2018, 2017, 2016 and 2015, respectively. Commercial loans accounted for under the fair value 
option include U.S. commercial loans of $4.7 billion, $2.5 billion, $2.6 billion, $2.9 billion and $2.3 billion, and non-U.S. commercial loans of $3.1 billion, $1.1 billion, $2.2 billion, $3.1 billion and 
$2.8 billion at December 31, 2019, 2018, 2017, 2016 and 2015, respectively. 
Includes U.S. commercial real estate loans of $59.0 billion, $56.6 billion, $54.8 billion, $54.3 billion and $53.6 billion, and non-U.S. commercial real estate loans of $3.7 billion, $4.2 billion, $3.5 
billion, $3.1 billion and $3.5 billion at December 31, 2019, 2018, 2017, 2016 and 2015, respectively. 
Includes card-related products. 

(4) 

(5) 

(6)  Represents non-U.S. credit card loans, which were included in assets of business held for sale on the Consolidated Balance Sheet. 

102 102

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 

2019 

2018 

December 31 
2017 

2016 

2015 

$ 

1,470  $ 

536 
47 
— 
2,053 

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 

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

867 
158 
93 
12 
1,130 
82 
1,212 
9,377 
459 
$ 
9,836 
(1)   Balances exclude foreclosed properties insured by certain government-guaranteed loans, principally FHA-insured loans, that entered foreclosure of $260 million, $488 million, $801 million, $1.2 

Total commercial (3)  
Total nonperforming loans and leases 

794 
80 
156 
18 
1,048 
54 
1,102 
4,944 
300 

1,256 
279 
72 
36 
1,643 
60 
1,703 
7,707 
377 

814 
299 
112 
24 
1,249 
55 
1,304 
6,470 
288 

1,094 
43 
280 
32 
1,449 
50 
1,499 
3,552 
285 

Total nonperforming loans, leases and foreclosed properties 

U.S. small business commercial  

Foreclosed properties 

6,758  $ 

8,084  $ 

5,244  $ 

3,837  $ 

billion and $1.4 billion at December 31, 2019, 2018, 2017, 2016 and 2015, respectively. 

(2)   In 2019, $422 million in interest income was estimated to be contractually due on $2.1 billion of consumer loans and leases classified as nonperforming at December 31, 2019, as presented in 
the table above, plus $5.5 billion of TDRs classified as performing at December 31, 2019. Approximately $297 million of the estimated $422 million in contractual interest was received and included 
in interest income for 2019. 

(3)   In 2019, $133 million in interest income was estimated to be contractually due on $1.5 billion of commercial loans and leases classified as nonperforming at December 31, 2019, as presented in 
the table above, plus $1.3 billion of TDRs classified as performing at December 31, 2019. Approximately $88 million of the estimated $133 million in contractual interest was received and included 
in interest income for 2019. 

Table III  Accruing Loans and Leases Past Due 90 Days or More (1) 

(Dollars in millions) 

Consumer 

Residential mortgage (2) 
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  

2019 

2018 

December 31 
2017 

2016 

2015 

$ 

1,088  $ 
1,042 
— 
33 
— 
2,163 

106 
8 
19 
20 
153 
97 
250 

1,884  $ 

3,230  $ 

4,793  $ 

994 
— 
38 
—
2,916 

197 
—
4
29 
230 
84 
314 

900 
—
40 
— 
4,170 

144 
3
4
19 
170 
75 
245 

782 
66
34 
4 
5,679 

106 
5
7
19 
137 
71 
208 

$ 

2,413  $ 

3,230  $ 

4,415  $ 

5,887  $ 

7,150 
789 
76 
39 
3 
8,057 

113 
1 
3 
15 
132 
61 
193 
8,250 

(1)  Our policy is to classify consumer real estate-secured loans as nonperforming at 90 days past due, except the fully-insured loan portfolio and loans accounted for under the fair value option. 
(2)  Balances are fully-insured loans. 

Bank of America 2019  103
Bank of America 2019  103 

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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. 

Due in One 
Year or Less 

$ 

$ 

76,523 
13,683 
47,828 
138,034 

28% 

December 31, 2019 

Due After One 
Year Through 
Five Years 

Due After 
Five Years 

$ 

$ 

$ 

$ 

200,298 
39,259 
56,072 
295,629 

59% 

21,526 
274,103 
295,629 

$ 

$ 

$ 

$ 

50,216 
6,023 
7,875 
64,114 

$ 

$ 

Total 

327,037 
58,965 
111,775 
497,777 

13% 

100% 

31,383 
32,731 
64,114 

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 
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 
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  

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  

2019 

2018 

2017 

2016 

2015 

$ 

9,601  $  10,393  $  11,237  $  12,234  $  14,419 

(93) 
(429) 
(3,535) 
— 
(518) 
(249) 
(4,824) 
(650) 
(115) 
(31) 
(26) 
(822) 
(5,646) 

(207) 
(483) 
(3,345) 
— 
(495) 
(197) 
(4,727) 
(575) 
(82) 
(10) 
(8) 
(675) 
(5,402) 

(188) 
(582) 
(2,968) 
(103) 
(491) 
(212) 
(4,544) 
(589) 
(446) 
(24) 
(16) 
(1,075) 
(5,619) 

(403) 
(752) 
(2,691) 
(238) 
(392) 
(232) 
(4,708) 
(567) 
(133) 
(10) 
(30) 
(740) 
(5,448) 

(866) 
(975) 
(2,738) 
(275) 
(383) 
(224) 
(5,461) 
(536) 
(59) 
(30) 
(19) 
(644) 
(6,105) 

140 
787 
587 
— 
309 
15 
1,838 
122 
31 
2 
5 
160 
1,998 
(3,648) 
3,574 
(111) 
9,416 
— 
9,416 
797 
16 
— 
813 

393 
339 
424 
87 
271 
31 
1,545 
172 
5 
35 
10 
222 
1,767 
(4,338) 
3,043  
(890)  
12,234 
— 
12,234 
528 
118 
— 
646 
10,229  $  10,398  $  11,170  $  11,999  $  12,880 

272 
347 
422 
63 
258 
27 
1,389 
175 
13 
41 
9
238 
1,627 
(3,821) 
3,581 
(514) 
11,480 
(243) 
11,237 
646 
16
100 
762 

288 
369 
455 
28 
277 
49 
1,466 
142 
6
15 
11 
174 
1,640 
(3,979) 
3,381 
(246) 
10,393 
— 
10,393 
762 
15 
—
777 

179 
485 
508 
— 
300 
15 
1,487 
120 
14 
9 
9
152 
1,639 
(3,763) 
3,262 
(291) 
9,601 
— 
9,601 
777 
20 
— 
797 

$ 

(1)  Represents amounts 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 $320 million, $287 million, $258 million, $253 million and $282 million in 2019, 2018, 2017, 2016 and 2015, respectively. 
Includes U.S. small business commercial recoveries of $48 million, $47 million, $43 million, $45 million and $57 million in 2019, 2018, 2017, 2016 and 2015, respectively. 

(3) 

(4)   Primarily represents write-offs of PCI loans, 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. 

104 104

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table V  Allowance for Credit Losses (continued) 

(Dollars in millions)  

Loan and allowance ratios (6): 

Loans and leases outstanding at December 31 (7)  
Allowance for loan and lease losses as a percentage of total loans and leases outstanding 

at December 31 (7) 

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

leases at December 31  

Ratio of the allowance for loan and lease losses at December 31 to net charge-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 (10) 

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 (10) 

2019 

2018 

2017 

2016 

2015 

$  975,091 

$ 942,546 

$ 931,039 

$ 908,812 

$ 890,045 

0.97% 

1.02% 

1.12% 

1.26% 

1.37% 

0.98 

0.96 

1.08 

0.97 

1.18 

1.05 

1.36 

1.16 

1.63 

1.11 

$  951,583 

$ 927,531 

$ 911,988 

$ 892,255 

$ 869,065 

0.38% 

0.41% 

0.44% 

0.43% 

0.50% 

265 

2.58 

194 

2.55 

161 

2.61 

149 

3.00 

130 

2.82 

$ 

4,151 

$ 

4,031 

$ 

3,971 

$ 

3,951 

$ 

4,518 

148% 

113% 

99% 

98% 

82% 

(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 $8.3 billion, $4.3 billion, $5.7 billion, $7.1 billion and $6.9 billion at December 31, 
2019, 2018, 2017, 2016 and 2015, respectively. Average loans accounted for under the fair value option were $6.8 billion, $5.5 billion, $6.7 billion, $8.2 billion and $7.7 billion in 2019, 2018, 
2017, 2016 and 2015, respectively. 

(8)   Excludes consumer loans accounted for under the fair value option of $594 million, $682 million, $928 million, $1.1 billion and $1.9 billion at December 31, 2019, 2018, 2017, 2016 and 2015, 

respectively. 

(9)   Excludes commercial loans accounted for under the fair value option of $7.7 billion, $3.7 billion, $4.8 billion, $6.0 billion and $5.1 billion at December 31, 2019, 2018, 2017, 2016 and 2015, 

respectively. 

(10)  Primarily includes amounts allocated to credit card and unsecured consumer lending portfolios in Consumer Banking and, in 2016 and 2015,  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 
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 

2019 

2018 

December 31 
2017 

2016 

2015 

Amount 

Percent 
of Total 

Amount 

Percent 
of Total 

Amount 

Percent 
of Total 

Amount 

Percent 
of Total 

Amount 

Percent 
of Total 

$ 

325 
221 
3,710 
—
234 
52 
4,542 
3,015 
658 
1,042 
159 
4,874 

3.45%  $ 
2.35 
39.39 
— 
2.49 
0.55 
48.23 
32.02 
6.99 
11.07 
1.69 
51.77 

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 
51 
0.30 
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% 
19.73 
23.93 
2.24 
1.82 
0.38 
60.36 
24.23 
6.17 
7.90 
1.34 
39.64 

9,416 

100.00% 

9,601 

100.00% 

10,393 

100.00% 

11,480 

100.00% 

12,234 

100.00% 

Less: Allowance included in assets of 

business held for sale (2) 

Allowance for loan and lease losses 
Reserve for unfunded lending commitments 

Allowance for credit losses 

— 

9,416 
813 
$ 10,229 

— 

9,601 
797 
$ 10,398 

— 

10,393 
777 
$ 11,170 

(243) 

11,237 
762 
$ 11,999 

— 

12,234 
646 
$ 12,880 

(1) 

Includes allowance for loan and lease losses for U.S. small business commercial loans of $523 million, $474 million, $439 million, $416 million and $507 million at December 31, 2019, 2018, 
2017, 2016 and 2015, respectively. 

(2)  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 2019  105 
Bank of America 2019  105

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 – Net Interest Income and 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 – Leases 
Note 10 – Deposits 
Note 11 – Federal Funds Sold or Purchased, Securities Financing Agreements, Short-term Borrowings  

and Restricted Cash 

Note 12 – Long-term Debt 
Note 13 – Commitments and Contingencies 
Note 14 – Shareholders’ Equity 
Note 15 – Accumulated Other Comprehensive Income (Loss) 
Note 16 – Earnings Per Common Share 
Note 17 – Regulatory Requirements and Restrictions 
Note 18 – Employee Benefit Plans 
Note 19 – Stock-based Compensation Plans 
Note 20 – Income Taxes 
Note 21 – Fair Value Measurements 
Note 22 – Fair Value Option 
Note 23 – Fair Value of Financial Instruments 
Note 24 – Business Segment Information 
Note 25 – Parent Company Information 
Note 26 – Performance by Geographical Area 
Glossary 
Acronyms 

Page 
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110  
111  
112  
113  
114  
122  
123  
130  
133  
141  
142  
146  
146  
147  

147  
149  
150  
155  
157  
158  
158  
160  
164  
165  
166  
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177  
177  
180  
182  
183  
184  

106 106

Bank of America 2019 

Bank of America 2019

       
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, 2019 
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,  2019,  the 
Corporation’s internal control over financial reporting is effective. 
The  Corporation’s  internal  control  over  financial  reporting 
as  of  December  31,  2019  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, 2019. 

Brian T. Moynihan 
Chairman, Chief Executive Officer and President 

Paul M. Donofrio 
Chief Financial Officer 

Bank of America 2019  107 
Bank of America 2019  107

   
 
 
 
 
 
 
 
 
 
 
 
 
 
             
 
 
 
 
 
 
 
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: 

the 

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  (the 
"Corporation") as of December 31, 2019 and December 31, 2018, 
income, 
related  consolidated  statements  of 
and 
comprehensive income, changes in shareholders’ equity and cash 
flows for each of the three years in the period ended December 
31, 2019, 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,  2019,  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,  2019  and 
December 31, 2018, and the results of its operations and its cash 
flows for each of the three years in the period ended December 
31,  2019  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, 2019, 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. 

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 

the 

Our audits of the consolidated financial statements included 
performing  procedures 
risks  of  material 
to  assess 
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. 

required 

that  were  communicated  or 

Critical Audit Matters 
The critical audit matters communicated below are matters arising 
from  the  current  period  audit  of  the  consolidated  financial 
statements 
to  be 
communicated  to  the  audit  committee  and  that  (i)  relate  to 
accounts  or  disclosures  that  are  material  to  the  consolidated 
financial statements and (ii) involved our especially challenging, 
subjective, or complex judgments. The communication of critical 
audit  matters  does  not  alter  in  any  way  our  opinion  on  the 
consolidated financial statements, taken as a whole, and we are 
not, by communicating the critical audit matters below, providing 
separate opinions on the critical audit matters or on the accounts 
or disclosures to which they relate. 

Allowance for Loan and Lease Losses 
As  described  in  Notes  1  and  6  to  the  consolidated  financial 
statements, the allowance for loan and lease losses represents 
management’s estimate of probable incurred credit losses in the 
Corporation’s loan and lease portfolio. As of December 31, 2019, 
the allowance for loan and lease losses was $9.4 billion on total 
loans  and  leases  of  $975.1  billion,  which  excludes  loans 
accounted for under the fair value option. The allowance for loan 
and  lease  losses  includes  both  quantitative  and  qualitative 
components. The allowance for certain consumer loan portfolios 
considers a variety of factors including 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. The allowance for 

108 

Bank of America 2019 

Bank of America 2019

108

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
certain commercial loans is calculated using loss rates delineated 
by  risk  rating  and  product  type.  In  addition,  the  qualitative 
component has a higher degree of management subjectivity, and 
includes factors such as concentrations, economic conditions and 
other considerations. 

The  principal  considerations  for  our  determination  that 
performing procedures relating to the allowance for loan and lease 
losses  is  a  critical  audit  matter  are  (i)  there  was  significant 
judgment  and  estimation  by  management  in  determining  the 
allowance for loan and lease losses, which in turn led to a high 
degree of auditor judgment, subjectivity and effort in performing 
procedures and in evaluating audit evidence obtained relating to 
the allowance for loan and lease losses, including the qualitative 
component, and  (ii)  the  audit  effort  involved  professionals  with 
specialized skill and knowledge to assist in evaluating certain audit 
evidence. 

Addressing  the  matter  involved  performing  procedures  and 
evaluating audit evidence in connection with forming our overall 
opinion  on  the  consolidated  financial  statements.  These 
procedures included testing the effectiveness of controls relating 
to the allowance for loan and lease losses. These procedures also 
included,  among  others,  testing  management’s  process  for 
estimating  the  allowance  for  loan  and  lease  losses,  including 
evaluating the appropriateness of the loss forecast models and 
methodology, testing the completeness and accuracy of certain 
data  used  in  the  allowance  for  loan  and  lease  losses,  and 
evaluating  the  reasonableness  of  significant  assumptions  and 
judgments  used  by  management  to  estimate  the  qualitative 
component of the allowance for loan and lease losses including 
those judgments related to the impact of concentrations, economic 
conditions and other considerations. The procedures also included 
the  involvement  of  professionals  with  specialized  skill  and 
knowledge to assist in evaluating the reasonableness of certain 
forecast  models  and  methodologies,  evaluating  the 
loss 
reasonableness  of  risk  ratings  used  in  the  allowance  for 
commercial loans, and evaluating the reasonableness of certain 
judgments  used  by  management  in  estimating  the  qualitative 
component of the allowance for loan and lease losses. 

Valuation of Certain Level 3 Financial Instruments 
As  described  in  Notes  1  and  21  to  the  consolidated  financial 
statements, the Corporation carries certain financial instruments 
at fair value, which includes $10.3 billion of assets and $5.9 billion 
of  liabilities  classified  as  Level  3  fair  value  measurements  for 
which  the  determination  of  fair  value  requires  significant 

management judgment or estimation. The Corporation determines 
the  fair  value  of  certain  Level  3  financial  instruments  using 
quantitative models that utilize multiple significant unobservable 
inputs,  including  long-dated  volatility  and forward  price,  as 
applicable. As disclosed by management, estimation risk is greater 
for  financial  instruments  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 are used in determining fair values. 

The  principal  considerations  for  our  determination  that 
performing procedures relating to the valuation of certain Level 3 
financial instruments is a critical audit matter are the significant 
judgment and estimation used by management to determine the 
fair value of these financial instruments. This in turn led to a high 
degree of auditor judgment and effort in performing procedures, 
including the involvement of professionals with specialized skill 
and knowledge to assist in evaluating certain audit evidence. 

Addressing  the  matter  involved  performing  procedures  and 
evaluating audit evidence in connection with forming our overall 
opinion  on  the  consolidated  financial  statements.  These 
procedures included testing the effectiveness of controls relating 
to the valuation of financial instruments, including controls related 
to valuation models, significant unobservable inputs, and data.  
These procedures also included, among others, the involvement 
of professionals with specialized skill and knowledge to assist in 
developing an independent estimate of fair value for a sample of 
these  certain 
instruments  and  comparison  of 
management’s estimate to the independently developed estimate 
of fair value. Developing the independent estimate involved testing 
the completeness and accuracy of data provided by management 
and  evaluating 
reasonableness  of  management’s 
assumptions used to develop the significant unobservable inputs. 

financial 

the 

Charlotte, North Carolina 
February 19, 2020 

We have served as the Corporation’s auditor since 1958. 

Bank of America 2019  109 
Bank of America 2019  109

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Bank of America Corporation and Subsidiaries 

Consolidated Statement of Income 

(In millions, except per share information) 

2019 

2018 

2017 

Net interest income 
Interest income 
Interest expense 

Net interest income 

Noninterest income 

Fees and commissions 
Market making and similar activities 
Other income 

Total noninterest income 
Total revenue, net of interest expense 

Provision for credit losses 

Noninterest expense 

Compensation and benefits 
Occupancy and equipment 
Information processing and communications 
Product delivery and transaction related 
Marketing 
Professional fees 
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 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 

$ 

$ 

71,236 
22,345 
48,891 

$ 

66,769 
18,607 
48,162 

57,579 
12,340 
45,239 

33,015 
9,034 
304 
42,353 
91,244 

33,078 
9,008 
772 
42,858 
91,020 

33,341 
7,102 
1,444 
41,887 
87,126 

3,590 

3,282 

3,396 

31,977 
6,588 
4,646 
2,762 
1,934 
1,597 
5,396 
54,900 
32,754 
5,324 
27,430 
1,432 
25,998 

2.77 
2.75 
9,390.5 
9,442.9 

$ 

$ 

$ 

31,880 
6,380 
4,555 
2,857 
1,674 
1,699 
4,109 
53,154 
34,584 
6,437 
28,147 
1,451 
26,696 

2.64 
2.61 
10,096.5 
10,236.9 

$ 

$ 

$ 

31,931 
6,264 
4,530 
3,041 
1,746 
1,888 
5,117 
54,517 
29,213 
10,981 
18,232 
1,614 
16,618 

1.63 
1.56 
10,195.6 
10,778.4 

$ 

$ 

$ 

2019 

2018 

2017 

$ 

27,430  $ 

28,147  $ 

18,232 

5,875 
(963) 
616 
136 
(86) 
5,578 

$ 

33,008  $ 

(3,953) 
749 
(53) 
(405) 
(254) 
(3,916) 
24,231  $ 

61 
(293) 
64 
288 
86 
206 
18,438 

See accompanying Notes to Consolidated Financial Statements. 

110 110

Bank of America 2019 

Bank of America 2019

       
 
 
 
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 $50,364 and $56,399 measured at fair value) 

Trading account assets (includes $90,946 and $119,363 pledged as collateral) 
Derivative assets 
Debt securities: 

Carried at fair value 
Held-to-maturity, at cost (fair value – $219,821 and $200,435) 

Total debt securities 

Loans and leases (includes $8,335 and $4,349 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 $3,709 and $2,942 measured at fair value) 
Customer and other receivables 
Other assets (includes $15,518 and $19,739 measured at fair value) 

Total assets 

Liabilities 
Deposits in U.S. offices: 
Noninterest-bearing 
Interest-bearing (includes $508 and $492 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 $16,008 and $28,875 measured at fair value) 

Trading account liabilities 
Derivative liabilities 
Short-term borrowings (includes $3,941 and $1,648 measured at fair value) 
Accrued expenses and other liabilities (includes $15,434 and $20,075 measured at fair value

 and $813 and $797 of reserve for unfunded lending commitments) 

Long-term debt (includes $34,975 and $27,689 measured at fair value) 

Total liabilities 

Commitments and contingencies (Note 7 – Securitizations and Other Variable Interest Entities 

and Note 13 – Commitments and Contingencies) 

Shareholders’ equity 
Preferred stock, $0.01 par value; authorized – 100,000,000 shares; issued and outstanding – 3,887,440 and 3,843,140 shares 
Common stock and additional paid-in capital, $0.01 par value; authorized – 12,800,000,000 shares;

 issued and outstanding – 8,836,148,954 and 9,669,286,370 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 t

he 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 $8,717 and $10,943 of non-recourse debt) 

All other liabilities (includes $19 and $27 of non-recourse liabilities) 

Total liabilities of consolidated variable interest entities 

See accompanying Notes to Consolidated Financial Statements. 

December 31 

2019 

2018 

$ 

30,152  $ 

131,408 
161,560 
7,107 

274,597 

229,826 
40,485 

29,063 
148,341 
177,404 
7,494 

261,131 

214,348 
43,725 

256,467 
215,730 
472,197 
983,426 
(9,416) 
974,010 
10,561 
68,951 
9,158 
55,937 
129,690 

238,101 
203,652 
441,753 
946,895 
(9,601) 
937,294 
9,906 
68,951 
10,367 
65,814 
116,320 
2,434,079  $  2,354,507 

403,305  $ 
940,731 

412,587 
891,636 

13,719 
77,048 
1,434,803 

14,060 
63,193 
1,381,476 

165,109 

186,988 

83,270 
38,229 
24,204 

68,220 
37,891 
20,189 

182,798 

240,856 
2,169,269 

165,026 

229,392 
2,089,182 

23,401 

22,326 

91,723 

118,896 

156,319 
(6,633) 
264,810 

136,314 
(12,211) 
265,325 
2,434,079  $  2,354,507 

5,811 
38,837 
(807) 

38,030 
540 
44,381 

$ 

$ 

2,175 

$ 

8,718 

22 

5,798 
43,850 

(912) 
42,938 
337 
49,073 

742 

10,944 

30 

10,915 

$ 

11,716 

Bank of America 2019  111 
Bank of America 2019  111

$ 

$ 

$ 

$ 

$ 

$ 

$ 

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
Bank of America Corporation and Subsidiaries 

Consolidated Statement of Changes in Shareholders’ Equity 

(In millions) 

Balance, December 31, 2016 
Net income 
Net change in debt 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 

Common stock issued in connection with exercise of warrants and 

exchange of preferred stock 

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 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 
Cumulative adjustment for adoption of lease accounting standard 
Net income 
Net change in debt 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 

Common Stock and 
Additional Paid-in Capital 

Shares 

Amount 

Retained 
Earnings 

Accumulated 
Other 
Comprehensive 
Income (Loss) 

Total 
Shareholders’ 
Equity 

$ 

25,220 

10,052.6  $ 

147,038  $ 

101,225  $ 

(7,288)  $ 

18,232 

(4,027) 
(1,578) 

61 
(293) 
64 
288 
86 

(2,897) 

700.0 

2,933 

(36) 

$ 

22,323 

43.3 
(508.6) 
10,287.3  $ 

932 
(12,814) 
138,089  $ 

113,816  $ 
(32) 

(7,082)  $ 
57 

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 
165 
27,430 
5,875 
(963) 
616 
136 
(86) 

(6,146) 
(1,432) 
3,643 
(2,568) 
959 
(28,144) 
264,810 

(1,270) 

(3,953) 
749 
(53) 
(405) 
(254) 

1,270 

28,147 

(5,424) 
(1,451) 

(12) 

136,314  $ 
165 
27,430 

(12,211)  $ 

5,875 
(963) 
616 
136 
(86) 

(6,146) 
(1,432) 

(12) 

156,319  $ 

(6,633)  $ 

4,515 
(4,512) 

58.2 
(676.2) 

$ 

22,326 

9,669.3  $ 

901 
(20,094) 
118,896  $ 

Issuance of preferred stock 
Redemption of preferred stock 
Common stock issued under employee plans, net, and other 
Common stock repurchased 
Balance, December 31, 2019 

3,643 
(2,568) 

123.3 
(956.5) 

$ 

23,401 

8,836.1  $ 

971 
(28,144) 
91,723  $ 

See accompanying Notes to Consolidated Financial Statements. 

112 112

Bank of America 2019 

Bank of America 2019

       
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 amortization 
Net amortization of premium/discount on debt securities 
Deferred income taxes 
Stock-based compensation 
Impairment of equity method investment 

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 assets/liabilities 
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 

2019 

2018 

2017 

$ 

27,430  $ 

28,147  $ 

18,232 

3,590 
(217) 
1,729 
2,066 
2,435 
1,974 
2,072 

3,282 
(154) 
2,063 
1,824 
3,041 
1,729 
— 

3,396 
(255) 
2,103 
2,251 
8,175 
1,649 
— 

(28,874) 

(28,071) 

(43,506) 

30,191 

28,972 

40,548 

7,920 
(11,113) 
16,363 
6,211 
61,777 

387 
(13,466) 

52,006 
79,114 
(152,782) 

34,770 
(37,115) 

12,201 

(5,963) 
(46,808) 
(2,974) 
(80,630) 

53,327 
(21,879) 
4,004 

52,420 
(50,794) 

(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) 

3,643 
(2,568) 
(28,144) 
(5,934) 
(698) 
3,377 
(368) 
(15,844) 
177,404 
161,560  $ 

4,515 
(4,512) 
(20,094) 
(6,895) 
(651) 
53,118 
(1,200) 
19,970 
157,434 
177,404  $ 

(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 

22,196  $ 

19,087  $ 

4,359 

2,470 

12,852 
3,235 

$ 

$ 

See accompanying Notes to Consolidated Financial Statements. 

Bank of America 2019  113 
Bank of America 2019  113

   
 
 
 
 
Bank of America Corporation and Subsidiaries 
Notes to Consolidated Financial Statements 

Adoption of the standards did not have a significant effect on the 
Corporation’s regulatory capital measures. 

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 requires management to make estimates 
and assumptions that affect reported amounts and disclosures. 
Actual  results  could  materially  differ  from  those  estimates  and 
assumptions. Certain prior-period amounts have been reclassified 
to conform to current-period presentation. 

In the Consolidated Statement of Income, amounts related to 
certain asset and liability management (ALM) activities have been 
reclassified  from  other  income  to  market  making  and  similar 
activities,  which  was  previously  referred  to  as  trading  account 
income. All prior periods presented reflect this change, which has 
no impact on the Corporation's total noninterest income or net 
income, and  has  no  impact  on  business  segment  results.  The 
amounts included in market making and similar activities related 
to this change in presentation are increases of $930 million, $1.1 
billion and $332 million for 2019, 2018 and 2017, respectively. 

New Accounting Standards 

Lease Accounting 
On January 1, 2019, the Corporation adopted the new accounting 
standards that require lessees to recognize operating leases on 
the 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 are required prospectively 
and are included in Note 9 – Leases. The Corporation elected to 
retain  prior  determinations  of  whether  an  existing  contract 
contains  a  lease  and  how  the  lease  should  be  classified.  The 
Corporation  elected  to  recognize  leases  existing  on  January  1, 
2019  through  a  cumulative-effect  adjustment  which  increased 
retained  earnings  by  $165  million, with  no  adjustment  to  prior 
periods  presented.  Upon  adoption,  the  Corporation  also 
recognized right-of-use assets and lease liabilities of $9.7 billion. 

Accounting for Financial Instruments -- Credit Losses 
On January 1, 2020, the Corporation adopted the new accounting 
standard that requires the measurement of the allowance for credit 
losses to be based on management’s best estimate of lifetime 
expected  credit  losses  inherent  in  the  Corporation’s  relevant 
financial assets. The Corporation’s lifetime expected credit losses 
are determined using macroeconomic forecast assumptions and 
management judgments applicable to and through the expected 
life of the loan portfolios, and are net of expected recoveries on 
loans that were previously charged off. The standard also expands 
credit quality disclosures beginning in the first quarter of 2020. 
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 or the ultimate losses in those portfolios. 
Upon adoption of the standard on January 1, 2020, the Corporation 
recorded a $3.3 billion, or 32 percent, increase to the allowance 
for  credit  losses.  After  adjusting  for  deferred  taxes  and  other 
adoption effects, a $2.4 billion decrease was recorded in retained 
earnings through a cumulative-effect adjustment. 

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  legally  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 market making and similar activities 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, 2019 and 2018, the fair value of this collateral was $693.0 
billion  and  $599.0  billion, of  which  $593.8  billion  and  $508.6 

114 114

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 
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 market making and 
similar activities. 

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 
for  which  the 
flow  methodologies  or  similar  techniques 
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 market making and similar 
activities. 

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 market making and similar activities. 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  market  making  and  similar  activities  and  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. The 
Corporation also uses cash flow hedges to hedge the price risk 
associated with deferred compensation. Changes in the fair value 
of  derivatives  used  in  cash  flow  hedges  are  recorded  in 
accumulated  other  comprehensive 
(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 

income 

Bank of America 2019  115 
Bank of America 2019  115

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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  market  making  and  similar 
activities. 

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 market making and similar activities. Substantially all 
other debt securities purchased are used in the Corporation’s 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 
recorded at cost less impairment, if any, plus or minus qualifying 
observable price changes. These securities are reported in other 
assets. 

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 interest reported in interest income and changes in fair value 
reported in market making and similar activities or 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 
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  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. 

Leases 
The Corporation provides equipment financing to its customers 
through a variety of lessor arrangements. Direct financing leases 
and  sales-type  leases  are  carried  at  the  aggregate  of  lease 
payments  receivable  plus  the  estimated  residual  value  of  the 
leased  property  less  unearned  income,  which  is  accreted  to 
interest  income  over  the  lease  terms  using  methods  that 
approximate  the  interest  method.  Operating  lease  income  is 
recognized  on  a  straight-line  basis.  The  Corporation's  lease 
arrangements generally do not contain non-lease components. 

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 
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. 

116 116

Bank of America 2019 

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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 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 
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 

in  a  troubled  debt  restructuring 

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 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 

Bank of America 2019  117 
Bank of America 2019  117

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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. 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. 

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 and LHFS 
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 
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 

118 118

Bank of America 2019 

Bank of America 2019

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 the Corporation intends to sell 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 
with interest recorded in interest income and changes in fair value 
recorded in other income. 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. 

Lessee Arrangements 
Substantially  all  of  the  Corporation’s  lessee  arrangements  are 
operating  leases.  Under  these  arrangements,  the  Corporation 
records  right-of-use  assets  and  lease  liabilities  at  lease 
commencement. Right-of-use assets are reported in other assets 
on  the  Consolidated  Balance  Sheet,  and  the  related  lease 
liabilities are reported in accrued expenses and other liabilities. 
All leases are recorded on the Consolidated Balance Sheet except 
leases  with  an  initial  term  less  than  12  months  for  which  the 
Corporation made the short-term lease election. Lease expense 
is recognized on a straight-line basis over the lease term and is 
recorded in occupancy and equipment expense in the Consolidated 
Statement of Income. 

The  Corporation  made  an  accounting  policy  election  not  to 
separate lease and non-lease components of a contract that is or 
contains a lease for its real estate and equipment leases. As such, 
lease payments represent payments on both lease and non-lease 
components.  At  lease  commencement,  lease  liabilities  are 
recognized  based  on  the  present  value  of  the  remaining  lease 
payments  and  discounted  using  the  Corporation’s  incremental 
borrowing rate. Right-of-use assets initially equal the lease liability, 
adjusted 
lease 
commencement and for any lease incentives. 

lease  payments  made  prior 

for  any 

to 

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 
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. Under applicable accounting standards, 
fair value measurements are categorized into one of three levels 

Bank of America 2019  119 
Bank of America 2019  119

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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. 

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 
transactions. 
processing  and 
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. 

120 120

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 
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 
clients with transactions related to mergers and acquisitions and 
financial restructurings. Revenue varies depending on the size of 
the transaction and scope of services performed and is generally 
contingent on successful completion 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 client. 

Other Revenue Measurement and Recognition Policies 
The Corporation did not disclose the value of any open performance 
obligations at December 31, 2019, 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. 

Bank of America 2019  121 
Bank of America 2019  121

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTE 2 Net Interest Income and Noninterest Income 
The table below presents the Corporation’s net interest income and noninterest income disaggregated by revenue source for 2019, 
2018 and 2017. 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 24 – Business Segment Information. 

(Dollars in millions) 

Net interest income 
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 
Fees and commissions 

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 

2019 

2018 

2017 

$ 

$ 

$ 

$ 

43,086 
11,806 
4,843 
5,196 
6,305 
71,236 

7,188 
7,208 
1,249 
6,700 
22,345 
48,891  $ 

$ 

3,834 
1,963 
5,797 

6,588 
1,086 
7,674 

10,241 
3,661 
13,902 

$ 

40,811 
11,724 
3,176 
4,811 
6,247 
66,769 

4,495 
5,839 
1,358 
6,915 
18,607 
48,162  $ 

$ 

3,866 
1,958 
5,824 

6,667 
1,100 
7,767 

10,189 
3,971 
14,160 

36,221 
10,471 
2,390 
4,474 
4,023 
57,579 

1,931 
3,538 
1,204 
5,667 
12,340 
45,239 

3,777 
1,899 
5,676 

6,708 
1,110 
7,818 

9,310 
4,526 
13,836 

Investment banking fees 
Underwriting income 
Syndication fees 
Financial advisory services 

2,821 
1,499 
1,691 
6,011 
33,341 
7,102 
1,444 
41,887 
(1)  Gross interchange fees were $10.0 billion, $9.5 billion and $8.8 billion for 2019, 2018 and 2017, respectively, and are presented net of $6.2 billion, $5.6 billion and $5.1 billion of expenses for 

Total investment banking fees 
Total fees and commissions 
Market making and similar activities 
Other income 

2,722 
1,347 
1,258 
5,327 
33,078 
9,008 
772 
42,858  $ 

2,998 
1,184 
1,460 
5,642 
33,015 
9,034 
304 
42,353  $ 

Total noninterest income 

$ 

rewards and partner payments for the same periods. 

122 122

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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, 2019  and  2018.  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. 

(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/liabilities 

Less: Legally enforceable master netting agreements 
Less: Cash collateral received/paid 

Total derivative assets/liabilities 

Gross Derivative Assets 

Gross Derivative Liabilities 

December 31, 2019 

Trading and 
Other Risk 
Management 
Derivatives 

Qualifying 
Accounting 
Hedges 

Contract/ 
Notional (1) 

Total 

Trading and 
Other Risk 
Management 
Derivatives 

Qualifying 
Accounting 
Hedges 

Total 

$  15,074.4  $ 
3,279.8 
1,767.7 
1,673.6 

162.0  $ 
1.0 
— 
37.4 

9.7  $ 
— 
— 
— 

171.7  $ 
1.0 
— 
37.4 

168.5  $ 
1.0 
32.5 
— 

0.4  $ 
— 
— 
— 

168.9 
1.0 
32.5 
— 

1,657.7 
3,792.7 
274.3 
261.6 

315.0 
125.1 
731.1 
668.6 

42.0 
61.3 
33.2 
37.9 

321.6 
86.6 

300.2 
86.2 

30.3 
35.9 
— 
4.0 

6.5 
0.3 
— 
42.4 

2.1 
1.7 
— 
1.4 

2.7 
0.4 

0.7 
0.1 
— 
— 

— 
— 
— 
— 

— 
— 
— 
— 

— 
— 

31.0 
36.0 
— 
4.0 

6.5 
0.3 
— 
42.4 

2.1 
1.7 
— 
1.4 

2.7 
0.4 

31.7 
38.7 
3.8 
— 

8.1 
1.1 
34.6 
— 

4.4 
0.4 
1.4 
— 

5.6 
1.3 

0.9 
0.3 
— 
— 

— 
— 
— 
— 

— 
— 
— 
— 

— 
— 

5.4 
0.8 
334.3  $ 

— 
— 
10.5  $ 

$ 

$ 

5.4 
0.8 
344.8  $ 
(270.4) 
(33.9) 
40.5 

2.0 
0.4 
335.5  $ 

— 
— 
1.6  $ 

$ 

32.6 
39.0 
3.8 
— 

8.1 
1.1 
34.6 
— 

4.4 
0.4 
1.4 
— 

5.6 
1.3 

2.0 
0.4 
337.1 
(270.4) 
(28.5) 
38.2 

(1)  Represents the total contract/notional amount of derivative assets and liabilities outstanding. 
(2)   The net derivative asset (liability) and notional amount of written credit derivatives for which the Corporation held purchased credit derivatives with identical underlying referenced names were $2.8 

billion and $309.7 billion at December 31, 2019. 

Bank of America 2019  123 
Bank of America 2019  123

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(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/liabilities 

Less: Legally enforceable master netting agreements 
Less: Cash collateral received/paid 

Total derivative assets/liabilities 

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 

Total 

$  15,977.9  $ 
3,656.6 
1,584.9 
1,614.0 

141.0  $ 
4.7 
— 
30.8 

3.2  $ 
— 
— 
— 

144.2  $ 
4.7 
— 
30.8 

138.9  $ 
5.0 
28.6 
— 

2.0  $ 
— 
— 
— 

140.9 
5.0 
28.6 
— 

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 

38.8 
39.8 
— 
4.6 

7.7 
2.1 
— 
36.0 

2.7 
3.2 
— 
1.7 

5.3 
0.4 

4.4 
0.6 
323.8  $ 

$ 

1.4 
0.4 
— 
— 

— 
— 
— 
— 

— 
— 
— 
— 

— 
— 

— 
— 

5.0  $ 

$ 

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 

4.3 
0.6 
313.2  $ 

4.4 
0.6 
328.8  $ 
(252.7) 
(32.4) 
43.7 

2.3 
0.3 
— 
— 

— 
— 
— 
— 

— 
— 
— 
— 

— 
— 

— 
— 

4.6  $ 

$ 

44.5 
39.6 
5.0 
— 

8.4 
0.3 
27.5 
— 

4.5 
0.5 
2.2 
— 

4.9 
1.0 

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 asset (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. 

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, 2019  and  2018  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  11  –  Federal  Funds  Sold  or  Purchased, 
Securities  Financing  Agreements,  Short-term  Borrowings  and 
Restricted Cash. 

124 124

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Offsetting of Derivatives (1) 

(Dollars in billions)  
Interest rate contracts 
Over-the-counter 
Exchange-traded 
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 
Over-the-counter cleared 

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 

Derivative 
Assets 

Derivative 
Liabilities 

Derivative 
Assets 

Derivative  
Liabilities  

December 31, 2019 

December 31, 2018 

$ 

203.1  $ 
0.1 
6.0 

196.6  $ 
0.1 
5.3 

174.2  $ 
—
4.8 

169.4 
— 
4.0 

69.2 
0.5 

21.3 
26.4 

2.8 
0.8 
— 

6.4 
2.5 

302.8 
27.3 
9.0 

73.1 
0.5 

17.8 
22.8 

4.2 
0.8 
0.1 

6.6 
2.2 

298.3 
23.7 
8.1 

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 

Derivative assets/liabilities, after netting 

Over-the-counter 
Exchange-traded 
Over-the-counter cleared 

(259.2) 
(13.5) 
(7.2) 
26.3 
11.6 
37.9 
(8.6) 
Total net derivative assets/liabilities 
29.3 
(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 

(264.4) 
(13.5) 
(7.2) 
32.7 
11.0 
43.7 
(16.3) 
27.4  $ 

(269.3) 
(21.5) 
(8.1) 
31.2 
7.0 
38.2 
(16.1) 
22.1  $ 

(274.7) 
(21.5) 
(8.1) 
34.8 
5.7 
40.5 
(14.6) 
25.9  $ 

Other gross derivative assets/liabilities (2) 

Less: Financial instruments collateral (3) 

Total derivative assets/liabilities 

$ 

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 
in  qualifying  hedge  accounting 
derivatives  designated 
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 

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. 

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. 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 credit default swaps (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). 

Bank of America 2019  125 
Bank of America 2019  125

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Fair Value Hedges 
The table below summarizes information related to fair value hedges for 2019, 2018 and 2017. 

Gains and Losses on Derivatives Designated as Fair Value Hedges 

(Dollars in millions) 
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) 

Total  

2019 

Derivative 
2018 

2017 

2019 

Hedged Item 
2018 

2017 

$ 

$ 

6,113  $ 

119 
(102) 

6,130  $ 

(1,538)  $ 
(1,187) 
(52) 
(2,777)  $ 

(1,537)  $ 
1,811 
(67) 
207  $ 

(6,110)  $ 
(101) 
98 
(6,113)  $ 

1,429  $ 
1,079 
50 
2,558  $ 

1,045 
(1,767) 
35 
(687) 

(1)  Amounts are recorded in interest expense in the Consolidated Statement of Income. 
(2)   In 2019, 2018 and 2017, the derivative amount includes gains (losses) of $73 million, $(116) million and $(365) million in interest expense, $28 million, $(992) million and $2.2 billion in market 
making and similar activities, and $18 million and $(79) million in accumulated OCI, respectively. Line item totals are in the Consolidated Statement of Income and in the Consolidated Balance 
Sheet. 

(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 (2) 

Available-for-sale debt securities (2) 

Carrying Value 

Cumulative 
Fair Value 
Adjustments (1) 

Carrying Value 

Cumulative 
Fair Value 
Adjustments (1) 

$ 

December 31, 2019 
(162,389)  $ 

(8,685) 

$ 

(138,682)  $ 

December 31, 2018 

1,654 

64 

981 

(2,117) 

(29) 

(1)  For assets, increase (decrease) to carrying value and for liabilities, (increase) decrease to carrying value. 
(2)   At December 31, 2019 and 2018, the cumulative fair value adjustments remaining on long-term debt and AFS debt securities from discontinued hedging relationships resulted in a decrease in the 
related liability of $1.3 billion and $1.6 billion and an increase (decrease) in the related asset of $8 million 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 2019, 2018 and 2017. 
Of  the  $400  million  after-tax  net  loss  ($526  million  pretax)  on 
derivatives in accumulated OCI at December 31, 2019, $68 million 
after-tax ($90 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 3 years, with a maximum 
length of time for certain forecasted transactions of 16 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 compensation plans (2) 

Total 

Net investment hedges 

Gains (Losses) in
Accumulated OCI on Derivatives 

Gains (Losses) in Income 
Reclassified from Accumulated OCI 

2019 

2018 

2017 

2019 

2018 

2017 

$ 

$ 

671  $ 

34 

705  $ 

(159)  $ 
4 
(155)  $ 

(109)  $ 
59 
(50)  $ 

(104)  $ 
(2) 
(106)  $ 

(165)  $ 

27 

(138)  $ 

(327) 
148 
(179) 

Foreign exchange risk (3) 

989  $ 
(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 compensation and benefits 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 market making 

411  $ 

(1,588)  $ 

366  $ 

22  $ 

1,782 

$ 

and similar activities were gains of $154 million, $47 million and $120 million in 2019, 2018 and 2017, respectively. 

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 following table presents gains (losses) on these derivatives for 2019, 2018 and 2017. These gains (losses) 
are largely offset by the income or expense recorded on the hedged item. 

126 126

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Gains and Losses on Other Risk Management Derivatives 

(Dollars in millions) 

Interest rate risk on mortgage activities (1, 2)  $ 
Credit risk on loans (2) 
Interest rate and foreign currency risk on 

ALM activities (3) 

2019 

2018 

2017 

315  $ 
(58) 

(107)  $ 
9 

8 
(6) 

1,112 

3,278 

(1,318) 

Price risk on certain compensation plans (4) 
704 
(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 $73 million, $47 million and $220 million in 2019, 
2018 and 2017, respectively. 

(495) 

943 

(2)  Gains (losses) on these derivatives are recorded in other income. 
(3)   Gains (losses) on these derivatives are recorded in market making and similar activities. Prior-

period amounts have been updated to conform to the current-period presentation. 

(4)  Gains (losses) on these derivatives are recorded in compensation and benefits expense. 

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, 2019 and 2018, the 
Corporation had transferred $5.2 billion and $5.8 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 $5.2 billion and $5.8 
billion at the transfer dates. At December 31, 2019 and 2018, 
the fair value of the transferred securities was $5.3 billion and 
$5.5 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  market  making  and  similar  activities  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  market  making  and  similar  activities.  For  debt  securities, 
revenue, with the exception of interest associated with the debt 
securities,  is  typically  included  in  market  making  and  similar 
activities.  Unlike  commissions  for  equity  securities,  the  initial 
revenue  related  to  broker-dealer  services  for  debt  securities  is 
typically included in the pricing of the instrument rather than being 
charged  through  separate  fee  arrangements.  Therefore,  this 
revenue is recorded in market making and similar activities as part 
of  the  initial  mark  to  fair  value.  For  derivatives, the  majority  of 
revenue  is  included  in  market making and similar activities. In 

transactions where the Corporation acts as agent, which include 
exchange-traded futures and options, fees are recorded in other 
income. 

The following table, 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 2019, 2018 and 2017. This table 
includes debit valuation adjustment (DVA) and funding valuation 
adjustment (FVA) gains (losses). Global Markets results in Note 24 
– 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 

Market 
making and 
similar 
activities 

Net 
Interest 
Income 

2019 

Other (1) 

Total 

$ 

916  $  1,831  $ 

1,300 
3,565 
1,158 
123 

54 
(638) 
1,800 
75 

121  $  2,868 
1,397 
4,501 
3,469 
255 

43 
1,574 
511 
57 

$ 

7,062  $  3,122  $  2,306  $  12,490 

$ 

784  $  1,696  $ 

2018 

1,486 
3,874 
1,063 
50 

11 
(662) 
1,861 
202 

259  $  2,739 
1,511 
4,856 
3,512 
305 

14 
1,644 
588 
53 

$ 

7,257  $  3,108  $  2,558  $ 12,923 

$ 

429  $  1,846  $ 

2017 

1,409 
2,598 
1,685 
79 

12 
(427) 
1,945 
170 

248  $  2,523 
1,430 
4,075 
4,208 
324 

9 
1,904 
578 
75 

$ 

6,200  $  3,546  $  2,814  $ 12,560 

(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 

(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, $1.7 billion and $2.0 billion in 2019, 2018 and 
2017, 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-

Bank of America 2019  127 
Bank of America 2019  127

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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, 
2019 and 2018 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, 2019 
Carrying Value 

Over Five 
Years 

Total 

$ 

5  $ 

60  $ 

292 
297 

— 
— 
— 

561 
621 

— 
— 
— 

1  $ 
3  $ 
1 
2 
5  $ 
2  $ 
Maximum Payout/Notional 

297  $ 

621  $ 

972  $ 

— 
70 
70 

35 
344 
379 
449  $ 

—  $ 
6 
6  $ 

132 
134 

105 
472 
577 
711  $ 

—  $ 
1 
1  $ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

67,838 
26,521 
94,359 

$ 

71,320 
29,618 
100,938 

55,827 
19,049 
74,876 

56,488 
28,707 
85,195 

$ 

160,071  $ 

$ 

2  $ 

44  $ 

— 
657 
657 
95,016  $ 

62 
104 
166 
101,104  $ 

December 31, 2018 
Carrying Value 

636 
680 

— 
21 
21 

701  $ 

436  $ 
914 
1,350 

— 
— 
— 
1,350  $ 

4  $ 
—  $ 
1 
1 
1  $ 
5  $ 
Maximum Payout/Notional 

$ 

164 
808 
972 

—
—
—

639  $ 

1,125 
1,764  $ 

$ 

17,708 
12,337 
30,045 

76 
60 
136 
30,181  $ 

488  $ 

1,691 
2,179 

— 
— 
— 
2,179  $ 

532  $ 

1,500 
2,032  $ 

229 
1,731 
1,960 

35 
344 
379 
2,339 

643 
1,134 
1,777 

212,693 
87,525 
300,218 

56,626 
29,528 
86,154 
386,372 

970 
3,373 
4,343 

105 
493 
598 
4,941 

536 
1,503 
2,039 

53,758 
24,297 
78,055 

60,042 
24,524 
84,566 

$ 

$ 

95,699 
33,881 
129,580 

$ 

95,274 
34,530 
129,804 

822 
1,649 
2,471 
132,051  $ 

59 
39 
98 
129,902  $ 

$ 

20,054 
14,426 
34,480 

72 
70 
142 
34,622  $ 

264,785 
107,134 
371,919 

60,995 
26,282 
87,277 
459,196 

$ 

162,621  $ 

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 

128 128

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
take additional protective measures such as early termination of 
all  trades.  Further,  as  previously  discussed  on  page  124,  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. 

Certain 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, 2019  and 2018, the  Corporation  held  cash  and 
securities collateral of $84.3 billion and $81.6 billion and posted 
cash and securities collateral of $69.1 billion and $56.5 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, 2019, 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 $2.3 billion, including 
$913 million for Bank of America, National Association (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, 
2019 and 2018, the liability recorded for these derivative contracts 
was not significant. 

The following table presents the amount of additional collateral 
that would have been contractually required by derivative contracts 
and other trading agreements at December 31, 2019 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, 2019 

(Dollars in millions) 

Bank of America Corporation 
Bank of America, N.A. and subsidiaries (1) 
(1) 

Included in Bank of America Corporation collateral requirements in this table. 

One 
incremental 
notch 

Second 
incremental 
notch 

$ 

480  $ 
222 

491 
353 

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, 2019 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. 

Derivative Liabilities Subject to Unilateral Termination 
Upon Downgrade at December 31, 2019 

(Dollars in millions) 

Derivative liabilities 
Collateral posted 

One 
incremental 
notch 

Second 
incremental 
notch 

$ 

57  $ 
42 

783 
411 

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 rates and foreign exchange rates 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  foreign 
exchange 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  market  making  and  similar 
activities, on a gross and net of hedge basis for 2019, 2018 and 
2017. 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 Gains (Losses) on Derivatives (1) 

Derivative assets (CVA) 
Derivative assets/liabilities 

(FVA) 

Net 

Gross 

Gross  Net 
2018 
$  72 $  45  $  77  $ 187  $ 330  $  98 

Gross  Net 
2017 

2019 

(2) 

46 

(15) 

14 

160 

178 

(281) 
Derivative liabilities (DVA) 
(1)  At December 31, 2019, 2018 and 2017, cumulative CVA reduced the derivative assets balance 
by $528 million, $600 million and $677 million, cumulative FVA reduced the net derivatives 
balance  by  $153  million, $151  million  and  $136  million, and  cumulative  DVA  reduced  the 
derivative liabilities balance by $285 million, $432 million and $450 million, respectively. 

(324) 

(19) 

(55) 

(147) 

(135) 

Bank of America 2019  129 
Bank of America 2019  129

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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, 2019 and 2018. 

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 (2) 

Total debt securities carried at fair value 

Held-to-maturity debt securities, substantially all U.S. agency mortgage-backed securities 

Total debt securities (3, 4) 

Available-for-sale debt securities 
Mortgage-backed securities: 

Amortized 
Cost 

Gross 
Unrealized 
Gains 

Gross 
Unrealized 
Losses 

December 31, 2019 

Fair 
Value 

$  121,698  $ 
4,587 
14,797 
948 
142,030 
67,700 
11,987 
3,874 
225,591 
17,716 
243,307 
10,596 
253,903 
215,730 
$  469,633  $ 

1,013  $ 
78 
249 
138 
1,478 
1,023 
6 
67 
2,574 
202 
2,776 
255 
3,031 
4,433 
7,464  $ 

(183)  $  122,528 
4,641 
(24) 
15,021 
(25) 
(9) 
1,077 
(241) 
143,267 
(195) 
68,528 
(2) 
11,991 
— 
3,941 
(438) 
227,727 
(6) 
17,912 
(444) 
245,639 
10,828 
(23) 
(467) 
256,467 
(342) 
219,821 
(809)  $  476,288 

December 31, 2018 

138  $ 

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 

(3,428)  $  121,826 
5,530 
(110) 
14,078 
(402) 
1,917 
(11) 
143,351 
(3,951) 
54,923 
(1,378) 
9,306 
(6) 
4,410 
(6) 
211,990 
(5,341) 
17,376 
(72) 
229,366 
(5,413) 
8,735 
(32) 
238,101 
(5,445) 
(3,964) 
200,435 
(9,409)  $  438,536 
(1)  At December 31, 2019 and 2018, the underlying collateral type included approximately 49 percent and 68 percent prime, six percent and four percent Alt-A and 45 percent and 28 percent subprime. 
(2)   Primarily includes non-U.S. securities used to satisfy certain international regulatory requirements. Any changes in value are reported in other income. For detail on the components, see Note 21 – 

$  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  $ 

Held-to-maturity debt securities, substantially all U.S. agency mortgage-backed securities  

19 
11 
136 
304 
62 
5 
29 
400 
99 
499 
172 
671 
747 

Other debt securities carried at fair value (2)  

Total debt securities carried at fair value  

Total available-for-sale debt securities  

Total debt securities (3, 4)  

Total taxable securities 

Tax-exempt securities 

1,418  $ 

Fair Value Measurements. 
Includes securities pledged as collateral of $67.0 billion and $40.6 billion at December 31, 2019 and 2018. 

(3) 

(4)   The Corporation held debt securities from FNMA and FHLMC that each exceeded 10 percent of shareholders’ equity, with an amortized cost of $157.2 billion and $54.1 billion, and a fair value of 
$160.6 billion and $55.1 billion at December 31, 2019, and 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. 

At December 31, 2019, the accumulated net unrealized gain 
on  AFS  debt  securities,  excluding  the  amount  related  to  debt 
securities previously transferred to held to maturity, included in 
accumulated OCI was $1.8 billion, net of the related income tax 
expense of $569 million. The Corporation had nonperforming AFS 
debt  securities  of  $9  million  and  $11  million  at  December  31, 
2019 and 2018. 

At December 31, 2019, the Corporation held equity securities 
at  an  aggregate  fair  value  of  $891  million  and  other  equity 
securities, as valued under the measurement alternative, at cost 
of $183 million, both of which are included in other assets. At 
December 31, 2019, the Corporation also held equity securities 
at fair value of $1.0 billion included in time deposits placed and 
other short-term investments. 

The  gross  realized  gains  and  losses  on  sales  of  AFS  debt 
securities for 2019, 2018 and 2017 are presented in the table 
below. 

Gains and Losses on Sales of AFS Debt Securities 

(Dollars in millions)  

Gross gains 
Gross losses 

Net gains on sales of AFS debt securities 
Income tax expense attributable to realized 
net gains on sales of AFS debt securities 

2019 

2018 

2017 

$ 

$ 

$ 

336  $ 
(119) 
217  $ 

169  $ 
(15) 
154  $ 

352 
(97) 
255 

54  $ 

37

$ 

97 

130 130

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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, 2019 and 2018. 

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 

Less than Twelve Months 

Twelve Months or Longer 

Total 

Fair 
Value 

Gross 
Unrealized 
Losses 

Fair 
Value 

Gross 
Unrealized 
Losses 

December 31, 2019 

Fair 
Value 

Gross 
Unrealized 
Losses 

$ 

17,641  $ 
255 
2,180 
19 
20,095 
12,836 
851 
938 
34,720 
4,286 
39,006 

(41)  $ 

(1) 
(22) 
(1) 
(65) 
(71) 
— 
— 
(136) 
(5) 
(141) 

17,238  $ 
925 
442 
1 
18,606 
18,866 
837 
222 
38,531 
190 
38,721 

(142)  $ 
(23) 
(3) 
— 
(168) 
(124) 
(2) 
— 
(294) 
(1) 
(295) 

34,879  $ 

1,180 
2,622 
20 
38,701 
31,702 
1,688 
1,160 
73,251 
4,476 
77,727 

(183) 
(24) 
(25) 
(1) 
(233) 
(195) 
(2) 
— 
(430) 
(6) 
(436) 

103 

(5) 

21 

(3) 

124 

(8) 

Total temporarily impaired and other-than-temporarily impaired 

AFS debt securities 

$ 

39,109  $ 

(146)  $ 

38,742  $ 

(298)  $ 

77,851  $ 

(444) 

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 

$ 

14,771  $ 
3 
1,344 
106 
16,224 
288 
773 
183 
17,468 
232 
17,700 

131 

— 
(8) 
(8) 
(65) 
(1) 
(5) 
(1) 
(72) 
(2) 
(74) 

— 

December 31, 2018 

(49)  $ 

99,211  $ 

(3,379)  $  113,982  $ 

4,452 
11,991 
49 
115,703 
51,374 
21 
185 
167,283 
2,148 
169,431 

(110) 
(394) 
(3) 
(3,886) 
(1,377) 
(1) 
(5) 
(5,269) 
(70) 
(5,339) 

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) 

3 

— 

134 

— 

Total temporarily impaired and other-than-temporarily impaired 

AFS debt securities 

$ 

17,831  $ 

(74)  $  169,434  $ 

(5,339)  $  187,265  $ 

(5,413) 

(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. 

In 2019, 2018 and 2017, the Corporation had $24 million, 
$33  million  and  $41  million, respectively, of  credit-related  OTTI 
losses  on  AFS  debt  securities  which  were  recognized  in  other 
income. The amount of non-credit related OTTI losses for these 
AFS debt securities, which is 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 
$85  million,  $120  million  and  $274  million  at  December  31, 
2019, 2018 and 2017, 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, 2019. 

Bank of America 2019  131 
Bank of America 2019  131

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Significant Assumptions 

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. 

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 12.9 percent for 
prime, 11.1 percent for Alt-A and 18.8 percent for subprime at 
December 31, 2019. Default rates are projected by considering 
collateral  characteristics  including, but  not  limited  to, LTV, FICO 
and geographic concentration. Weighted-average life default rates 

Range (1) 

Weighted 
average 

10th 
Percentile (2) 

90th 
Percentile (2) 

16.6% 
14.7 
11.9 

5.5% 
8.0 
1.0 

27.8% 
30.7 
36.5 

by collateral type were 7.8 percent for prime, 11.6 percent for Alt-
A and 13.6 percent for subprime at December 31, 2019. 

The remaining contractual maturity distribution and yields of 
the  Corporation’s  debt  securities  carried  at  fair  value  and  HTM 
debt securities at December 31, 2019 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 

(Dollars in millions)  

Amount 

Yield (1) 

Amount 

Yield (1) 

Amount 

Yield (1) 

Amount 

Yield (1) 

Amount 

Yield (1) 

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 

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 

$ 

— 

— 

— 

— 

— 

1,350 

15,648 

1,189 

18,187 

2,189 

—%  $ 

— 

— 

— 

— 

0.92 

1.17 

2.80 

1.26 

1.72 

11 

— 

3,806 

— 

3,817 

35,544 

2,598 

1,650 

43,609 

7,472 

5.25%  $ 

— 

2.37 

— 

2.38 

1.67 

1.03 

3.02 

1.74 

2.10 

66 

27 

10,136 

12 

10,241 

30,789 

7 

440 

41,477 

4,849 

4.56%  $124,618 

3.24%  $124,695 

3.24% 

2.48 

2.57 

— 

2.58 

2.25 

4.17 

3.32 

2.34 

2.06 

4,560 

868 

2,157 

132,203 

20 

96 

595 

132,914 

3,206 

3.16 

2.99 

9.26 

3.33 

2.45 

6.74 

2.91 

3.34 

2.44 

4,587 

14,810 

2,169 

146,261 

67,703 

18,349 

3,874 

236,187 

17,716 

3.16 

2.54 

9.22 

3.25 

1.92 

1.18 

2.97 

2.70 

2.10 

2.67 

3.19 

fair value 

$  20,376 

1.31 

$  51,081 

1.79 

$  46,326 

2.31 

$ 136,120 

3.32 

$ 253,903 

Amortized cost of HTM debt securities (2) 

$  1,025 

2.83 

$ 

48 

3.57 

$  1,102 

2.57 

$ 213,555 

3.19 

$ 215,730 

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) 

— 

— 

— 

— 

— 

1,347 

15,751 

1,196 

18,294 

2,192 

$  20,486 

$  1,025 

$ 

11 

— 

$ 

71 

26 

3,854 

— 

3,865 

35,686 

2,606 

1,687 

43,844 

7,509 

10,287 

25 

10,409 

31,478 

8 

465 

42,360 

4,976 

$  51,353 

$ 

48 

$  47,336 

$  1,113 

$125,449 

$125,531 

4,615 

893 

2,386 

133,343 

20 

98 

596 

134,057 

3,235 

$ 137,292 

$ 217,635 

4,641 

15,034 

2,411 

147,617 

68,531 

18,463 

3,944 

238,555 

17,912 

$ 256,467 

$ 219,821 

(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. 

132 132

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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, 2019 and 2018. 

10,399 
4,982 

97,608 
90,998 
192 
465,175 

594 

465,769 

307,048 
104,966 
62,689 
19,880 
15,333 
509,916 

(Dollars in millions) 

Consumer real estate 

Core portfolio 

Residential mortgage 
Home equity 
Non-core portfolio 

Residential mortgage 
Home equity 

Credit card and other consumer 

Credit card 
Direct/Indirect consumer (4) 
Other consumer 

Total consumer 

30-59 Days 
Past Due (1) 

60-89 Days 
Past Due (1) 

$ 

1,378 
135 

$ 

458 
34 

564 
297 
— 
2,866 

261 
70 

209 
16 

429 
85 
— 
1,070 

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 

Total 

Value Option  Outstandings 

December 31, 2019 

$ 

$ 

565 
198 

2,204 
403 

$  223,566 
34,823 

$  225,770 
35,226 

1,263 
72 

1,042 
35 
— 
3,175 

1,930 
122 

2,035 
417 
— 
7,111 

8,469 
4,860 

95,573 
90,581 
192 
458,064 

Consumer loans accounted for under the fair value 

option (5) 

Total consumer loans and leases 

2,866 

1,070 

3,175 

7,111 

458,064 

$ 

594 

594 

Commercial 

U.S. commercial 
Non-U.S. commercial 
Commercial real estate (6) 
Commercial lease financing 
U.S. small business commercial 

Total commercial 

Commercial loans accounted for under the fair value 

option (5) 

788 
35 
144 
100 
119 
1,186 

279 
23 
19 
56 
56 
433 

371 
8 
119 
39 
107 
644 

1,438 
66 
282 
195 
282 
2,263 

305,610 
104,900 
62,407 
19,685 
15,051 
507,653 

Total commercial loans and leases 
Total loans and leases (7) 

1,186 
4,052 

$ 

433 
1,503 

$ 

644 
3,819 

$ 

2,263 
9,374 

507,653 
$  965,717 

$ 

$ 

7,741 

7,741 
8,335 

7,741 

517,657 
$  983,426 

Percentage of outstandings  
100.00% 
(1)   Consumer real estate loans 30-59 days past due includes fully-insured loans of $517 million and nonperforming loans of $139 million. Consumer real estate loans 60-89 days past due includes 

98.20% 

0.39% 

0.85% 

0.95% 

0.41% 

0.15% 

fully-insured loans of $206 million and nonperforming loans of $114 million. 

(2)  Consumer real estate includes fully-insured loans of $1.1 billion. 
(3)  Consumer real estate includes $856 million and direct/indirect consumer includes $45 million of nonperforming loans. 
(4)  Total outstandings primarily includes auto and specialty lending loans and leases of $50.4 billion, U.S. securities-based lending loans of $36.7 billion and non-U.S. consumer loans of $2.8 billion. 
(5)   Consumer loans accounted for under the fair value option includes residential mortgage loans of $257 million and home equity loans of $337 million. Commercial loans accounted for under the fair 
value option includes U.S. commercial loans of $4.7 billion and non-U.S. commercial loans of $3.1 billion. For more information, see Note 21 – Fair Value Measurements and Note 22 – Fair Value 
Option. 

(6)  Total outstandings includes U.S. commercial real estate loans of $59.0 billion and non-U.S. commercial real estate loans of $3.7 billion. 
(7)   Total outstandings includes loans and leases pledged as collateral of $25.9 billion. The Corporation also pledged $168.2 billion of loans with no related outstanding borrowings to secure potential 

borrowing capacity with the Federal Reserve Bank and Federal Home Loan Bank. 

Bank of America 2019  133 
Bank of America 2019  133

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 

Credit card 
Direct/Indirect consumer (4) 
Other consumer (5) 
Total consumer 

30-59 Days 
Past Due (1) 

60-89 Days 
Past Due (1) 

$ 

1,188 
200 

$ 

757 
139 

577 
317 
— 
3,178 

249 
85 

309 
69 

418 
90 
— 
1,220 

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 

Total 

Value Option  Outstandings 

December 31, 2018 

$ 

$ 

793 
387 

2,230 
672 

$  191,465 
39,338 

$  193,695 
40,010 

2,201 
339 

994 
40 
— 
4,754 

3,267 
547 

1,989 
447 
— 
9,152 

11,595 
7,729 

96,349 
90,719 
202 
437,397 

Consumer loans accounted for under the fair value 

option (6) 

Total consumer loans and leases 

3,178 

1,220 

4,754 

9,152 

437,397 

$ 

682 

682 

Commercial 

U.S. commercial 
Non-U.S. commercial 
Commercial real estate (7) 
Commercial lease financing 
U.S. small business commercial 

Total commercial 

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 

Commercial loans accounted for under the fair value 

option (6) 

Total commercial loans and leases 
Total loans and leases (8) 

831 
4,009 

$ 

465 
1,685 

$ 

720 
5,474 

2,016 
$  11,168 

493,981 
$  931,378 

$ 

$ 

3,667 

3,667 
4,349 

3,667 

499,664 
$  946,895 

Percentage of outstandings 
100.00% 
(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 

98.36% 

0.42% 

0.18% 

1.18% 

0.58% 

0.46% 

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)  Total outstandings primarily includes auto and specialty lending loans and leases of $50.1 billion, U.S. securities-based lending loans of $37.0 billion and non-U.S. consumer loans of $2.9 billion. 
(5)  Substantially all of other consumer is consumer overdrafts. 
(6)   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 more information, see Note 21 – Fair Value Measurements and Note 22 – Fair Value 
Option. 

(7)  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. 
(8)   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. 

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 $7.5 billion 
and $6.1 billion at December 31, 2019 and 2018, 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 2019, the Corporation sold $4.7 billion of consumer 

real estate compared to $11.6 billion in 2018. 

Nonperforming Loans and Leases 
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 loans have 
not been otherwise modified. The Corporation continues to have 
a lien on the underlying collateral. 

134 134

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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, 2019 and 2018. 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 

Credit card 
Direct/Indirect consumer 
Total consumer 

Commercial 

Nonperforming Loans 
and Leases 

Accruing Past Due 
90 Days or More 

2019 

2018 

2019 

2018 

December 31 

$ 

883  $ 
363 

1,010  $ 
955 

176  $ 

— 

587 
173 

n/a 
47 
2,053 

883 
938 

n/a 
56 
3,842 

912 
— 

1,042 
33 
2,163 

274 
— 

1,610 
— 

994 
38 
2,916 

U.S. commercial 
Non-U.S. commercial 
Commercial real estate 
Commercial lease financing 
U.S. small business commercial 

197 
— 
4 
29 
84 
314 
3,230 
(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, 2019 and 2018, residential mortgage includes $740 
million and $1.4 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 $348 million and $498 million 
of loans on which interest is still accruing. 

794 
80 
156 
18 
54 
1,102 
4,944  $ 

1,094 
43 
280 
32 
50 
1,499 
3,552  $ 

Total commercial 
Total loans and leases 

106 
8 
19 
20 
97 
250 

2,413  $ 

$ 

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. 

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, 2019 and 2018. 

Bank of America 2019  135 
Bank of America 2019  135

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Consumer Real Estate – Credit Quality Indicators (1) 

(Dollars in millions)  

Refreshed LTV 

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 (2) 

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 (2) 

Total consumer real estate 

Core 
Residential 
Mortgage 

Non-core 
Residential 
Mortgage 

Core 
Home 
Equity 

Non-core 
Home 
Equity 

Core 
Residential 
Mortgage 

Non-core 
Residential 
Mortgage 

Core 
Home 
Equity 

Non-core 
Home 
Equity 

December 31, 2019 

December 31, 2018 

$  205,357  $ 

7,433  $  34,733  $ 

4,127  $  173,911  $  10,272  $  39,246  $ 

6,478 

3,100 

273 

226 

1,049 
16,264 

267 
2,426 
$  225,770  $  10,399  $  35,226  $ 

267 

$ 

751  $ 

2,127  $ 
4,821 
26,905 
175,653 
16,264 

1,230  $ 
1,053 
1,981 
3,709 
2,426 
$  225,770  $  10,399  $  35,226  $ 

1,550 
6,025 
26,900 

348 

507 

2,349 

817 
16,618 

533 

545 
3,512 

354 

410 

715 

1,083 

4,982  $  193,695  $  14,862  $  40,010  $ 

8,276 

541  $ 
800 
1,412 
2,229 

2,125  $ 
4,538 
23,841 
146,573 
16,618 

1,974  $ 
1,719 
3,042 
4,615 
3,512 

1,064  $ 
2,008 
7,008 
29,930 

1,503 
1,720 
2,188 
2,865 

4,982  $  193,695  $  14,862  $  40,010  $ 

8,276 

(1)  Excludes $594 million and $682 million of loans accounted for under the fair value option at December 31, 2019 and 2018. 
(2)  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) 

Credit 
Card 

Direct/Indirect 
Consumer 
December 31, 2019 

Other 
Consumer 

Credit 
Card 

Direct/Indirect 
Consumer 
December 31, 2018 

Other 
Consumer 

$ 

5,179  $ 

12,277 
35,301 
44,851 

1,720 
2,734 
8,460 
37,825 
40,259  $ 
90,998  $ 

$ 

5,016  $ 

12,415 
35,781 
45,126 

192 
192  $ 

98,338  $ 

1,719 
3,124 
8,921 
36,709 
40,693  $ 
91,166  $ 

202 
202 

Total credit card and other consumer 

$ 

97,608  $ 

(1)  Other internal credit metrics may include delinquency status, geography or other factors. 
(2)  Direct/indirect consumer includes $39.6 billion and $39.9 billion of securities-based lending which is overcollateralized and therefore has minimal credit risk at December 31, 2019 and 2018. 

Commercial – Credit Quality Indicators (1) 

(Dollars in millions) 
Risk ratings 
Pass rated 
Reservable criticized 
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 (3) 

Total commercial 

Risk ratings 
Pass rated 
Reservable criticized 
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 (3) 

Total commercial 

U.S. 
Commercial 

Non-U.S. 
Commercial 

Commercial 
Real Estate 

December 31, 2019 

Commercial 
Lease 
Financing 

U.S. Small 
Business 
Commercial (2) 

$ 

299,380  $ 
7,668 

104,051  $ 
915 

61,598  $ 

1,091 

19,551  $ 
329 

$ 

307,048  $ 

104,966  $ 

62,689  $ 

19,880  $ 

December 31, 2018 

231 
18 

308 
756 
2,267 
4,607 
7,146 
15,333 

$ 

291,918  $ 
7,359 

97,916  $ 
860 

59,910  $ 
935 

22,168  $ 
366 

389 
29 

$ 

299,277  $ 

98,776  $ 

60,845  $ 

22,534  $ 

264 
684 
2,072 
4,254 
6,873 
14,565 

(1)  Excludes $7.7 billion and $3.7 billion of loans accounted for under the fair value option at December 31, 2019 and 2018. 
(2)   At December 31, 2019 and 2018, U.S. small business commercial includes $715 million and $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. Refreshed FICO score and other internal credit metrics are applicable only to the U.S. small business 
commercial portfolio. 

(3)   Other internal credit metrics may include delinquency status, application scores, geography or other factors. At both December 31, 2019 and 2018, 99 percent of the balances where internal credit 

metrics are used were current or less than 30 days past due. 

136 136

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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.  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 of $632 million that have been 
discharged in Chapter 7 bankruptcy with no change in repayment 
terms and not reaffirmed by the borrower were included in TDRs 
at December 31, 2019, of which $101 million were classified as 
nonperforming and $275 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, 2019 and 2018, 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 $229 million and $244 million 
at December 31, 2019 and 2018. The carrying value of consumer 
real estate loans, including fully-insured loans, for which formal 
foreclosure proceedings were in process at December 31, 2019 
was  $1.6  billion.  During  2019  and  2018,  the  Corporation 
reclassified $611 million and $670 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, 2019 and 
2018  and  the  average  carrying  value  and  interest  income 
recognized  in  2019, 2018  and  2017  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 2019  137 
Bank of America 2019  137

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 

Residential mortgage 
Home equity 

With no recorded allowance 

Residential mortgage 
Home equity 

With an allowance recorded 

Residential mortgage 
Home equity 

Total 

Unpaid 
Principal 
Balance 

Carrying 
Value 

Related 
Allowance 

Unpaid 
Principal 
Balance 

Carrying 
Value 

Related 
Allowance 

December 31, 2019 

December 31, 2018 

$ 

4,224  $ 
1,176 

3,354  $ 

706 

—  $ 
— 

5,396  $ 
2,948 

4,268  $ 
1,599 

$ 

1,426  $ 

1,399  $ 

543 

523 

$ 

5,650  $ 
1,719 

4,753  $ 
1,229 

70  $ 
69 

70  $ 
69 

1,977  $ 

1,929  $ 

812 

760 

7,373  $ 
3,760 

6,197  $ 
2,359 

— 
— 

114 
144 

114 
144 

Average 
Carrying 
Value 

Interest 
Income 
Recognized (1) 

Average 
Carrying 
Value 

Interest 
Income 
Recognized (1) 

Average 
Carrying 
Value 

Interest 
Income 
Recognized (1) 

2019 

2018 

2017 

$ 

3,831  $ 
1,221 

155  $ 

76 

5,424  $ 
1,894 

207  $ 
105 

7,737  $ 
1,997 

$ 

1,635  $ 

637 

62  $ 
22 

2,409  $ 

861 

91  $ 
25 

3,414  $ 

858 

311 
109 

123 
24 

Residential mortgage 
Home equity 

434 
133 
(1)   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 

7,833  $ 
2,755 

5,466  $ 
1,858 

298  $ 
130 

11,151  $ 

217  $ 

2,855 

98 

$ 

which the principal is considered collectible. 

The table below presents the December 31, 2019, 2018 and 2017 unpaid principal balance, carrying value, and average pre- and 
post-modification interest rates of consumer real estate loans that were modified in TDRs during 2019, 2018 and 2017. 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 2019, 2018 and 2017 

(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) 

464 
141 
605 

774 
489 
1,263 

824 
764 
1,588 

$ 

$ 

$ 

$ 

$ 

$ 

December 31, 2019 

377 
101 
478 

December 31, 2018 

641 
358 
999 

December 31, 2017 

712 
590 
1,302 

4.19% 
5.04 
4.39 

4.33% 
4.46 
4.38 

4.43% 
4.22 
4.33 

$ 

$ 

$ 

$ 

$ 

$ 

4.13% 
4.31 
4.17 

4.21% 
3.74 
4.03 

4.16% 
3.49 
3.83 

(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. 

138 138

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The table below presents the December 31, 2019, 2018 and 2017 carrying value for consumer real estate loans that were modified 

in a TDR during 2019, 2018 and 2017, by type of modification. 

Consumer Real Estate – Modification Programs 

(Dollars in millions) 

TDRs Entered into During 
2018 

2019 

2017 

Modifications under government programs (1) 
Modifications under proprietary programs (1) 
Loans discharged in Chapter 7 bankruptcy (2) 
Trial modifications 

85 
437 
211 
569 
1,302 
(1)   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; there were no such modifications in 2019 or 2017. These modifications were 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. 

61
523 
130 
285 
999  $ 

174 
68 
201 
478  $ 

Total modifications  

35  $ 

$ 

$ 

$ 

(2) 

The table below presents the carrying value of consumer real estate loans that entered into payment default during 2019, 2018 
and 2017 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) 

2019 

2018 

2017 

$ 

$ 

26 
88 
30 
57 
201 

$ 

$ 

39 
158 
64 
107 
368 

$ 

$ 

81 
138 
116 
391 
726 

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  following  table  provides  the  unpaid  principal  balance, 
carrying value and related allowance at December 31, 2019 and 
2018 and the average carrying value for 2019, 2018 and 2017 
on  TDRs  within  the  Credit  Card  and  Other  Consumer  portfolio 
segment. 

Impaired Loans – Credit Card and Other Consumer 

Unpaid  
Principal 
Balance 

Carrying 
Value (1) 

Related 
Allowance 

Unpaid 
Principal 
Balance 

Carrying 
Value (1) 

Related 
Allowance 

December 31, 2019 

December 31, 2018 

Average Carrying Value (2) 
2018 

2019 

2017 

(Dollars in millions)  

With no recorded allowance 
Direct/Indirect consumer 
With an allowance recorded 

Credit card (3) 
Includes accrued interest and fees. 

(1) 

$ 

$ 

73

$ 

32

$ 

—  $ 

72

$ 

33

$ 

— 

$ 

33  $ 

30

$ 

21 

633  $ 

647  $ 

188  $ 

522  $ 

533  $ 

154 

$ 

594  $ 

491  $ 

511 

(2)   The related interest income recognized, which 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 was considered collectible, was not significant in 2019, 2018 and 2017. 

(3)  The average carrying value in 2017 includes $47 million related to the non-U.S. credit card portfolio, which was sold in the second quarter of 2017. 

Bank of America 2019  139 
Bank of America 2019  139

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The table below provides information on the Corporation’s primary modification programs for the Credit Card and Other Consumer 

TDR portfolio at December 31, 2019 and 2018. 

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 

Credit Card 

2019 

2018 

Direct/Indirect Consumer 
2019 
2018 

Total TDRs by Program Type 

2019 

2018 

$ 

$ 

$ 

$ 

339 
308 
— 
647 

85% 

$

$ 

259 
273 
1 
533 

85% 

$

$ 

— 
— 
32 
32 
78% 

$ 

$ 

— 
— 
33 
33 
81% 

$ 

$ 

339 
308 
32 
679 

84% 

259 
273 
34 
566 

85% 

The table below provides information on the Corporation’s Credit Card and Other Consumer TDR portfolio including the December 
31, 2019, 2018 and 2017 unpaid principal balance, carrying value, and average pre- and post-modification interest rates of loans that 
were modified in TDRs during 2019, 2018 and 2017. 

Credit Card and Other Consumer – TDRs Entered into During 2019, 2018 and 2017 

(Dollars in millions) 

Credit card 
Direct/Indirect consumer 

Total 

Credit card 
Direct/Indirect consumer 

Total 

Credit card 
Non-U.S. credit card 

Total 
Includes accrued interest and fees. 

(1) 

Unpaid 
Principal 
Balance 

Carrying 
Value (1) 

Pre-
Modification 
Interest Rate 

Post-
Modification 
Interest Rate 

$ 

$ 

$ 

$ 

$ 

$ 

340 
40 
380 

278 
42 
320 

203 
37 
240 

$ 

$ 

$ 

$ 

$ 

$ 

December 31, 2019 

355 
21 
376 

19.18% 
5.23 
18.42 

December 31, 2018 

292 
23 
315 

19.49% 
5.10 
18.45 

December 31, 2017 

213 
22 
235 

18.47% 
4.81 
17.17 

5.35% 
5.21 
5.34 

5.24% 
4.95 
5.22 

5.32% 
4.30 
5.22 

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  14  percent  of  new 
credit card TDRs and 20 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, 2019 and 2018, remaining commitments to 
lend additional funds to debtors whose terms have been modified 
in a commercial loan TDR were $445 million and $297 million. 
The  balance  of  commercial  TDRs  in  payment  default  was  not 
significant at December 31, 2019 and 2018. 

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, 
2019 and 2018, and the average carrying value for 2019, 2018 
and  2017.  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. 

140 140

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 

Unpaid 
Principal 
Balance 

Carrying 
Value 

Related 
Allowance 

Unpaid 
Principal 
Balance 

Carrying 
Value 

Related 
Allowance 

Average Carrying Value (1) 

December 31, 2019 

December 31, 2018 

2019 

2018 

2017 

$ 

$ 

$ 

$ 

$ 

$ 

534 
123 
67 
12 

1,776 
113 
322 
57 
91 

520 
123 
58 
12 

1,574 
113 
236 
51 
77 

$ 

$ 

— 
— 
— 
— 

216 
9 
64 
1 
30 

$ 

$ 

638 
93 
— 
— 

1,437 
155 
247 
71 
83 

$ 

$ 

616 
93 
— 
— 

1,270 
149 
162 
71 
72 

$ 

$ 

— 
— 
— 
— 

121 
30 
16 
— 
29 

$ 

$ 

635 
79 
96 
5 

1,316 
218 
149 
73 
75 

$ 

$ 

655 
43 
44 
3 

1,162 
327 
46 
42 
73 

772 
46 
69 
— 

1,260 
463 
73 
8 
73 

U.S. commercial 
Non-U.S. commercial 
Commercial real estate 
Commercial lease financing 
U.S. small business commercial (2) 

2,032 
509 
142 
8 
73 
(1)   The related interest income recognized, which includes interest accrued and collected on the outstanding balances of accruing impaired loans as well as interest cash collections on nonaccruing 

2,075 
248 
247 
71 
83 

1,817 
370 
90 
45 
73 

1,886 
242 
162 
71 
72 

2,310 
236 
389 
69 
91 

2,094 
236 
294 
63 
77 

1,951 
297 
245 
78 
75 

121 
30 
16 
— 
29 

216 
9 
64 
1 
30 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

impaired loans for which the principal was considered collectible, was not significant in 2019, 2018 and 2017. 
Includes U.S. small business commercial renegotiated TDR loans and related allowance. 

(2) 

Loans Held-for-sale 
The Corporation had LHFS of $9.2 billion and $10.4 billion at December 31, 2019 and 2018. Cash and non-cash proceeds from sales 
and paydowns of loans originally classified as LHFS were $30.6 billion, $29.2 billion and $41.3 billion for 2019, 2018 and 2017, 
respectively. Cash used for originations and purchases of LHFS totaled $28.9 billion, $28.1 billion and $43.5 billion for 2019, 2018 
and 2017, respectively. 

NOTE 6 Allowance for Credit Losses 
The table below summarizes the changes in the allowance for credit losses by portfolio segment for 2019, 2018 and 2017. 

Consumer 
Real Estate 

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 

Provision for loan and lease losses 
Other (1) 

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 

Provision for loan and lease losses 
Other (1) 

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 

Provision for loan and lease losses 
Other (1) 

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 

$ 

$ 

$ 

$ 

$ 

$ 

928  $ 
(522) 
927 
405 
(680) 
(107) 
546 
— 
— 
— 

546  $ 

1,720  $ 

(690) 
664 
(26) 
(492) 
(274) 
928 
— 
— 
— 

928  $ 

2,750  $ 

(770) 
657 
(113) 
(710) 
(207) 
1,720 
— 
— 
— 
1,720  $ 

2019 
3,874  $ 
(4,302) 
911 
(3,391) 
3,512 
1 
3,996 
— 
—
— 
3,996  $ 

2018 
3,663  $ 
(4,037) 
823 
(3,214) 
3,441 
(16) 
3,874 
— 
— 
— 
3,874  $ 

2017 
3,229  $ 
(3,774) 
809 
(2,965) 
3,437 
(38) 
3,663 
— 
— 
— 
3,663  $ 

(1)  Primarily represents write-offs of purchased credit-impaired loans, the net impact of portfolio sales, and transfers to LHFS. 

4,799  $ 

(822) 
160 
(662) 
742 
(5) 
4,874 
797 
16
813 

5,687  $ 

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  $ 

9,601 
(5,646) 
1,998 
(3,648) 
3,574 
(111) 
9,416 
797 
16 
813 
10,229 

10,393 
(5,402) 
1,639 
(3,763) 
3,262 
(291) 
9,601 
777 
20 
797 
10,398 

11,237 
(5,619) 
1,640 
(3,979) 
3,381 
(246) 
10,393 
762 
15 
777 
11,170 

Bank of America 2019  141 
Bank of America 2019  141

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The table below presents the allowance and the carrying value of outstanding loans and leases by portfolio segment at December 

31, 2019 and 2018. 

(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) 

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) 

Total 

Allowance for loan and lease losses 
Carrying value (2, 3) 
Allowance as a percentage of carrying value (3) 

Consumer 
Real Estate 

Credit Card and 
Other Consumer 

Commercial 

Total 

December 31, 2019 

$ 

$ 

$ 

$ 

$ 

$ 

139
5,982 

2.32% 

407 
270,395 

0.15% 

546 
276,377 

$ 

$ 

$ 

188
679 
27.69% 

3,808 
188,119 

2.02% 

3,996 
188,798 

$ 

$ 

$ 

320
2,764 
11.58% 

4,554 
507,152 

0.90% 

4,874 
509,916 

$ 

$ 

$ 

647 
9,425 

6.86% 

8,769 
965,666 

0.91% 

9,416 
975,091 

0.20% 

2.12% 

0.96% 

0.97% 

December 31, 2018 

258 
8,556 

3.02% 

670 
248,287 

0.27% 

928 
256,843 

$ 

$ 

$ 

154 
566 
27.21% 

3,720 
189,140 

1.97% 

3,874 
189,706 

$ 

$ 

$ 

196 
2,433 

8.06% 

4,603 
493,564 

0.93% 

4,799 
495,997 

$ 

$ 

$ 

608 
11,555 

5.26% 

8,993 
930,991 

0.97% 

9,601 
942,546 

1.02% 
(1)   Impaired loans include nonperforming commercial loans and leases, as well as all TDRs, including both commercial and consumer TDRs. Impaired loans exclude nonperforming consumer loans 

0.36% 

2.04% 

0.97% 

unless they are TDRs, and all consumer and commercial loans accounted for under the fair value option. 

(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 $8.3 billion and $4.3 billion at December 31, 2019 and 2018. 

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, 2019 and 
2018  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, 2019 and 
2018 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. 

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 in 
connection with its funding activities. 

The  Corporation  did  not  provide  financial  support  to 
consolidated or unconsolidated VIEs during 2019, 2018 and 2017 
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 $1.1 billion and $218 million at December 
31, 2019 and 2018. 

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 GSEs, 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 

142 142

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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  warranties. 
subordinate securities and equity tranches issued by the trusts. 
Except as described in Note 13 – Commitments and Contingencies, 

the Corporation does not provide guarantees or recourse to the 
securitization  trusts  other  than  standard  representations  and 

The table below summarizes select information related to first-

lien mortgage securitizations for 2019, 2018 and 2017. 

First-lien Mortgage Securitizations 

(Dollars in millions) 

Residential Mortgage - Agency 
2018 

2017 

2019 

Commercial Mortgage 

2019 

2018 

2017 

5,887 
Proceeds from loan sales (1) 
91 
Gains on securitizations (2) 
— 
Repurchases from securitization trusts (3) 
(1)   The Corporation transfers residential mortgage loans to securitizations sponsored primarily by the GSEs or GNMA in the normal course of business and primarily receives RMBS in exchange. 

6,858  $  5,801  $  16,161  $ 

62 
1,485 

158 
2,713 

101 
—

103 
— 

27 
881 

6,991  $ 

8,661  $ 

$ 

Substantially all of these securities are classified as Level 2 within the fair value hierarchy and are sold shortly after receipt. 

(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 $64 million, $71 million and $243 million, net of hedges, during 2019, 2018 and 2017, 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. 

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  $192.1  billion  and 
$226.6 billion at December 31, 2019 and 2018. Servicing fee 
and ancillary fee income on serviced loans was $585 million, $710 
million and $893 million during 2019, 2018 and 2017. Servicing 
advances on serviced loans, including loans serviced for others 
and loans held for investment, were $2.4 billion and $3.3 billion 

at December 31, 2019 and 2018. For more information on MSRs, 
see Note 21 – Fair Value Measurements. 

During  2019, 

the  Corporation  deconsolidated  agency 
residential mortgage securitization trusts with total assets of $1.2 
billion.  There  were  no  significant  deconsolidations  in  2018  or 
2017. 

The following table summarizes select information related to 
first-lien mortgage securitization trusts in which the Corporation 
held a variable interest at December 31, 2019 and 2018. 

First-lien Mortgage VIEs 

Agency 

Prime 

Residential Mortgage 

Non-agency 

Subprime 

December 31 

Alt-A 

Commercial Mortgage 

(Dollars in millions) 

Unconsolidated VIEs 

2019 

2018 

2019 

2018 

2019 

2018 

2019 

2018 

2019 

2018 

Maximum loss exposure (1) 

$ 

12,554  $ 

16,011 

$ 

340  $ 

448 

$ 

1,622  $ 

1,897 

$ 

98  $ 

217 

$ 

1,036  $ 

767 

On-balance sheet assets 

Senior securities: 

Trading account assets 

$ 

627  $ 

460 

$ 

5  $ 

30 

$ 

54  $ 

36 

$ 

24  $ 

90 

$ 

65  $ 

97 

Debt securities carried at fair 

value 

Held-to-maturity securities 

All other assets 

6,392 

5,535 

— 

9,381 

6,170 

— 

193 

— 

2 

246 

— 

3 

1,178 

1,470 

— 

49 

— 

37 

72 

— 

2 

125 

— 

2 

— 

809 

38 

— 

528 

40 

Total retained positions 

Principal balance outstanding (2) 

$ 
$ 

12,554  $ 
160,226  $ 

16,011 
187,512 

$ 
$ 

200  $ 
7,268  $ 

279 
8,954 

$ 
$ 

1,281  $ 
8,594  $ 

1,543 
8,719 

$ 
$ 

98  $ 
19,878  $ 

217 
23,467 

$ 
$ 

912  $ 
60,129  $ 

665 
43,593 

Consolidated VIEs 

Maximum loss exposure (1) 

$ 

10,857  $ 

13,296 

$ 

5  $ 

7 

$ 

44  $ 

—  $ 

—  $ 

—  $ 

—  $ 

On-balance sheet assets 

Trading account assets 

$ 

780  $ 

1,318 

$ 

116  $ 

150 

$ 

149  $ 

—  $ 

—  $ 

—  $ 

—  $ 

Loans and leases, net 

All other assets 

Total assets 

Total liabilities 

9,917 

161 

11,858 

143 

10,858  $ 

13,319 

4  $ 

26 

$ 

$ 

$ 

$ 

— 

— 

116  $ 

111  $ 

— 

— 

150 

143 

$ 

$ 

— 

— 

149  $ 

105  $ 

— 

— 

—  $ 

—  $ 

— 

— 

—  $ 

—  $ 

— 

— 

—  $ 

—  $ 

— 

— 

—  $ 

—  $ 

76 

76 

— 

— 

76 

— 

(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 more information, see Note 13 
– Commitments and Contingencies and Note 21 – Fair Value Measurements. 

(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. 

Bank of America 2019  143 
Bank of America 2019  143

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Other Asset-backed Securitizations 
The  following  table  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, 2019 and 2018. 

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 

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 

2019 

2018 

2019 

2018 

2019 

2018 

2019 

2018 

412  $ 

908 

$ 

—  $ 

—  $ 

7,526  $ 

7,647 

$ 

3,701  $ 

2,150 

$ 

— 
11 
— 

11  $ 
1,023  $ 

— 
27 
— 

27 

1,813 

$ 

$ 

$ 

$ 

— 
— 
— 

—  $ 
—  $ 

$ 

— 
— 
— 

$ 

2,188 
1,126 
4,212 

$ 

1,419 
1,337 
4,891 

$ 

— 
— 
— 

26 
— 
— 

—  $ 
—  $ 

7,526  $ 
21,234  $ 

7,647 
16,949 

$ 

$ 

—  $ 
4,395  $ 

26 
2,829 

64  $ 

85 

$ 

17,915  $ 

18,800 

$ 

54  $ 

128 

$ 

2,656  $ 

1,540 

—  $ 

122 

(2) 

3 
123  $ 

—  $ 
64 

— 
64  $ 

— 

$ 

—  $ 

— 

$ 

73 

$ 

366 

$ 

2,480 

$ 

1,553 

133 

(5) 

4 
132 

— 

55 

— 

55 

$ 

$ 

$ 

26,985 

(800) 

119 
26,304  $ 

—  $ 

8,372 

17 
8,389  $ 

29,906 

(901) 

136 
29,141 

$ 

— 

$ 

10,321 

20 

10,341 

$ 

— 

— 

— 
73  $ 

— 

$ 

19 

— 
19  $ 

— 

— 

— 
366 

— 
238 

— 
238 

$ 

$ 

$ 

— 

— 

176 
2,656  $ 

2,175 

$ 

— 

— 
2,175  $ 

— 

— 

1 
1,554 

742 

12 

— 
754 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

(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 more information, see 
Note 13 – Commitments and Contingencies. 

(2)  At December 31, 2019 and 2018, loans and leases in the consolidated credit card trust included $10.5 billion and $11.0 billion of seller’s interest. 
(3)  At December 31, 2019 and 2018, all other assets in the consolidated credit card trust included unbilled accrued interest and fees. 
(4)  The retained senior 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. 

Home Equity Loans 
The Corporation retains interests, primarily senior securities, in 
home  equity  securitization  trusts  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. 

During  2019,  2018  and  2017,  new  senior  debt  securities 
issued to third-party investors from the credit card securitization 
trust were $1.3 billion, $4.0 billion and $3.1 billion, respectively. 
At  December  31,  2019  and  2018,  the  Corporation  held 
subordinate securities issued by the credit card securitization trust 
with a notional principal amount of $7.4 billion and $7.7 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  2019,  2018  and  2017,  the  credit  card 
securitization trust issued $202 million, $650 million and $500 
million, respectively, of these subordinate securities. 

transfers  securities,  typically  MBS, 

Resecuritization Trusts 
The  Corporation 
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 $24.4 billion, $22.8 billion and 
$25.1  billion  of  securities  during  2019,  2018  and  2017, 
respectively. Securities transferred into resecuritization VIEs were 
measured at fair value with changes in fair value recorded in market 
making  and  similar  activities  prior  to  the  resecuritization  and, 
accordingly, no gain or loss on sale was recorded. During 2019, 
2018 and 2017, resecuritization proceeds included securities with 
an initial fair value of $5.2 billion, $4.1 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 $3.7 billion and $2.1 billion at December 
31, 2019 and 2018. The weighted-average remaining life of bonds 
held in the trusts at December 31, 2019 was 10.0 years. There 
were no significant write-downs or downgrades of assets or issuers 
during 2019, 2018 and 2017. 

144 144

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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, 
2019 and 2018. 

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 

2019 

2018 

December 31 

4,055  $ 

26,326  $ 

30,381  $ 

4,177  $ 

24,498  $ 

28,675 

2,213  $ 
— 
1,810 
(2) 
81 
4,102  $ 

46  $ 

2 

48  $ 
4,102  $ 

549  $ 

74 
3,214 
(38) 
20,547 
24,346  $ 

—  $ 

5,087 
5,087  $ 
98,491  $ 

2,762  $ 
74 
5,024 
(40) 
20,628 
28,448  $ 

46  $ 

5,089 
5,135  $ 
102,593  $ 

2,335  $ 
— 
1,949 
(2) 
53 
4,335  $ 

152  $ 
7 
159  $ 
4,335  $ 

860  $ 

84 
3,940 
(30) 
18,885 
23,739  $ 

—  $ 

4,231 
4,231  $ 
94,746  $ 

3,195 
84 
5,889 
(32) 
18,938 
28,074 

152 
4,238 
4,390 
99,081 

$ 

$ 

$ 

$ 

$ 
$ 

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 $2.2 billion and $2.1 billion 
at December 31, 2019 and 2018, 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  unconsolidated 
CDOs  totaled  $304  million  and  $421  million  at  December  31, 
2019 and 2018. 

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, 2019 and 2018, the Corporation’s consolidated investment 
VIEs  had  total  assets  of  $104  million  and  $270  million.  The 
Corporation  also  held  investments  in  unconsolidated  VIEs  with 
total assets of $32.4 billion and $37.7 billion at December 31, 
2019  and  2018.  The  Corporation’s  maximum  loss  exposure 
associated with both consolidated and unconsolidated investment 
VIEs totaled $6.4 billion and $7.2 billion at December 31, 2019 
and 2018 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 $1.7 billion and $1.8 billion at December 31, 2019 
and 2018. 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. 

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 $18.9 billion and $17.0 billion at December 31, 
2019  and  2018.  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. 

The  Corporation’s 

in  affordable  housing 
investments 
partnerships,  which  are  reported  in  other  assets  on  the 
Consolidated Balance Sheet, totaled $10.0 billion and $8.9 billion, 
including unfunded commitments to provide capital contributions 
of $4.3 billion and $3.8 billion at December 31, 2019 and 2018. 
The unfunded commitments are expected to be paid over the next 
five  years.  During  2019,  2018  and  2017,  the  Corporation 
recognized tax credits and other tax benefits from investments in 
affordable housing partnerships of $1.0 billion, $981 million and 
$1.0 billion and reported pretax losses in other income of $882 
million, $798 million and $766 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 
a troubled affordable housing project. Such additional investments 
have not been and are not expected to be significant. 

Bank of America 2019  145 
Bank of America 2019  145

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTE 8 Goodwill and Intangible Assets 

Goodwill 
The table below presents goodwill balances by business segment 
and All Other at December 31, 2019 and 2018. The reporting units 
utilized for goodwill impairment testing are the operating segments 
or one level below. 

Goodwill 

(Dollars in millions) 

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

Total goodwill 

December 31 

2019 

2018 

$ 

$ 

30,123  $ 

9,677 
23,923 
5,182 
46 
68,951  $ 

30,123 
9,677 
23,923 
5,182 
46 
68,951 

During 2019, the Corporation completed its annual goodwill 
impairment  test  as  of  June  30,  2019  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. 

Intangible Assets 
At  December  31,  2019  and  2018,  the  net  carrying  value  of 
intangible assets was $1.7 billion and $1.8 billion. At December 
31, 2019  and  2018, intangible  assets  included  $1.6  billion  of 
intangible assets associated with trade names, substantially all 
of  which  had  an  indefinite  life  and,  accordingly,  are  not  being 
amortized. Amortization of intangibles expense was $112 million, 
$538  million  and  $621  million  for  2019,  2018  and  2017, 
respectively. 

NOTE 9 Leases 
The Corporation enters into both lessor and lessee arrangements. 
For more information on lease accounting, see Note 1 – Summary 
of  Significant  Accounting  Principles,  and  on  lease  financing 
receivables, see Note 5 – Outstanding Loans and Leases. 

Lessor Arrangements 
The  Corporation’s  lessor  arrangements  primarily  consist  of 
operating, sales-type and direct financing leases for equipment. 
Lease agreements may include options to renew and for the lessee 
to purchase the leased equipment at the end of the lease term. 
At December 31, 2019, the total net investment in sales-type 
and direct financing leases was $21.9 billion, comprised of $19.3 
billion  in  lease  receivables  and  $2.6  billion  in  unguaranteed 
residuals.  In  certain  cases, the  Corporation  obtains  third-party 
residual  value  insurance  to  reduce  its  residual  asset  risk.  The 
carrying  value  of  residual  assets  with  third-party  residual  value 
insurance for at least a portion of the asset value was $5.8 billion. 
For 2019, total lease income was $1.7 billion, consisting of 
$797 million from sales-type and direct financing leases and $891 
million from operating leases. 

Lessee Arrangements 
The Corporation’s lessee arrangements predominantly consist of 
operating leases for premises and equipment; the Corporation’s 

146 146

Bank of America 2019 

Bank of America 2019

financing leases are not significant. Right-of-use assets were $9.7 
billion  and  lease  liabilities  were  $10.1  billion  at  December  31, 
2019. The weighted-average discount rate used to calculate the 
present value of future minimum lease payments was four percent. 
Lease terms may contain renewal and extension options and 
early termination features. Generally, these options do not impact 
the lease term because the Corporation is not reasonably certain 
that it will exercise the options. The weighted-average lease term 
was 8.2 years at December 31, 2019. 

The table below provides the components of lease cost and 

supplemental information for 2019. 

Lease Cost and Supplemental Information for 2019 

(Dollars in millions) 

Operating lease cost 
Variable lease cost (1) 
Total lease cost (2)  

Right-of-use assets obtained in exchange for new 

operating lease liabilities (3) 

$ 

$ 

$ 

2,085 
498 
2,583 

931 

Operating cash flows from operating leases (4) 
(1)  Primarily consists of payments for common area maintenance and property taxes. 
(2)   Amounts are recorded in occupancy and equipment expense in the Consolidated Statement 

2,009 

of Income. 

(3)   Represents non-cash activity and, accordingly, is not reflected in the Consolidated Statement 

of Cash Flows. 

(4)  Represents cash paid for amounts included in the measurement of lease liabilities. 

Maturity Analysis 
The maturities of lessor and lessee arrangements outstanding at 
December 31, 2019 are presented in the table below based on 
undiscounted cash flows. 

Maturities of Lessor and Lessee Arrangements 

Operating 
Leases 

Lessor 

Sales-type and 
Direct Financing 
Leases (2) 
December 31, 2019 

Lessee (1) 

Operating 
Leases 

$ 

843  $ 
746 
651 
530 
397 
1,057 

4,657  $ 
4,887 
4,259 
3,416 
1,939 
1,910 

1,966 
1,763 
1,502 
1,240 
1,098 
4,225 

$ 

4,224 

21,068 

11,794 

1,756 

1,701 

(Dollars in millions) 

2020 
2021 
2022 
2023 
2024 
Thereafter 
Total undiscounted 

cash flows 

Less: Net present 
value adjustment 

Total (3) 

10,093 
(1)   Excludes $1.5 billion in commitments under lessee arrangements that have not yet commenced 

19,312  $ 

$ 

with lease terms that will begin in 2020. 

(2)   Includes $15.1 billion in commercial lease financing receivables and $4.2 billion  in direct/ 

indirect consumer lease financing receivables. 

(3)   Represents  lease  receivables  for  lessor  arrangements  and  lease  liabilities  for  lessee 

arrangements. 

At December 31, 2018, operating lease commitments under 
lessee arrangements were $2.4 billion, $2.2 billion, $2.0 billion, 
$1.7 billion and $1.3 billion for 2019 through 2023, respectively, 
and $6.2 billion in the aggregate for all years thereafter. These 
amounts include variable lease payments and commitments under 
leases that have not yet commenced, both of which are excluded 
from the lessee maturity analysis presented in the table above. 

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTE 10 Deposits 
The table below presents information about the Corporation’s time deposits of $100 thousand or more at December 31, 2019 and 
2018. The Corporation also had aggregate time deposits of $15.8 billion and $16.4 billion in denominations that met or exceeded 
the Federal Deposit Insurance Corporation (FDIC) insurance limit at December 31, 2019 and 2018. 

Time Deposits of $100 Thousand or More 

(Dollars in millions) 

December 31, 2019 

December 31 
2018 

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 

$ 

16,115  $ 

21,351  $ 

7,108 

4,821 

2,273  $ 
1,105 

39,739  $ 
13,034 

29,505  
10,792  

The scheduled contractual maturities for total time deposits at December 31, 2019 are presented in the table below. 

Contractual Maturities of Total Time Deposits 

(Dollars in millions) 

Due in 2020 
Due in 2021 
Due in 2022 
Due in 2023 
Due in 2024 
Thereafter 

Total time deposits 

U.S. 

Non-U.S. 

Total 

$ 

$ 

56,351  $ 

3,503 
990 
280 
187 
212 
61,523  $ 

12,000  $ 
101 
18 
15 
981 
35 
13,150  $ 

68,351 
3,604 
1,008 
295 
1,168 
247 
74,673 

NOTE 11 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 22 – 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 

2019 

2018 

$ 

$ 

279,610 
281,684 

201,797 
203,063 

24,301 
36,538 

$ 

$ 

1.73% 
n/a 

2.31% 
n/a 

2.42 
n/a 

251,328 
279,350 

193,681 
201,089 

36,021 
52,480 

1.26% 
n/a 

1.80% 
n/a 

2.69 
n/a 

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  $11.7  billion  and  $12.1  billion  at 
December  31, 2019  and  2018.  These  short-term  bank  notes, 
along with Federal Home Loan Bank 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 
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, 2019 and 2018. 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. 

Bank of America 2019  147 
Bank of America 2019  147

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Securities Financing Agreements 

Gross Assets/ 
Liabilities (1) 

Amounts Offset 

Net Balance 
Sheet Amount 

Financial 
Instruments (2) 

Net Assets/ 
Liabilities 

(Dollars in millions) 

Securities borrowed or purchased under agreements to resell (3) 
Securities loaned or sold under agreements to repurchase 
Other (4) 
Total 

434,257  $ 
$ 
324,769 
15,346 

D
(159,660) 
(159,660) 
— 

ecember 31, 2019 
$ 
$ 

274,597  $ 
$ 
165,109 
15,346 

340,115  $ 

(159,660)  $ 

180,455  $ 

$ 
$ 

$ 

December 31, 2018 

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. 

366,274  $ 
$ 
293,853 
19,906 

(106,865)  $ 
(106,865)  $ 

259,409  $ 
186,988  $ 

(106,865)  $ 

206,894  $ 

313,759  $ 

19,906 

$ 
$ 

— 

$ 

(1) 

(244,486)  $ 
(141,482) 
$ 
(15,346) 
(156,828)  $ 

(240,790)  $ 
(176,740)  $ 
(19,906) 

(196,646)  $ 

30,111 
23,627 
— 
23,627 

18,619 
10,248 
— 
10,248 

(2)   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. 

(3)  Excludes repurchase activity of $12.9 billion and $11.5 billion reported in loans and leases on the Consolidated Balance Sheet at December 31, 2019 and 2018. 
(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. 

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 

Overnight and 
Continuous 

30 Days or Less 

After 30 Days 
Through 90 Days 

Greater than 
90 Days (1) 

Total 

$ 

$ 

$ 

$ 

129,455 
18,766 
15,346 
163,567 

139,017 
7,753 
19,906 
166,676 

$ 

$ 

$ 

$ 

December 31, 2019 

122,685  $ 
3,329 
— 
126,014  $ 

25,322  $ 

1,241 
— 
26,563  $ 

December 31, 2018 

81,917  $ 

4,197 
— 
86,114  $ 

34,204  $ 

1,783 
— 
35,987  $ 

21,922 
2,049 
— 
23,971 

21,476 
3,506 
— 
24,982 

$ 

$ 

$ 

$ 

299,384 
25,385 
15,346 
340,115 

276,614 
17,239 
19,906 
313,759 

Securities Sold 
Under Agreements 
to Repurchase 

Securities 
Loaned 

Other 

Total 

$ 

$ 

$ 

$ 

173,533  $ 

10,467 
14,933 
96,576 
3,875 
299,384  $ 

164,664  $ 

11,400 
14,090 
81,329 
5,131 
276,614  $ 

December 31, 2019 
1  $ 

2,014 
20,026 
3,344 
— 
25,385  $ 

December 31, 2018 
—  $ 

2,163 
10,869 
4,207 
— 
17,239  $ 

—  $ 

258 
15,024 
64 
— 
15,346  $ 

—  $ 

287 
19,572 
47 
— 
19,906  $ 

173,534 
12,739 
49,983 
99,984 
3,875 
340,115 

164,664 
13,850 
44,531 
85,583 
5,131 
313,759 

148 148

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
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, 2019 and 2018, the Corporation held restricted 
cash  included  within  cash  and  cash  equivalents  on  the 
Consolidated Balance Sheet of $24.4 billion and $22.6 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. 

NOTE 12 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, 2019 and 2018, and the related contractual rates and maturity dates as of December 31, 2019. 

(Dollars in millions) 

Notes issued by Bank of America Corporation (1) 
Senior notes: 

Fixed 
Floating 

Senior structured notes 
Subordinated notes: 

Fixed 
Floating 

Junior subordinated notes: 

Fixed 
Floating (2) 

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) 

Total other debt 
Total long-term debt 

Weighted-
average Rate 

Interest Rates 

Maturity Dates 

2019 

2018 

December

31 

3.30  % 
1.81 

0.25 - 8.05  % 
0.25 - 6.68 

2020 - 2050  $ 
2020 - 2044 

4.89 
2.74 

6.71 
2.71 

3.34 

2.18 
6.00 

4.98 
1.79 

2.94 - 8.57 
2.56 - 2.89 

6.45 - 8.05 
2.71 

2021 - 2045 
2022 - 2026 

2027 - 2066 
2056 

3.34 

1.99 - 2.51 
6.00 

2023 

2020 - 2041 
2036 

0.01 - 7.72 
1.77 - 1.84 

2020 - 2034 
2020 

140,265  $ 

19,552 
16,941 

21,632 
782 

736 
1 
199,909 

508 

6,519 
1,744 

112 
2,500 
8,373 
402 
20,158 

20,442 
347 
20,789 

$ 

240,856  $ 

120,548 
25,574 
13,815 

20,843 
1,742 

732 
1 
183,255 

— 

1,770 
1,617 

130 
14,751 
10,326 
442 
29,036 

16,483 
618 
17,101 
229,392 

(1) 

(2) 

Includes total loss-absorbing capacity compliant debt. 
Includes amounts related to trust preferred securities. For more information, see Trust Preferred Securities in this Note. 

(3)  Represents liabilities of consolidated VIEs included in total long-term debt on the Consolidated Balance Sheet. 

During 2019, the Corporation issued $52.5 billion of long-term 
debt consisting of $29.3 billion of notes issued by Bank of America 
Corporation, $10.9  billion  of  notes  issued  by  Bank  of  America, 
N.A. and $12.3 billion of other debt, substantially all of which was 
structured liabilities. During 2018, the Corporation issued $64.4 
billion of long-term debt consisting of $30.7 billion of notes issued 
by Bank of America Corporation, $18.7 billion of notes issued by 
Bank of America, N.A. and $15.0 billion of other debt, substantially 
all of which was structured liabilities. 

During  2019,  the  Corporation  had  total  long-term  debt 
maturities  and  redemptions  in  the  aggregate  of  $50.6  billion 
consisting of $21.1 billion for Bank of America Corporation, $19.9 
billion for Bank of America, N.A. and $9.6 billion of other debt. 
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. 

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, 2019 and 
2018, the amount of foreign currency-denominated debt translated 
into U.S. dollars included in total long-term debt was $49.6 billion 
and  $48.6  billion.  Foreign  currency  contracts  may  be  used  to 
convert  certain  foreign  currency-denominated  debt  into  U.S. 
dollars. 

At December 31, 2019, long-term debt of consolidated VIEs in 
the  table  above  included  debt  from  credit  card,  residential 
mortgage, home equity, other VIEs and ABS of $8.4 billion, $217 
million,  $64  million,  $46  million  and  $19  million,  respectively. 
Long-term debt of VIEs is collateralized by the assets of the VIEs. 
For  more  information,  see  Note  7  –  Securitizations  and  Other 
Variable Interest Entities. 

Bank of America 2019  149 
Bank of America 2019  149

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 3.26 percent, 3.55 percent and 1.92 
percent, respectively, at December 31, 2019, and 3.29 percent, 
3.66  percent  and  2.26  percent, respectively, at  December  31, 
2018. 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. 
Debt outstanding of $5.7 billion at December 31, 2019 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. 
The table below shows the carrying value for aggregate annual 
contractual maturities of long-term debt as of December 31, 2019. 
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 (1) 

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 (2) 
Other 

Total Bank of America, N.A. 

Other debt 

Structured liabilities 
Nonbank VIEs (2) 

Total other debt 
Total long-term debt 

2020 

2021 

2022 

2023 

2024 

Thereafter 

Total 

$ 

9,312  $ 

822 
— 
— 
10,134 

3,000 
— 
2,509 
3,099 
134 
8,742 

15,978  $ 
453 
360 
— 
16,791 

3,499 
— 
2 
4,080 
55 
7,636 

14,875  $ 

2,232 
386 
— 
17,493 

— 
— 
3 
1,185 
— 
1,188 

23,045  $ 
288 
— 
— 
23,333 

17,236  $ 
547 
3,213 
— 
20,996 

79,371  $  159,817 
16,941 
12,599 
22,414 
18,455 
737 
737 
199,909 
111,162 

509 
— 
1 
9 
130 
649 

— 
— 
— 
— 
— 
— 

19 
1,744 
97 
— 
83 
1,943 

7,027 
1,744 
2,612 
8,373 
402 
20,158 

5,275 
— 
5,275 
24,151  $ 

1,884 
— 
1,884 
26,311  $ 

1,057 
— 
1,057 
19,738  $ 

1,372 
1 
1,373 
25,355  $ 

745 
— 
745 

20,442 
10,109 
347 
346 
20,789 
10,455 
21,741  $  123,560  $  240,856 

$ 

(1) 

Includes amounts related to trust preferred securities. For more information, see Trust Preferred Securities in this Note. 

(2)  Represents liabilities of consolidated VIEs included in total long-term debt on the Consolidated Balance Sheet. 

Trust Preferred Securities 
At December 31, 2019, trust preferred securities (Trust Securities) 
with a carrying value of $1 million, issued by BAC Capital Trust XV 
(the  Trust),  a  100  percent  owned,  non-consolidated  finance 
subsidiary of the Corporation, were issued and outstanding. The 
Trust  Securities  are  mandatorily  redeemable  preferred  security 
obligations  of  the  Trust.  The  sole  asset  of  the  Trust  is  a  junior 
subordinated  deferrable  interest  note  of  the  Corporation  (the 
Note). 

Periodic  cash  payments  and  payments  upon  liquidation  or 
redemption with respect to Trust Securities are guaranteed by the 
Corporation to the extent of funds held by the Trust (the Preferred 
Securities Guarantee). The Preferred Securities Guarantee, when 
taken together with the Corporation’s other obligations including 
its obligations under the Note, generally will constitute a full and 
unconditional  guarantee,  on  a  subordinated  basis,  by  the 
Corporation of payments due on the Trust Securities. 

NOTE 13 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 $10.6 billion and $10.7 billion at December 31, 
2019  and  2018.  At  December  31, 2019, the  carrying  value  of 
these commitments, excluding commitments accounted for under 
the fair value option, was $829 million, including deferred revenue 
of $16 million and a reserve for unfunded lending commitments 
of $813 million. At December 31, 2018, the comparable amounts 
were $813 million, $16 million and $797 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. 

150 150

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Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The table below includes the notional amount of commitments  which is classified in accrued expenses and other liabilities. For 
of $4.4 billion and $3.1 billion at December 31, 2019 and 2018  more information regarding the Corporation’s loan commitments 
accounted for under the fair value option, see Note 22 – Fair Value 
that are accounted for under the fair value option. However, the 
table excludes cumulative net fair value of $90 million and $169 
Option. 
million at December 31, 2019 and 2018 on these commitments, 

Credit Extension Commitments 

Expire in One 
Year or Less 

Expire After One 
Year Through 
Three Years 

Expire After Three 
Years Through 
Five Years 

Expire After 
Five Years 

Total 

(Dollars in millions)  

Notional amount of credit extension commitments 

Loan commitments (1) 
Home equity lines of credit 
Standby letters of credit and financial guarantees (2) 
Letters of credit (3) 

Legally binding commitments 

Credit card lines (4) 

Total credit extension commitments 

Notional amount of credit extension commitments 

Loan commitments (1) 
Home equity lines of credit 
Standby letters of credit and financial guarantees (2) 
Letters of credit (3) 

Legally binding commitments 

Credit card lines (4) 

Total credit extension commitments 

$ 

$ 

$ 

$ 

97,454  $ 

1,137 
21,311 
1,156 
121,058 
376,067 
497,125  $ 

84,910  $ 

2,578 
22,571 
1,168 
111,227 
371,658 
482,885  $ 

December 31, 2019 

148,000  $ 
1,948 
11,512 
254 
161,714 
— 
161,714  $ 

173,699  $ 
6,351 
3,712 
65 
183,827 
— 
183,827  $ 

December 31, 2018 

142,271  $ 
2,249 
9,702 
84 
154,306 
— 
154,306  $ 

155,298  $ 
3,530 
2,457 
69 
161,354 
— 
161,354  $ 

24,487  $ 
34,134 
408 
25 
59,054 
— 
59,054  $ 

22,683  $ 
34,702 
1,074 
57 
58,516 
— 
58,516  $ 

443,640 
43,570 
36,943 
1,500 
525,653 
376,067 
901,720 

405,162 
43,059 
35,804 
1,378 
485,403 
371,658 
857,061 

(1)  At December 31, 2019 and 2018, $5.1 billion and $4.3 billion of these loan commitments are held in the form of a security. 
(2)   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 $27.9 billion and $8.6 billion at December 31, 2019, and $28.3 billion and $7.1 billion at December 31, 2018. Amounts in the table include consumer SBLCs of $413 million and $372 million 
at December 31, 2019 and 2018. 

(3)  At December 31, 2019 and 2018, included are letters of credit of $1.4 billion and $422 million related to certain liquidity commitments of VIEs. For more information, see Note 7 – Securitizations 

and Other Variable Interest Entities. 
Includes business card unused lines of credit. 

(4) 

Other Commitments 
At  December  31,  2019  and  2018,  the  Corporation  had 
commitments to purchase loans (e.g., residential mortgage and 
commercial real estate) of $86 million and $329 million, which 
upon  settlement  will  be  included  in  loans  or  LHFS,  and 
commitments to purchase commercial loans of $1.1 billion and 
$463 million, which upon settlement will be included in trading 
account assets. 

At  December  31,  2019  and  2018,  the  Corporation  had 
commitments to purchase commodities, primarily liquefied natural 
gas, of $830 million and $1.3 billion, which upon settlement will 
be included in trading account assets. 

At  December  31,  2019  and  2018,  the  Corporation  had 
commitments to enter into resale and forward-dated resale and 
securities borrowing agreements of $97.2 billion and $59.7 billion, 
and  commitments  to  enter  into  forward-dated  repurchase  and 
securities lending agreements of $24.9 billion and $21.2 billion. 
These commitments expire primarily within the next 12 months. 
At  December  31,  2019  and  2018,  the  Corporation  had  a 
commitment to originate or purchase up to $3.3 billion and $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. 

Other Guarantees 

$9.8 billion. At December 31, 2019 and 2018, the Corporation’s 
maximum  exposure  related  to  these  guarantees  totaled  $1.1 
billion  and  $1.5  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. 

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, 2019 and 2018, 
the notional amount of these guarantees totaled $7.3 billion and 

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  a  merchant  processor  fails  to  meet  its  obligation  regarding 

Bank of America 2019  151 
Bank of America 2019  151

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
disputed transactions, then the Corporation could be held liable. 
In  2019  and  2018,  the  sponsored  entities  processed  $916.6 
billion and $874.3 billion of transactions and recorded losses of 
$24 million and $31 million. 

At  December  31,  2019  and  2018,  the  maximum  potential 
exposure for sponsored transactions totaled $384.2 billion and 
$348.1  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. 

A significant portion of the Corporation's merchant processing 
activity is performed by a joint venture, formed in 2009, in which 
the  Corporation  holds  a  49  percent  ownership  interest.  The 
carrying value of the Corporation’s investment was $640 million 
and $2.8 billion at December 31, 2019 and 2018. The joint venture 
is accounted for as an equity method investment and reported in 
All Other. On July 29, 2019, the Corporation gave notice to the 
joint venture partner of the termination of the joint venture upon 
the conclusion of its current term in June 2020. As a result, the 
Corporation  incurred  a  non-cash,  pretax  impairment  charge  in 
2019 of $2.1 billion, included in other general operating expense. 

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 Corporation 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 payments under 
these agreements are approximately $8.7 billion and $5.9 billion 
at December 31, 2019 and 2018. The estimated maturity dates 
of these obligations extend up to 2049. The Corporation has made 

no  material  payments  under  these  guarantees.  For  more 
information  on  maximum  potential  future  payments  under  VIE-
related liquidity commitments, see Note 7 – Securitizations and 
Other Variable Interest Entities. 

During 2019, the Corporation recognized a loss of $210 million 
in other income under its indemnity obligation in connection with 
the  2017  sale  of  its  non-U.S.  consumer  credit  card  business 
(payment protection insurance). 

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. 

Guarantees of Certain Long-term Debt 
The Corporation, as the parent company, fully and unconditionally 
guarantees  the  securities  issued  by  BofA  Finance  LLC,  a  100 
percent  owned  finance  subsidiary  of  the  Corporation,  and 
effectively provides for the full and unconditional guarantee of trust 
securities  issued  by  certain  statutory  trust  companies  that  are 
100 percent owned finance subsidiaries of the Corporation. 

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. 

The  notional  amount  of  unresolved  repurchase  claims  at 
December 31, 2019 and 2018 was $10.7 billion and $14.4 billion. 
These balances included $3.7 billion and $6.2 billion at December 
31, 2019 and 2018 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 for 
2019 also includes $1.6 billion of repurchase claims related to a 
single monoline insurer and is the subject of litigation. 

During  2019,  the  Corporation  received  $461  million  in  new 
repurchase claims that were not time-barred. During 2019, $4.2 
billion in claims were resolved, including $2.1 billion of claims that 
were deemed time-barred. 

152 152

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reserve and Related Provision 
The reserve for representations and warranties obligations and 
corporate  guarantees  was  $1.8  billion  and  $2.0  billion  at 
December  31,  2019  and  2018  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, is based on our experience in previous 
negotiations, and is subject to judgment, a variety of assumptions, 
and known or unknown uncertainties. 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  to  the  Corporation's  financial 
condition and liquidity. See Litigation and Regulatory Matters in 
this Note below for the Corporation's combined range of possible 
loss in excess of the reserve for representations and warranties, 
and the accrued liability for litigation. 

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 $681 million and $469 million was recognized in 2019 
and 2018. 

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 
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 $1.6 billion in excess of the accrued liability, if any. 

The  estimated  range  of  possible  loss,  as  well  as  the 
Corporation's accrued liability, is based upon currently available 
information  and  is  subject  to  significant  judgment, a  variety  of 
assumptions and known and unknown uncertainties. The matters 
underlying the estimated range of possible loss and liability accrual 
are unpredictable and will change from time to time, and actual 
losses  may  vary  significantly  from  the  current  estimate  and 
accrual. The estimated range of possible loss does not represent 
the Corporation’s maximum loss exposure. 

taking 

into  account  accrued 

Information  is  provided  below  regarding  the  nature  of  the 
litigation  and  associated  claimed  damages.  Based  on  current 
knowledge,  and 
liabilities, 
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 condition 
or liquidity of the Corporation. However, in light of the significant 
judgment, variety  of  assumptions  and  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 business or results 
of  operations  for  any  particular  reporting  period,  or  cause 
significant reputational harm. 

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.  These  actions  are  at  various  procedural  stages  with 
material developments provided below. 

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 
the  First 
summary 
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. 

Bank of America 2019  153 
Bank of America 2019  153

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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, 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 the 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  and  its 
Enforcement  Section  is  also  conducting  a  parallel  investigation 
related to the same alleged reporting error. 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 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, 
named Visa, MasterCard, the Corporation, BANA and other banks 
as  defendants.  Plaintiffs  alleged  antitrust  claims  and  sought 
compensatory and treble damages as well as injunctive relief. 

In 2018, defendants reached a settlement of the putative Rule 
23(b)(3) damages class. Defendants agreed to pay an additional 
amount  to  participating  class  members  by  contribution  to  the 
escrow  fund  established  as  part  of  the  settlement  previously 
rejected by the U.S. Court of Appeals for the Second Circuit. The 

Corporation’s additional contribution was not material. The District 
Court granted final approval of the settlement in December 2019. 
Beginning  in  January  2020,  a  number  of  class  members  who 
objected to the settlement appealed to the U.S. Court of Appeals 
for the Second Circuit. 

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  of,  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. 

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,Commodity Exchange Act, 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, Commodity Exchange 
Act  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 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, Countrywide and certain affiliates are named as 
defendants in two consolidated putative class action lawsuits filed 
in  the  U.S.  District  Court  for  the  Central  District  of  California 
(Waldrup and Williams, et al.). Plaintiffs allege that Countrywide 
and 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  assert  a  RICO  claim  and  seek, among  other  forms  of 
relief, compensatory and treble damages. On February 8, 2018, 

154 154

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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. 

On  January  21,  2020,  the  parties  agreed  to  resolve  the 
litigation for an amount that is not material to the Corporation, and 
which was fully accrued as of December 31, 2019. The agreement 
is subject to court approval. 

U.S. Bank - Harborview and SURF/OWNIT Repurchase 
Litigation 
Beginning in 2011, U.S. Bank, National Association (U.S. Bank), 
as trustee for the HarborView Mortgage Loan Trust 2005-10 and 
various  SURF/OWNIT  RMBS  trusts  filed  complaints  against  the 
Corporation, Countrywide entities, Merrill Lynch entities and other 
affiliates  in  New  York  Supreme  Court  alleging  breaches  of 
representations  and  warranties.  The  defendants  and  certain 
certificate-holders  in  the  trusts  agreed  to  settle  the  respective 
matters  in  amounts  not  material  to  the  Corporation, subject  to 
acceptance by U.S. Bank. The litigations have been stayed pending 
finalization of the settlements. 

NOTE 14 Shareholders’ Equity 

Common Stock 

Declared Quarterly Cash Dividends on Common Stock (1) 

Declaration Date 

Record Date 

Payment Date 

January 29, 2020 
October 22, 2019 
July 25, 2019 
April 24, 2019 
January 30, 2019 
(1) 

March 6, 2020 
December 6, 2019 
September 6, 2019 
June 7, 2019 
March 1, 2019 

March 27, 2020 
December 27, 2019 
September 27, 2019 
June 28, 2019 
March 29, 2019 

In 2019, and through February 19, 2020. 

Dividend 
Per Share 
0.18 
$ 
0.18 
0.18 
0.15 
0.15 

The cash dividends paid per share of common stock were $0.66, 
$0.54 and $0.39 for 2019, 2018 and 2017, respectively. 

The following table summarizes common stock repurchases 

during 2019, 2018 and 2017. 

Common Stock Repurchase Summary 

(in millions) 
Total share repurchases, including CCAR 

capital plan repurchases 

2019 

2018 

2017 

956 

676 

509 

Purchase price of shares repurchased and 

retired 
CCAR capital plan repurchases 
Other authorized repurchases 
   Total shares repurchased 

$ 25,644  $16,754  $  9,347 
3,467
$ 28,144  $20,094  $12,814 

3,340 

2,500 

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 Corporation’s Board of Directors (Board) 
authorized  the  repurchase  of  approximately  $20.6  billion  in 
common stock from July 1, 2018 through June 30, 2019, which 
included  approximately  $600  million  in  repurchases  to  offset 
shares awarded under equity-based compensation plans during 
the same period. On February 7, 2019, following approval by the 
Federal  Reserve,  the  Board  authorized  the  repurchase  of  an 
additional $2.5 billion of common stock by June 30, 2019. 

On  June  27,  2019,  following  the  Federal  Reserve's  non-
objection to the Corporation's 2019 CCAR capital plan, the Board 
authorized  the  repurchase  of  approximately  $30.9  billion  in 

common stock from July 1, 2019 through June 30, 2020, which 
includes  approximately  $900  million  in  repurchases  to  offset 
shares awarded under equity-based compensation plans during 
the same period. 

During 2019, the Corporation repurchased 956 million shares 
of common stock in connection with the Board's 2018 and 2019 
repurchase authorizations, which reduced shareholders’ equity by 
$28.1 billion. 

In  connection  with  employee  stock  plans,  in  2019,  the 
Corporation issued 91 million shares of its common stock and, to 
satisfy tax withholding obligations, repurchased 35 million shares 
of its common stock. At December 31, 2019, the Corporation had 
reserved 579 million unissued shares of common stock for future 
issuances  under  employee  stock  plans,  convertible  notes  and 
preferred stock. 

Preferred Stock 
The cash dividends declared on preferred stock were $1.4 billion, 
$1.5  billion  and  $1.6  billion  for  2019,  2018  and  2017, 
respectively. 

On June 20, 2019, the Corporation issued 40,000 shares of 
5.125%  Fixed-to-Floating  Rate  Non-Cumulative  Preferred  Stock, 
Series JJ for $1.0 billion. On June 25, 2019, the Corporation issued 
55,900 shares of 5.375% Non-Cumulative Preferred Stock, Series 
KK  for  $1.4  billion.  On  September  17,  2019,  the  Corporation 
issued 52,400 shares of 5.000% Non-Cumulative Preferred Stock, 
Series LL for $1.3 billion. Additionally, on January 24, 2020, the 
Corporation  issued  44,000  shares  of  4.300%  Fixed-to-Floating 
Rate Non-Cumulative Preferred Stock, Series MM for $1.1 billion. 
In 2019, the Corporation fully redeemed Series V and Series 
W  preferred  stock  for  $2.6  billion.  Additionally, on  January  27, 
2020, the Corporation fully redeemed Series Y preferred stock for 
$1.1 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 

Bank of America 2019  155 
Bank of America 2019  155

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
of 30 consecutive trading days, the closing price of common stock 
exceeds 130 percent of the then-applicable conversion price of  will still pay any accrued dividends payable.  
the Series L Preferred Stock. If a conversion of Series L Preferred 
Stock occurs at the option of the holder, subsequent to a dividend 

stock outstanding at December 31, 2019.  

The table below presents a summary of perpetual preferred  

record date but prior to the dividend payment date, the Corporation  

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) 

7% Cumulative 
Redeemable 

June 
1997 

Floating Rate Non-
Cumulative 

November 
2006 

Floating Rate Non-
Cumulative 

Adjustable Rate Non-
Cumulative 

March 
2012 

March 
2012 

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 

Series B 

Series E (2) 

Series F 

Series G 

Series L 

7.25% Non-
Cumulative 
Perpetual 
Convertible 

Series T 

6% Non-cumulative 

January 
2008 

September 
2011 

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 

Series U (4) 

Fixed-to-Floating 
Rate Non-Cumulative 

May 
2013 

40,000 

25,000 

1,000 

Series X (4) 

Series Y (2) 

Fixed-to-Floating 
Rate Non-Cumulative 

September 
2014 

6.500% Non-
Cumulative 

January      
2015 

80,000 

25,000 

2,000 

44,000 

25,000 

1,100 

6.500% 

1.63 

Series Z (4) 

Fixed-to-Floating 
Rate Non-Cumulative 

October 
2014 

56,000 

25,000 

1,400 

5.2% to, but excluding, 
6/1/23; 3-mo. LIBOR + 
313.5 bps thereafter 

6.250% to, but excluding, 
9/5/24; 3-mo. LIBOR + 
370.5 bps thereafter 

52.00 

52 

62.50 

125 

72 

91 

65.00 

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 AA (4) 

Series CC (2) 

Series DD (4) 

Series EE (2) 

Series FF (4) 

Series GG (2) 

Series HH (2) 

Series JJ (4) 

Series KK (2) 

Series LL (2) 

Series 1 (5) 

Series 2 (5) 

Series 4 (5) 

Series 5 (5) 

Fixed-to-Floating 
Rate Non-Cumulative 

March 
2015 

6.200% Non-
Cumulative 

January      
2016 

Fixed-to-Floating 
Rate Non-Cumulative 

6.000% Non-
Cumulative 

Fixed-to-Floating 
Rate Non-Cumulative 

6.000% Non-
Cumulative 

5.875% Non-
Cumulative 

Fixed-to-Floating 
Rate Non-Cumulative 

5.375% Non-
Cumulative 

March 
2016 

April 
2016 

March 
2018 

May 
2018 

July 
2018 

June 
2019 

June 
2019 

5.000% Non-
Cumulative 

September 
2019 

Floating Rate Non-
Cumulative 

November 
2004 

Floating Rate Non-
Cumulative 

March 
2005 

Floating Rate Non-
Cumulative 

November 
2005 

Floating Rate Non-
Cumulative 

March 
2007 

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 

68 

63 

54 

94,000 

25,000 

2,350 

5.875% to, but excluding, 
3/15/28; 3-mo. LIBOR + 
293.1 bps thereafter 

58.75 

138 

54,000 

25,000 

1,350 

6.000% 

1.50 

34,160 

25,000 

854 

5.875% 

1.47 

40,000 

25,000 

1,000 

5.125% to, but excluding, 
6/20/24; 3-mo. LIBOR + 
329.2 bps thereafter 

25.63 

55,900 

25,000 

1,398 

5.375% 

0.67 

52,400 

25,000 

1,310 

5.000% 

0.31 

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 

422 

3-mo. LIBOR + 50 bps (3) 

0.82 

0.81 

1.01 

1.01 

81 

50 

26 

38 

16 

3 

10 

9 

17 

On or after 
June 1, 2023 

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 
June 20, 2024 

On or after 
June 25, 2024 

On or after 
September 17, 2024 

On or after 
November 28, 2009 

On or after 
November 28, 2009 

On or after 
November 28, 2010 

On or after 
May 21, 2012 

Issuance costs and certain adjustments 

Total 

3,887,440 

(357) 

$  23,401 

(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 

156 156

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTE 15 Accumulated Other Comprehensive Income (Loss) 
The table below presents the changes in accumulated OCI after-tax for 2019, 2018 and 2017. 

(Dollars in millions) 

Balance, December 31, 2016 

Net change 

Balance, December 31, 2017 

Accounting change related to certain tax effects 
Cumulative adjustment for hedge accounting change 
Net change 

Balance, December 31, 2018 

Net change 

Balance, December 31, 2019 

Debt Securities 

Debit Valuation 
Adjustments 

Derivatives 

Employee 
Benefit Plans 

Foreign 
Currency 

$ 

$ 

$ 

$ 

(1,267)  $ 
61 
(1,206)  $ 
(393) 
— 
(3,953) 
(5,552)  $ 
5,875 

323  $ 

(767)  $ 
(293) 
(1,060)  $ 
(220) 
— 
749 
(531)  $ 
(963) 
(1,494)  $ 

(895)  $ 

64 

(831)  $ 
(189) 
57 
(53) 
(1,016)  $ 
616 
(400)  $ 

(3,480)  $ 
288 
(3,192)  $ 
(707) 
— 
(405) 
(4,304)  $ 
136 
(4,168)  $ 

(879)  $ 

86 

(793)  $ 
239 
—  
(254) 
(808)  $ 
(86) 
(894)  $ 

Total 

(7,288) 
206 
(7,082) 
(1,270)  
57 
(3,916)  
(12,211) 
5,578 
(6,633) 

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 2019, 2018 and 2017. 

(Dollars in millions) 

Debt 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 increase (decrease) in fair value 
Reclassifications into earnings: 

Net interest income 
Compensation and benefits 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 (3) 

Net change 

Pretax 

Tax 
effect 

2019 

After-
tax 

Pretax 

Tax 
effect 

2018 

After-
tax 

Pretax 

Tax 
fect 

ef

2

017 

After-
tax 

$  8,020  $  (2,000)  $  6,020  $ (5,189)  $  1,329  $ (3,860)  $ 

(193) 
7,827 

48 
(1,952) 

(145) 
5,875 

(123) 
(5,312) 

30 
1,359 

(93) 
(3,953) 

240  $ 
(304) 
(64) 

(1,276) 
18 
(1,258) 

289 
6 
295 

(987) 
24 
(963) 

952 
26 
978 

(224) 
(5) 
(229) 

728 
21 
749 

(490) 
42 
(448) 

14  $ 

111 
125 

171 
(16) 
155 

254 
(193) 
61 

(319) 
26 
(293) 

692 

(156) 

536 

(232) 

74 

(158) 

(50) 

1 

(49) 

104 
2 
106 
798 

41 
150 
3 
194 

(13) 
(110) 
(123) 

(26) 
— 
(26) 
(182) 

(21) 
(36) 
(1) 
(58) 

(52) 
89 
37 

78 
2 
80 
616 

20 
114 
2 
136 

(65) 
(21) 
(86) 

165 
(27) 
138 
(94) 

(703) 
171 
11 
(521) 

(8) 
(149) 
(157) 

(40) 
7 
(33) 
41 

164 
(46) 
(2) 
116 

(195) 
98 
(97) 

125 
(20) 
105 
(53) 

(539) 
125 
9 
(405) 

(203) 
(51) 
(254) 

327 
(148) 
179 
129 

223 
179 
3 
405 

(122) 
56 
(66) 
(65) 

(55) 
(61) 
(1) 
(117) 

(439) 
(606) 
(1,045) 

430 
701 
1,131 

205 
(92) 
113 
64 

168 
118 
2 
288 

(9) 
95 
86 
206 

Total other comprehensive income (loss) 

$  7,438  $  (1,860)  $  5,578  $ (5,106)  $  1,190  $ (3,916)  $ (1,023)  $  1,229  $ 

(1)  Reclassifications of pretax debt securities and DVA 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. 
(3)  Reclassifications of pretax debt securities, DVA and foreign currency (gains) losses are recorded in other income in the Consolidated Statement of Income. 

Bank of America 2019  157 
Bank of America 2019  157

   
 
 
 
 
 
 
NOTE 16 Earnings Per Common Share 
The calculation of EPS and diluted EPS for 2019, 2018 and 2017 is presented below. For more information on the calculation of EPS, 
see Note 1 – Summary of Significant Accounting Principles. 

$ 

$ 

$ 

$ 

$ 

2019 

2018 

2017 

27,430  $ 
(1,432) 
25,998  $ 
9,390.5 
2.77 

$ 

28,147  $ 
(1,451) 
26,696  $ 

10,096.5 
2.64 

25,998 
— 
25,998 
9,390.5 
52.4 
9,442.9 

$ 

$ 

26,696 
— 
26,696 
10,096.5 
140.4 
10,236.9 

$ 

2.75  $ 

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 

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, 2019 and 
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. 

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, 2019 and 
2018 for the Corporation and BANA. 

(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. 

For 2019, 2018 and 2017, 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 
and 2017, average options to purchase four million and 21 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. For 2017, 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 2019, 
2018 and 2017, average warrants to purchase three million, 136 
million and 143 million shares of common stock, respectively, were 
included in the diluted EPS calculation under the treasury stock 
method. Substantially all of these warrants were exercised on or 
before their expiration date of January 16, 2019. 

NOTE 17 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 

158 158

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Regulatory Capital under Basel 3 

(Dollars in millions, except as noted) 

Risk-based capital metrics: 

Common equity tier 1 capital 
Tier 1 capital 
Total capital (3) 
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) (4) 
Tier 1 leverage ratio 

SLR leverage exposure (in billions) 
SLR 

Risk-based capital metrics: 

Common equity tier 1 capital 
Tier 1 capital 
Total capital (3) 
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) (4) 
Tier 1 leverage ratio 

SLR leverage exposure (in billions) 
SLR 

Bank of America Corporation 

Bank of America, N.A. 

Standardized 
Approach 

Advanced 
Approaches 

Regulatory 
Minimum (1) 

Standardized 
Approach 

Advanced 
Approaches 

Regulatory 
Minimum (2) 

December 31, 2019 

$  166,760 
188,492 
221,230 
1,493 

$  166,760 
188,492 
213,098 
1,447 

$  154,626 
154,626 
166,567 
1,241 

11.2% 
12.6 
14.8 

11.5% 
13.0 
14.7 

9.5% 

11.0 
13.0 

12.5% 
12.5 
13.4 

$  154,626 
154,626 
158,665 
991 
15.6% 
15.6 
16.0 

7.0% 
8.5 
10.5 

$ 

2,374 

$ 

2,374 

$ 

1,780 

$ 

1,780 

7.9% 

7.9% 

4.0 

8.7% 

8.7% 

5.0 

$ 

2,946 

$ 

2,177 

6.4% 

5.0 

7.1% 

6.0 

December 31, 2018 

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

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

$  149,824 
149,824 
161,760 
1,195 

11.6% 
13.2 
15.4 

11.9% 
13.4 
15.1 

8.25% 
9.75 
11.75 

12.5% 
12.5 
13.5 

$  149,824 
149,824 
153,627 
959 
15.6% 
15.6 
16.0 

6.5% 
8.0 
10.0 

$ 

2,258 

$ 

2,258 

$ 

1,719 

$ 

1,719 

8.4% 

8.4% 

4.0 

8.7% 

8.7% 

5.0 

$ 

2,791 

$ 

2,112 

6.8% 

5.0 

7.1% 

6.0 

(1)   The capital conservation buffer and global systemically important bank surcharge were 2.5 percent at December 31, 2019 and 1.875 percent at December 31, 2018. The countercyclical capital 

buffer for both periods was zero. The SLR minimum includes a leverage buffer of 2.0 percent. 

(2)   Risk-based capital regulatory minimums at December 31, 2019 are the minimum ratios under Basel 3 including a capital conservation buffer of 2.5 percent. The regulatory minimums for the leverage 

ratios as of both period ends and risk-based capital ratios as of December 31, 2018 are the percent required to be considered well capitalized under the PCA framework. 

(3)  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. 
(4)  Reflects total average assets adjusted for certain Tier 1 capital deductions. 

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, 2019 and 
2018, 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  $14.6  billion  and  $11.4  billion  for 
2019 and 2018. At December 31, 2019 and 2018, the Corporation 
had cash and cash equivalents in the amount of $6.3 billion and 
$5.8 billion, and securities with a fair value of $14.7 billion and 
$16.6 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 more information, see Note 11 
–  Federal  Funds  Sold  or  Purchased,  Securities  Financing 
Agreements,  Short-term  Borrowings  and  Restricted  Cash.  In 

addition, at December 31, 2019 and 2018, the Corporation had 
cash deposited with clearing organizations of $7.6 billion and $8.1 
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 2019, the Corporation received dividends of $20.5 billion 
from BANA and $215 million from Bank of America California, N.A. 
In addition, BANA returned capital of $8.0 billion to the Corporation 
in 2019. 

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  2020,  BANA  can  declare  and  pay  dividends  of 
approximately $9.4 billion to the Corporation plus an additional 
amount equal to its retained net profits for 2020 up to the date 
of any such dividend declaration. Bank of America California, N.A. 
can pay dividends of $94 million in 2020 plus an additional amount 
equal to its retained net profits for 2020 up to the date of any 
such dividend declaration. 

Bank of America 2019  159 
Bank of America 2019  159

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTE 18 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 
2019 or 2018. 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. 

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. 

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, 2019 and 2018. 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  decreases  in  the 
weighted-average discount rates in 2019 resulted in increases to 
the PBO of approximately $2.2 billion at December 31, 2019. 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. Significant gains and losses related to changes in the 
PBO for 2019 and 2018 primarily resulted from changes in the 
discount rate. 

Pension and Postretirement Plans (1) 

(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 

2019 

2018 

2019 

2018 

2019 

2018 

2019 

2018 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

18,178 
3,187 
— 
— 
— 
(1,090) 
 n/a
 n/a
20,275 

14,144 
— 
593 
— 
— 
— 
1,714 
(1,090) 
 n/a
 n/a
15,361 

4,914 
— 
4,914 

15,361 
4,914 
— 
15,361 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

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 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

2,461 
273 
20 
1 
(42) 
(108) 
 n/a
91 
2,696 

2,589 
17 
65 
1 
2 
(42) 
288 
(108) 
 n/a
75 
2,887 

364 
(555) 
(191) 

2,841 
(145) 
46 
2,887 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

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 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

2,584 
228 
91 
— 
— 
(237) 
 n/a
 n/a
2,666 

2,779 
1 
113 
— 
— 
— 
263 
(237) 
 n/a
 n/a
2,919 

733 
(986) 
(253) 

2,919 
(253) 
— 
2,919 

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 

$ 

$ 

$ 

$ 

$

$ 

$ 

252 
5 
24 
103 
— 
(185) 
— 
 n/a
199 

928 
5 
38 
103 
— 
— 
99 
(185) 
— 
1 
989 

— 
(790) 
(790) 

 n/a 
 n/a 
 n/a 
989 

$ 

$ 

$ 

$ 

$

$ 

$ 

3.32% 
 n/a
5.06 

4.32% 
 n/a 
5.18 

1.81% 
4.10 
1.53 

2.60% 
4.49 
1.47 

3.20% 
4.00 
4.52 

4.26% 
4.00
4.50 

3.27% 
 n/a 
n/a 

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 

(1)  The measurement date for all of the above plans was December 31 of each year reported. 
n/a = not applicable 

160 160

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The Corporation’s estimate of its contributions to be made to  minimum funding amount required by the Employee Retirement 

the Non-U.S. Pension Plans, Nonqualified and Other Pension Plans, 
and Postretirement Health and Life Plans in 2020 is $21 million, 
$92 million and $15 million, respectively. The Corporation does 
not expect to make a contribution to the Qualified Pension Plan in 
2020. It is the policy of the Corporation to fund no less than the 

Income Security Act of 1974 (ERISA). 

Pension Plans with ABO and PBO in excess of plan assets as 
of December 31, 2019 and 2018 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 

2019 

2018 

2019 

2018 

$ 

744  $ 
720 
191 

615  $ 
605 
173 

988  $ 
988 
1 

950 
949 
1 

Qualified Pension Plan 
2018 

2017 

2019 

Non-U.S. Pension Plans 
2018 

2017 

2019 

$

— 
593 
(1,088) 
135 
— 

$ 

— $ 

563 
(1,136) 
147 
—

$ 

— 
606 
(1,068) 
154 
— 

$ 

(360)  $ 

(426)  $ 

(308)  $ 

$ 

17 
65 
(99) 
6 
4 
(7)  $ 

$ 

19
65 
(126) 
10 
12 
(20)  $ 

4.32% 
6.00 
 n/a 

3.68% 
6.00 
n/a 

4.16% 
6.00 
n/a 

2.60% 
4.13 
4.49 

2.39% 
4.37 
4.31 

24 
72 
(136) 
8 
(7) 
(39) 

2.56% 
4.73 
4.51 

Nonqualified and 
Other Pension Plans 

Postretirement Health 
and Life Plans 

2019 

2018 

2017 

2019 

2018 

2017 

$

$ 

1 
113 
(95) 
34 
— 
53 

$ 

$ 

1
105 
(84) 
43 
—
65

$ 

$ 

1 
117 
(95) 
34 
— 
57 

$

$ 

5 
38 
(5) 
(24) 
(2) 
12 

$ 

$ 

6
36 
(6) 
(27) 
(3) 
6

$ 

$ 

6 
43 
— 
(21) 
4 
32 

4.26% 
3.73 
4.00 

3.58% 
3.19 
4.00 

4.01% 
3.50 
4.00

4.25% 
2.00 
 n/a

3.58% 
2.00
 n/a

3.99% 
 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  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 2020, 
reducing in steps to 5.00 percent in 2026 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 had a significant impact 
on the net periodic benefit cost for 2019. 

Bank of America 2019  161 
Bank of America 2019  161

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Pretax Amounts included in Accumulated OCI and OCI 

(Dollars in millions) 

Net actuarial loss (gain) 
Prior service cost (credits) 

Qualified 
Pension Plan 

Non-U.S. 
Pension Plans 

Nonqualified 
and Other 
Pension Plans 

Postretirement 
Health and 
Life Plans 

Total 

2019 

2018 

2019 

2018 

2019 

2018 

2019 

2018 

2019 

2018 

$ 3,865  $ 4,386  $  559  $  454  $ 1,008  $  912  $ 

— 

— 

18 

18 

— 

— 

48  $ 
(6) 
42  $ 

(75)  $ 5,480  $ 5,677 
12 
9 
(84)  $ 5,492  $ 5,686 

(9) 

Amounts recognized in accumulated OCI 

$ 3,865  $ 4,386  $  577  $  472  $ 1,008  $  912  $ 

Current year actuarial loss (gain) 
Amortization of actuarial gain (loss) and 

prior service cost 

Current year prior service cost (credit) 

Amounts recognized in OCI 

$  (385)  $  541  $  110  $  270  $  130  $ 

(59)  $ 

99  $ 

(73)  $ 

(46)  $  679 

(135) 

(147) 

— 

— 

(7) 

2 

(11) 

13 

$  (520)  $  394  $  105  $  272  $ 

(34) 

(43) 

26 

30 

(150) 

(171) 

— 
96  $  (102)  $  125  $ 

— 

— 

2 
13 
— 
(43)  $  (194)  $  521 

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 plans' 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  2020  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  $315  million  (1.55 
percent of total plan assets) and $221 million (1.22 percent of 
total plan assets) at December 31, 2019 and 2018. 

2020 Target Allocation 

Asset Category 

Equity securities 
Debt securities 
Real estate 
Other 

Percentage 

Qualified 
Pension Plan 

Non-U.S. 
Pension Plans 

Nonqualified 
and Other 
Pension Plans 

15 - 50% 
45 - 80% 
0 - 10% 
0 - 5% 

5 - 30% 
40 - 70% 
0 - 15% 
10 - 40% 

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 21 – Fair Value Measurements. 
Combined plan investment assets measured at fair value by level and in total at December 31, 2019 and 2018 are summarized in the 
Fair Value Measurements table. 

162 162

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Fair Value Measurements 

(Dollars in millions)  

Cash and short-term investments 

Level 1 

Level 3 
Level 2 
December 31, 2019 

Total 

Level 1 

Level 3 
Level 2 
December 31, 2018 

Total 

Money market and interest-bearing cash 
Cash and cash equivalent commingled/mutual funds 

$ 

1,426
— 

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 

4,403 
— 
— 
748 
804 

4,655 
147 
91

$ 

— $ 

250 

890 
3,676 
2,684 
1,015 
1,439 

— 
1,355 
— 

— $ 
— 

1,426  $ 

250 

1,530
— 

8 
— 
— 
— 
— 

— 
— 
—

5,301 
3,676 
2,684 
1,763 
2,243 

4,655 
1,502 
91 

3,637 
— 
— 
539 
933 

4,414 
288 
104 

$ 

— $ 

644 

805 
2,852 
2,119 
961 
1,177 

— 
1,275 
— 

— $ 
— 

1,530 
644 

9 
— 
— 
— 
— 

— 
— 
—

4,451 
2,852 
2,119 
1,500 
2,110 

4,414 
1,563 
104 

Private real estate 
Real estate commingled/mutual funds 

5 
898 
240 
1,045 
1,569  $  23,475 
(1)   Other investments include commodity and balanced funds of $233 million and $305 million, insurance annuity contracts of $614 million and $562 million and other various investments of $190 

1,661  $  25,836  $  11,538  $  10,368  $ 

Limited partnerships 
Other investments (1) 

Total plan investment assets, at fair value 

— 
945 
263 
1,037 

$  12,285  $  11,890  $ 

— 
13 
158 
364 

5 
885 
82 
588 

—
18 
173 
390 

—
927 
90 
636 

—
— 
— 
93 

—
— 
— 
11 

million and $178 million at December 31, 2019 and 2018. 

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 2019, 2018 and 2017. 

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 

2019 

9  $ 

—  $ 

5 
885 
82 
588 

1,569  $ 

9  $ 

93 
831 
85 
74 
1,092  $ 

10  $ 

150 
748 
38 
83 
1,029  $ 

— 
33 
— 
6 

39  $ 

2018 

—  $ 

(7) 
52 
(12) 
— 
33  $ 

2017 

—  $ 

8 
63 
14 
5 

90  $ 

$ 

$ 

$ 

$ 

$ 

$ 

(1)  $ 

(5) 
9 
8 
42 
53  $ 

8 

— 
927 
90 
636 
1,661 

—  $ 

9 

(81) 
2 
9 
514 
444  $ 

5 
885 
82 
588 
1,569 

(1)  $ 

9 

(65) 
20 
33 
(14) 
(27)  $ 

93 
831 
85 
74 
1,092 

Bank of America 2019  163 
Bank of America 2019  163

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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) 

2020 
2021 
2022 
2023 
2024 
2025 - 2029 
(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. 

917  $ 
926 
927 
917 
924 
4,409 

$ 

108  $ 
107 
110 
116 
126 
594 

242  $ 
245 
232 
230 
223 
1,011 

83 
80 
77 
74 
72 
313 

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 2019, 2018 and 2017 related to the 
qualified defined contribution plans. At December 31, 2019 and 
2018, 189  million  and  212  million  shares  of  the  Corporation’s 
common stock were held by these plans. Payments to the plans 
for dividends on common stock were $133 million, $115 million 
and $86 million in 2019, 2018 and 2017, respectively. 

Certain  non-U.S.  employees  are  covered  under  defined 
contribution  pension  plans  that  are  separately  administered  in 
accordance with local laws. 

NOTE 19 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). On April 24, 2019, Bank 
of America's shareholders approved an amendment to the KEEP 
to increase the number of shares available for grant by 150 million. 
Subsequent  to  this  amendment,  600  million  shares  of  the 
Corporation’s common stock are authorized to be used for grants 
of awards. 

During 2019 and 2018, the Corporation granted 94 million and 
71 million RSU awards to certain employees under the KEEP. These 
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 
2019 and 2018, 71 million and 63 million will vest predominantly 
over  three  years  with  most  vesting  occurring  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. For RSUs granted to employees who are retirement 
eligible, the awards are deemed authorized as of the beginning of 
the year preceding the grant date when the incentive award plans 
are  generally  approved.  As  a  result,  the  estimated  value  is 
expensed  ratably  over  the  year  preceding  the  grant  date. 
Additionally, 23 million and eight million of the RSUs granted in 
2019 and 2018 will vest predominantly over four years with most 
vesting occurring 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. 

The compensation cost for the stock-based plans was $2.1 
billion, $1.8 billion and $2.2 billion and the related income tax 
benefit was $511 million, $433 million and $829 million for 2019, 
2018 and 2017, respectively. 

Restricted Stock/Units 
The table below presents the status at December 31, 2019 of the 
share-settled restricted stock/units and changes during 2019.

 Stock-settled Restricted Stock/Units 

Outstanding at January 1, 2019 
Granted 
Vested 
Canceled 

Outstanding at December 31, 2019 

Shares/Units 

Weighted-
average Grant 
Date Fair Value 

165,621,246  $ 

91,164,482 
(92,215,549) 
(6,660,864) 
157,909,315 

23.22 
27.72 
19.30 
27.49 
27.93 

The table below presents the status at December 31, 2019 of 

the cash-settled RSUs and changes during 2019. 

Cash-settled Restricted Units 

Outstanding at January 1, 2019 
Granted 
Vested 
Canceled 

Outstanding at December 31, 2019 

Units 
2,609,122 
2,455,177 
(3,006,707) 
(93,170) 
1,964,422 

At December 31, 2019, there was an estimated $1.6 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 2.2 years. The total fair value of restricted stock vested in 2019, 
2018 and 2017 was $2.6 billion, $2.3 billion and $1.3 billion, 
respectively. In 2019, 2018 and 2017, the amount of cash paid 
to settle equity-based awards for all equity compensation plans 
was $84 million, $1.3 billion and $1.9 billion, respectively. 

164 164

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTE 20 Income Taxes 
The components of income tax expense for 2019, 2018 and 2017 
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 

$ 

2019 

2018 

2017 

$ 

1,136  $ 

816  $ 

901 
852 
2,889 

1,377 
1,203 
3,396 

2,001 
223 
211 
2,435 
5,324  $ 

2,579 
240 
222 
3,041 
6,437  $ 

1,310 
557 
939 
2,806 

7,238 
835 
102 
8,175 
10,981 

Total income tax expense does not reflect the tax effects of 
items that are included in OCI each period. For more information, 
see Note 15 – Accumulated Other Comprehensive Income (Loss). 
Other  tax  effects  included  in  OCI  each  period  resulted  in  an 
expense of $1.9 billion in 2019 and a benefit of $1.2 billion in 
both 2018 and 2017. 

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 
Changes in prior-period UTBs, including interest 
Tax-exempt income, including dividends 
Stock-based compensation 
Rate differential on non-U.S. earnings 
Nondeductible expenses 
Tax law changes 
Other 

Total income tax expense  

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 

2019 

2018 

2017 

$ 

2,197  $ 

1,773  $ 

875 

Increases related to positions taken 

during the current year 

Increases related to positions taken 

during prior years (1) 

Decreases related to positions 

taken during prior years (1) 

238 

401 

395 

406 

292 

750 

(1,102) 

(371) 

(122) 

Balance, December 31 

Settlements 
Expiration of statute of limitations 

(17) 
(5) 
$ 
1,773 
(1)   The sum of the positions taken during prior years differs from the $(613) million, $144 million 
and $133 million in the Reconciliation of Income Tax Expense table due to temporary items, 
state items and jurisdictional offsets, as well as the inclusion of interest in the Reconciliation 
of Income Tax Expense table. 

(6) 
— 
2,197  $ 

(541) 
(18) 
1,175  $ 

Income tax expense for 2019, 2018 and 2017 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 2019 and 2018, and 35 percent for 
2017.  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 2019, 2018 and 2017 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. 

Amount 

Percent 

Amount 

Percent 

Amount 

Percent 

2019 

2018 

2017 

$ 

6,878 

21.0%  $ 

7,263 

21.0%  $  10,225 

35.0% 

1,283 
(2,365) 
(613) 
(433) 
(225) 
504 
290 
—
5 
5,324 

$ 

3.9 
(7.2) 
(1.9) 
(1.3) 
(0.7) 
1.5 
0.9 
— 
0.1 

16.3%  $ 

1,367 
(1,888) 
144 
(413) 
(257) 
98 
302 
— 
(179) 
6,437 

881 
4.0 
(1,406) 
(5.5) 
133 
0.4 
(672) 
(1.2) 
(236) 
(0.7) 
(272) 
0.3 
97 
0.9 
2,281 
— 
(0.6) 
(50) 
18.6%  $  10,981 

3.0 
(4.8) 
0.5 
(2.3) 
(0.8) 
(0.9) 
0.3 
7.8 
(0.2) 
37.6% 

At December 31, 2019, 2018 and 2017, the balance of the 
Corporation’s  UTBs  which  would,  if  recognized,  affect  the 
Corporation’s effective tax rate was $814 million, $1.6 billion and 
$1.2 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. 

It is reasonably possible that the UTB balance may decrease 
by  as  much  as  $64  million  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 an interest benefit of $19 million 
in  2019  and  interest  expense  of  $43  million  and  $1  million  in 
2018  and  2017.  At  December  31,  2019  and  2018,  the 
Corporation’s  accrual  for  interest  and  penalties  that  related  to 
income taxes, net of taxes and remittances, was $147 million and 
$218 million. 

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 

Bank of America 2019  165 
Bank of America 2019  165

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
significant business operations examine tax returns periodically 
(continuously 
table 
summarizes the status of examinations by major jurisdiction for 
the Corporation and various subsidiaries at December 31, 2019. 

jurisdictions).  The 

in  some 

following 

Tax Examination Status 

Years under 
Examination (1) 

Status at 
December 31 
2019 

United States 
California 
New York 
United Kingdom 
(1)  All tax years subsequent to the years shown remain subject to examination. 

2017-2018 
2012-2017 
2016-2018 
2018 

To begin in 2020 
Field examination 
Field examination 
Field examination 

Significant components of the Corporation’s net deferred tax 
assets  and  liabilities  at  December  31,  2019  and  2018  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 
Lease liability 
Security, loan and debt valuations 
Accrued expenses 
Employee compensation and retirement benefits 
Credit carryforwards 
Available-for-sale securities 
Other 

Gross deferred tax assets 

Valuation allowance 

Total deferred tax assets, net of valuation 

allowance 

Deferred tax liabilities 

Equipment lease financing 
Right-to-use asset 
Tax credit investments 
Fixed assets 
Available-for-sale securities 
Other 

Gross deferred tax liabilities 
Net deferred tax assets 

December 31 

2019 

2018 

$ 

7,417  $ 
2,354 
2,321 
1,860 
1,719 
1,622 
183 
— 
1,203 
18,679 
(1,989) 

7,993 
2,400 
— 
1,818 
1,875 
1,564 
623 
1,854 
1,037 
19,164 
(1,569) 

16,690 

17,595 

2,933 
2,246 
1,577 
1,505 
100 
1,885 
10,246 

2,684 
— 
940 
1,104 
— 
2,126 
6,854 
6,444  $  10,741 

$ 

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, 2019. 

Net Operating Loss and Tax Credit Carryforward Deferred 
Tax Assets 

Deferred 
Tax Asset 

Valuation 
Allowance 

Net 
Deferred 
Tax Asset 

First Year 
Expiring 

$ 

312

$ 

—  $ 

312 

After 2028

5,276 

— 

5,276 

None

493 

(423) 

70 

Various 

(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) 
2028 
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 

(183) 

183 

— 

756 

Various 

1,336 

(580) 

the benefit of federal deductions were $1.7 billion and $734 million. 

166 166

Bank of America 2019 

Bank of America 2019

Management  concluded  that  no  valuation  allowance  was 
necessary to reduce the deferred tax assets related to the U.K. 
NOL  carryforwards  and  U.S.  federal  and  certain  state  NOL 
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, 2019, U.S. federal income taxes had not been 
provided on approximately $5.0 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 $1.0 billion. 

NOTE 21 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 and conducts a review of 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 become 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 more information, see Note 22 – 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 2019, there were no significant 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, and 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. 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 
factors,  where  appropriate. 
the  Corporation 
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 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. 

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, interest rates, 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 

Bank of America 2019  167 
Bank of America 2019  167

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Recurring Fair Value 
Assets and liabilities carried at fair value on a recurring basis at December 31, 2019 and 2018, including financial instruments that 
the Corporation accounts for under the fair value option, are summarized in the following tables. 

(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 (2) 
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 
Agency MBS 
Non-agency residential MBS 
Non-U.S. and other 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, 2019 

Level 1 

Level 2 

Level 3 

Netting 
Adjustments (1) 

Assets/Liabilities 
at Fair Value 

1,000

$ 

— $ 

— $ 

— $ 

1,000 

— 

50,364 

49,517 
— 
53,597 
3,965 

— 
— 
107,079 
14,079 

4,157 
25,226 
32,619 
23,854 

24,324 
8,786 
118,966 
328,442 

67,332 

1,196 

— 
— 
— 
— 
— 
— 
— 
67,332 

3
— 
— 
400 
403 
— 
— 
11,782 
201,675 

$ 

122,528 
4,641 
653 
15,021 
11,989 
3,876 
17,804 
177,708 

—
3,003 
1,035 
6,088 
10,126 
7,642 
3,334 
1,376 
697,958 

— $ 

508

$ 

$ 

— 

— 
1,507 
239 
482 

— 
1,553 
3,781 
2,226 

— 

— 
— 
424 
— 
2 
65 
108 
599 

—
— 
299 
— 
299 
693 
375 
2,360 
10,333 

— 

— 
— 
— 
— 

— 
— 
— 
(304,262) 

— 

— 
— 
— 
— 
— 
— 
— 
— 

— 
— 
— 
— 
— 
— 
— 
— 
(304,262) 

$ 

$ 

50,364 

53,674 
26,733 
86,455 
28,301 

24,324 
10,339 
229,826 
40,485 

68,528 

122,528 
4,641 
1,077 
15,021 
11,991 
3,941 
17,912 
245,639 

3 
3,003 
1,334 
6,488 
10,828 
8,335 
3,709 
15,518 
605,704 

— $ 

— $ 

508 

— 

16,008 

— 

— 

16,008 

13,140 
38,148 
10,751 
— 
62,039 
11,904 
— 
13,927 
— 
87,870 

282 
4,144 
11,310 
5,478 
21,214 
320,479 
3,941 
1,507 
33,826 
397,483 

— 
2 
— 
15 
17 
4,764 
— 
— 
1,149 
5,930 

— 
— 
— 
— 
— 
(298,918) 
— 
— 
— 
(298,918) 

$ 

13,422 
42,294 
22,061 
5,493 
83,270 
38,229 
3,941 
15,434 
34,975 
192,365 

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 $26.7 billion of GSE obligations. 

(3)   Includes securities with a fair value of $14.7 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 $1.5 billion which are classified as Level 3 assets. 

(4) 

(5)  Total recurring Level 3 assets were 0.42 percent of total consolidated assets, and total recurring Level 3 liabilities were 0.27 percent of total consolidated liabilities. 

168 168

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(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 (2) 
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 
Non-agency residential MBS 
Non-U.S. and other 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 
5,357 
6,791 
4,011 
2,400 
1,775 
659,511 

$ 

— 

— 
1,558 
276 
465 

— 
1,635 
3,934 
3,466 

— 

— 
— 
597 
— 
2 
7 
— 
606 

— 
172 
— 
172 
338 
542 
2,932 
11,990 

— 

— 
— 
— 
— 

— 
— 
— 
(285,121) 

— 

— 
— 
— 
— 
— 
— 
— 
— 

— 
— 
— 
— 
— 
— 
— 

$ 

(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 
5,847 
8,735 
4,349 
2,942 
19,739 
580,817 

— 

$ 

492 

$ 

— 

$ 

—  $ 

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 
26,872 
382,424 

— 
— 
— 
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 
27,689 
184,890 

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. 

(3)   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. 

(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 2019  169 
Bank of America 2019  169

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 2019, 2018 and 
2017, including net realized and unrealized gains (losses) included 
in  earnings  and  accumulated  OCI.  Transfers  into  Level  3  occur 

primarily due to decreased price observability, and transfers out 
of  Level  3  occur  primarily  due  to  increased  price  observability. 
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. 

Level 3 – Fair Value Measurements (1) 

Total 
Realized/ 
Unrealized 
Gains  
(Losses) in 
Net 
Income (2) 

Balance 
January 1 

Gains  
(Losses)  
in OCI (3)  Purchases 

Gross

Sales 

Issuances  Settlements 

Gross 

Gross 

Transfers  Transfers 

into 
Level 3 

out of 
Level 3 

Balance 
December 31 

Change in 
Unrealized 
Gains 
(Losses) in
Net Income 
Related to 
Financial 
Instruments 
Still Held (2) 

$  1,558  $ 
276 
465 
1,635 
3,934 
(935) 

105  $  —  $ 
(12) 
46
99 
238 
(37) 

— 
(12) 
(2) 
(14) 
— 

534  $ (390) $ 

38 
1 
662 
1,235 
298 

(87) 
— 
(899) 
(1,376) 
(837) 

18  $ 
— 
— 
— 
18 
— 

(578) $ 
(9) 
(51) 
(175) 
(813) 
(97) 

699  $ 
79 
39 
738 
1,555 
147 

(439) $ 
(46) 
(6) 
(505) 
(996) 
(1,077) 

1,507  $ 
239 
482 
1,553 
3,781 
(2,538) 

597 
2 
7 
— 
606 

172 

338 
542 
2,932 
— 

(18) 

(817) 

13 
—
2
—
15 

36 

— 
48 
(81) 
(2) 

8

(59) 

64 
—
— 
— 
64 

— 

— 
(6) 
19 
— 

— 

(64) 

— 
—
—
—
— 

— 

230 
12 
— 
—

(1) 

— 

(73) 
—
— 
— 
(73) 

— 

(35) 
(71) 
(10) 
— 

(3) 

— 

— 
— 
— 
— 
— 

— 

217 
36 
179 
— 

(1) 

(40) 

(40) 
—
(5) 
—
(45) 

206 
—
61
108
375 

(343) 
— 
— 
— 
(343) 

(17) 

155 

(47) 

(57) 
(245) 
(683) 
—

— 

180 

— 
59 
5 
—

— 

(350) 

— 
— 
(1) 
— 

— 

1 

424 
2 
65 
108 
599 

299 

693 
375 
2,360 
(2) 

(15) 

(1,149) 

$  1,864  $ 
235 
556 
1,498 
4,153 
(1,714) 

(32)  $ 
(17) 
47 
148 
146 
106 

(1)  $ 
— 
(44) 
3 
(42) 
— 

436  $  (403)  $ 

44 
13 
585 
1,078 
531 

(11) 
(57) 
(910) 
(1,381) 
(1,179) 

5  $ 
— 
— 
— 
5 
— 

— 
25 
509 
469 
1,003 

— 

571 
690 
2,425 

(24) 

(8) 
(1,863) 

27 
— 
1 
— 
28 

(18) 

(16) 
44 
414 

11 

— 
103 

(33) 
(1) 
(3) 
— 
(37) 

— 

— 
(26) 
(38) 

— 

— 
4 

— 
— 
— 
— 
— 

— 

— 
71 
2 

9

— 
9 

(71) 
(10) 
(23) 
— 
(104) 

(8) 

(134) 
— 
(69) 

(12) 

— 
— 

— 
— 
— 
— 
— 

— 

— 
1 
96 

(2) 

— 
(141) 

(4) 
(30) 
(158) 
(760) 
778 

(25) 
(15) 
(11) 
(1) 
(52) 

(34) 

(83) 
(201) 
(792) 

— 

8 
486 

(568)  $  804  $ 

78 
117 
705 
1,704 
39 

(547)  $ 
(49) 
(137) 
(236) 
(969) 
504 

1,558  $ 
276 
465 
1,635 
3,934 
(935) 

774 
3 
60 
1 
838 

365 

— 
23 
929 

— 

— 
(262) 

(75) 
— 
(526) 
(469) 
(1,070) 

(133) 

— 
(60) 
(35) 

— 

— 
847 

597 
2 
7 
— 
606 

172 

338 
542 
2,932 

(18) 

— 
(817) 

29 
(18) 
47 
26 
84 
228 

— 
— 
— 
— 
— 

38 

(1) 
22 
(267) 
(2) 

— 

(55) 

(117) 
(22) 
48 
97 
6 
(116) 

— 
— 
— 
— 
— 

(18) 

(9) 
31 
149 

(7) 

— 
95 

(Dollars in millions)  

Year Ended December 31, 2019 
Trading account assets: 

Corporate securities, trading loans and other 
Equity securities 
Non-U.S. sovereign debt 
Mortgage trading loans, ABS and other MBS 

Total trading account assets 
Net derivative assets (liabilities) (4,5) 
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 (6,7) 
Loans held-for-sale (6,7) 
Other assets (7) 
Trading account liabilities – Equity securities 
Trading account liabilities – Corporate securities 

and other  

Long-term debt (5,6)  

Year Ended December 31, 2018 
Trading account assets: 

Corporate securities, trading loans and other 
Equity securities 
Non-U.S. sovereign debt 
Mortgage trading loans, ABS and other MBS 

Total trading account assets 
Net derivative assets (liabilities) (4) 
AFS debt securities: 

Non-agency residential MBS 
Non-U.S. securities 
Other taxable securities 
Tax-exempt securities 
Total AFS debt securities (8) 
Other debt securities carried at fair value – Non-

agency residential MBS 

Loans and leases (6,7) 
Loans held-for-sale (6) 
Other assets (7,8) 
Trading account liabilities – Corporate securities 

and other 

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)   Includes gains (losses) reported in earnings in the following income statement line items: Trading account assets/liabilities - predominantly market making and similar activities; Net derivative assets 
(liabilities) - market making and similar activities and other income; Other debt securities carried at fair value - other income; Loans and leases - predominantly other income; Loans held-for-sale - 
other income; Other assets - primarily other income related to MSRs; Long-term debt - primarily market making and similar activities. 

(3)   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. Amounts include net unrealized gains (losses) of $3 million and $(105) million related to financial instruments still held at December 31, 2019 and 2018. 

(4)  Net derivative assets (liabilities) include derivative assets of $2.2 billion and $3.5 billion and derivative liabilities of $4.8 billion and $4.4 billion at December 31, 2019 and 2018. 
(5)   Transfers into long-term debt include a $1.4 billion transfer in of Level 3 derivative assets to reflect the Corporation's change to present bifurcated embedded derivatives with their respective host 

instruments. 

(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)  Transfers out of AFS debt securities and into other assets primarily relate to the reclassification of certain securities. 

170 170

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Level 3 – Fair Value Measurements (1) 

Total 
Realized/ 
Unrealized 
Gains/ 

Balance 
January 1 

(Losses) in  Gains/  
(Losses) 
in OCI (3)  Purchases 

Net 
Income (2) 

Gross

Sales 

Issuances  Settlements 

(Dollars in millions) 

Year Ended December 31, 2017 

Trading account assets: 

Change in 
Unrealized 
Gains/  
(Losses) in  
Net Income  
Related to 
Financial 
Instruments 
out of 
Level 3  December 31  Still Held (2) 

Balance 

Gross

Transfers  Transfers 

Gross 

into 
Level 3 

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)  $ 

55 
53 
1,210 
1,865 
664 

(70) 
(59) 
(990) 
(1,821) 
(979) 

5  $ 
— 
— 
— 
5 
— 

(666)  $  728  $(1,054)  $ 

146 
(10) 
72 
(73) 
(233) 
218 
(982)  1,164 
48 
949 

(185) 
(13) 
(81) 
(1,333) 
(99) 

1,864  $ 
235 
556 
1,498 
4,153 
(1,714) 

Total trading account assets 
Net derivative assets (liabilities) (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) 
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 

18 
74 
165 
486 
(984) 

2 
4 
1 
7 

(1) 

15 
100 
144 

(359) 

(5) 

(27) 

14 

— 
(8) 
(2) 
(10) 
— 

16 
8 
3 
27 

— 

— 
(3) 
(57) 

— 

— 

49 
5 
14 
68 

— 
— 
(70) 
(70) 

— 

(21) 

3 
3 
2 

(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 

— 

8 

(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 - market making and similar activities; Net derivative assets (liabilities) 
- primarily market making and similar activities 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 market making and similar activities. 

(3)   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. 

(4)  Net derivative assets (liabilities) 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. 

Bank of America 2019  171 
Bank of America 2019  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, 2019 and 2018. 

Quantitative Information about Level 3 Fair Value Measurements at December 31, 2019 

(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 

$  1,407 

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 

Loans held-for-sale 

332 

281 

4 

491 

299 

303 

201 

85 

17 

Commercial loans, debt securities and other 

$  3,798 

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 

Other assets, primarily auction rate securities 

$ 

1,306 

482 

1,136 

108 

412 

354 

815 

Yield 

Prepayment speed 

Discounted cash 
flow, Market 
comparables 

Default rate 

Loss severity 

Discounted cash 
flow 

Price 

Yield 

Price 

Yield 

Prepayment speed 

Discounted cash 
flow, Market 
comparables 

Default rate 

Loss severity 

Price 

Long-dated equity volatilities 

Price 

Discounted cash 
flow, Market 
comparables 

MSRs 

$  1,545 

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 

0% to 25% 

6% 

1% to 27% CPR 

17% CPR 

0% to 3% CDR 

1% CDR 

0% to 47% 

$0 to $160 

0% to 30% 

$0 to $100 

1% to 20% 

10% to 20% 

3% to 4% 

35% to 40% 

$0 to $142 

35% 

14% 

$94 

14% 

$55 

6% 

13% 

4% 

38% 

$72 

n/a 

$10 to $100 

$96 

0 to 14 years 

0 to 9 years 

5 years 

3 years 

7% to 14% 

9% to 15% 

2% to 6% 

9% to 100% 

4% to 101% 

$0 to $116 

9% 

11% 

5% 

63% 

32% 

$74 

Structured liabilities 

Long-term debt 

Net derivative assets (liabilities) 

Credit derivatives 

Equity derivatives 

$ 

(1,149) 

Discounted cash 
flow, Market 
comparables, 
Industry standard 
derivative pricing (3) 

Yield 

Equity correlation 

Long-dated equity volatilities 

Price 

Natural gas forward price 

$1/MMBtu to $5/MMBtu 

$3/MMBtu 

$ 

13 

Yield 

Discounted cash 
flow, Stochastic 
recovery correlation 
model 

$ 

(1,081) 

Industry standard 
derivative pricing (3) 

Upfront points 

Prepayment speed 

Default rate 

Loss severity 

Price 

Equity correlation 

Long-dated equity volatilities 

5% 

n/a 

0 to 100 points 

63 points 

15% to 100% CPR 

22% CPR 

1% to 4% CDR 

2% CDR 

35% 

$0 to $104 

9% to 100% 

4% to 101% 

n/a 

$73 

63% 

32% 

Commodity derivatives 

$ 

(1,357)  Discounted cash 

Natural gas forward price 

$1/MMBtu to $5/MMBtu 

$3/MMBtu 

Interest rate derivatives 

$ 

(113) 

Total net derivative assets (liabilities) 

$ 

(2,538) 

flow, Industry 
standard derivative 
pricing (3) 

Correlation 

Volatilities 

Industry standard 
derivative pricing (4) 

Correlation (IR/IR) 

Correlation (FX/IR) 

Long-dated inflation rates 

Long-dated inflation volatilities 

30% to 69% 

14% to 54% 

15% to 94% 

0% to 46% 

-23% to 56% 

0% to 1% 

68% 

27% 

52% 

2% 

16% 

1% 

(1)  For loans and securities, structured liabilities and net derivative assets (liabilities), 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 $1.5 billion, Trading account assets – Non-U.S. sovereign debt of $482 million, Trading account assets – Mortgage trading loans, 
ABS and other MBS of $1.6 billion, AFS debt securities of $599 million, Other debt securities carried at fair value - Non-agency residential of $299 million, Other assets, including MSRs, of $2.4 
billion, Loans and leases of $693 million and LHFS of $375 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 

172 172

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 

$ 

(817)  Discounted cash 

Equity correlation 

Net derivative assets (liabilities) 

Credit derivatives 

$ 

(565) 

flow, Market 
comparables, 
Industry standard 
derivative pricing (3) 

Discounted cash 
flow, Stochastic 
recovery correlation 
model 

Equity derivatives 

Commodity derivatives 

Interest rate derivatives 

$ 

(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 (liabilities) 

$ 

(935) 

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% 

8% 

0% to 21% CPR 

12% CPR 

0% to 3% CDR 

1% 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 

17% 

$72 

7% 

$79 

13% 

15% 

4% 

38% 

$68 

$95 

0 to 14 years 

0 to 10 years 

5 years 

3 years 

7% to 14% 

9% to 15% 

11% to 100% 

4% to 84% 

7% to 18% 

$0 to $100 

9% 

12% 

67% 

32% 

16% 

$72 

0% to 5% 

4% 

0 points to 100 points 

70 points 

70% 

n/a 

15% to 20% CPR 

15% CPR 

1% to 4% CDR 

2% CDR 

35% 

$0 to $138 

11% to 100% 

4% to 84% 

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 (liabilities), 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 169: 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. 

(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 2019  173 
Bank of America 2019  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  result  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 

Assets Measured at Fair Value on a Nonrecurring Basis 

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. 

Nonrecurring Fair Value 
The Corporation holds certain assets that are measured at fair 
value only in certain situations (e.g., the impairment of an asset), 
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 2019, 2018 and 2017. In the tables below, other assets 
includes the measurement of the Corporation's merchant services 
equity method investment on which the Corporation recorded an 
impairment  charge  of  $2.1  billion  during  2019.  For  more 
information, see Note 13 – Commitments and Contingencies. 

(Dollars in millions) 

Assets 

Loans held-for-sale 
Loans and leases (1) 
Foreclosed properties (2, 3) 
Other assets 

Assets 

December 31, 2019 

December 31, 2018 

Level 2 

Level 3 

Level 2 

Level 3 

$ 

53  $ 
— 
— 
178 

102  $ 
257 
17 
646 

$ 

274
— 
— 
331 

— 
474 
42 
14 

2019 

Gains (Losses) 
2018 

2017 

Loans held-for-sale 
Loans and leases (1) 
Foreclosed properties 
Other assets 
Includes $36 million, $83 million and $135 million of losses on loans that were written down to a collateral value of zero during 2019, 2018 and 2017, respectively. 

(14)  $ 
(81) 
(9) 
(2,145) 

$ 

(1) 

$ 

(18) 
(202) 
(24) 
(64) 

(6) 
(336) 
(41) 
(124) 

(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 $260 million and $488 million of properties acquired upon foreclosure of certain government-guaranteed loans (principally FHA-insured loans) at December 31, 2019 and 2018. 

174 174

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The table below presents information about significant unobservable inputs at December 31, 2019 and 2018. 

Quantitative Information about Nonrecurring Level 3 Fair Value Measurements 

Financial Instrument 

Fair 
Value 

Valuation 
Technique 

Significant 
Unobservable 
Inputs 

December 31, 2019 

Inputs 

Ranges of 
Inputs 

Weighted 
Average (1) 

(Dollars in millions) 

Loans held-for-sale 
Loans and leases (2) 

Other assets (3) 

$ 

102  Discounted cash flow  Price 
257  Market comparables  OREO discount 

640  Discounted cash flow  Customer attrition 

Costs to sell 

Costs to service 

December 31, 2018 

$85 to $97 
13% to 59% 
8% to 26% 
0% to 19% 
11% to 19% 

13% to 59% 
8% to 26% 

$88 
24% 
9% 
5% 
15% 

25% 
9% 

Loans and leases (2) 

$ 

474  Market comparables  OREO discount 

Costs to sell 

(1)  The weighted average is calculated based upon the fair value of the loans. 
(2)  Represents residential mortgages where the loan has been written down to the fair value of the underlying collateral. 
(3)   The fair value of the merchant services joint venture was measured using a discounted cash flow method in which the two primary drivers of fair value were the customer attrition rate and certain 

costs to service the customers. The weighted averages are calculated based on variations of the attrition rates and costs to service the customers. 

NOTE 22 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. 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. 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. 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. 

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. 

Bank of America 2019  175 
Bank of America 2019  175

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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. 

assets and liabilities accounted for under the fair value option at 
December  31,  2019  and  2018,  and  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 2019, 2018 and 2017. 

Fair Value Option Elections 
The  following  tables  provide  information  about  the  fair  value 
carrying  amount  and  the  contractual  principal  outstanding  of 

Fair Value Option Elections 

(Dollars in millions) 

Federal funds sold and securities borrowed or 

purchased under agreements to resell 

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 

December 31, 2019 

December 31, 2018 

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 

$ 

50,364  $ 

50,318  $ 

46 

$ 

56,399  $ 

56,376  $ 

6,989 
19,574 
8,335 
3,709 
4 
508 

16,008 

14,703 
n/a 
8,372 
4,879 
n/a 
496 

16,029 

(7,714) 
n/a 
(37) 
(1,170) 
n/a 
12 

6,195 
13,778 
4,349 
2,942 
3 
492 

(21) 

28,875 

13,088 
n/a 
4,399 
4,749 
n/a 
454 

28,881 

23 

(6,893) 
n/a 
(50) 
(1,807) 
n/a 
38 

(6) 

Short-term borrowings 
— 
Unfunded loan commitments 
n/a 
(1,509) 
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 

1,648 
n/a 
29,198 

1,648 
169 
27,689 

3,930 
n/a 
35,730 

3,941 
90 
34,975 

11 
n/a 
(755) 

contractual principal outstanding. 
Includes structured liabilities with a fair value of $34.6 billion and $27.3 billion, and contractual principal outstanding of $35.3 billion and $28.8 billion at December 31, 2019 and 2018. 

(2) 

n/a = not applicable 

Gains (Losses) Relating to Assets and Liabilities Accounted for Under the Fair Value Option 

(Dollars in millions) 
Loans reported as trading account assets 
Trading inventory – other (1) 
Consumer and commercial loans 
Loans held-for-sale (2) 
Long-term debt (3) 
Other (4) 

Total (5) 

Loans reported as trading account assets 
Trading inventory – other (1) 
Consumer and commercial loans 
Loans held-for-sale (2) 
Long-term debt (3) 
Other (4) 

Total (5) 

Loans reported as trading account assets 
Trading inventory – other (1) 
Consumer and commercial loans 
Loans held-for-sale (2) 
Long-term debt (3) 
Other (4) 

Total (5) 

Market making and 
similar activities 

Other 
Income 

2019 

Total 

$ 

$ 

$ 

$ 

$ 

$ 

203  $ 

5,795 
92 
— 
(1,098) 
(15) 
4,977  $ 

8  $ 

1,750 
(422) 
1 
2,157 
8 
3,502  $ 

318  $ 

3,821 
(9) 
— 
(1,044) 
(93) 
2,993  $ 

2018 

2017 

—  $ 
— 
12 
98 
(78) 
52 
84  $ 

—  $ 
— 
(53) 
24 
(93) 
(31) 
(153)  $ 

—  $ 
— 
35 
298 
(146) 
49 

236  $ 

203 
5,795 
104 
98 
(1,176) 
37 
5,061 

8 
1,750 
(475) 
25 
2,064 
(23) 
3,349 

318 
3,821 
26 
298 
(1,190) 
(44) 
3,229 

(1)  The gains in market making and similar activities are primarily offset by losses on trading liabilities that hedge these assets. 
(2) 

Includes the value of IRLCs on funded loans, including those sold during the period. 

(3)   The net gains (losses) in market making and similar activities relate to the embedded derivatives in structured liabilities and are typically offset by (losses) gains on derivatives and securities that 
hedge these liabilities. For the cumulative impact of changes in the Corporation’s own credit spreads and the amount recognized in accumulated OCI, see Note 15 – Accumulated Other Comprehensive 
Income (Loss). For more information on how the Corporation’s own credit spread is determined, see Note 21 – Fair Value Measurements. 

(4)   Includes gains (losses) on federal funds sold and securities borrowed or purchased under agreements to resell, long-term deposits, federal funds purchased and securities loaned or sold under 

agreements to repurchase, short-term borrowings and unfunded loan commitments. 

(5)  Gains (losses) related to borrower-specific credit risk were $194 million, $(148) million and $38 million in 2019, 2018 and 2017, respectively. 

176 176

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTE 23 Fair Value of Financial Instruments 
Financial instruments are classified within the fair value hierarchy 
using  the  methodologies  described  in  Note  21  –  Fair  Value 
Measurements.  Certain  loans,  deposits,  long-term  debt  and 
unfunded lending commitments are accounted for under the fair 
value option. For more information, see Note 22 – 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. 

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, 2019 and 2018 are 
presented in the following table. 

Fair Value of Financial Instruments 

Carrying 
Value 

(Dollars in millions) 
Financial assets 

Loans 
Loans held-for-sale 

$  950,093  $ 
9,158 

Fair Value 

Level 2 

Level 3 

Total 

December 31, 2019 

63,633  $  914,597  $  978,230 
9,158 

8,439 

719 

Financial liabilities 

Deposits (1) 
Long-term debt 
Commercial 

unfunded lending 
commitments (2) 

Financial assets 

Loans 
Loans held-for-sale 

Financial liabilities 

Deposits (1) 
Long-term debt 
Commercial 

unfunded lending 
commitments (2) 

1,434,803 
240,856 

1,434,809 
247,376 

— 
1,149 

1,434,809 
248,525 

903 

90 

4,777 

4,867 

December 31, 2018 

$  911,520  $  58,228  $  859,160  $  917,388 
10,367 

10,367 

9,592 

775 

1,381,476 
229,392 

1,381,239 
230,019 

— 
817 

1,381,239 
230,836 

966 

169 

5,558 

5,727 

(1)   Includes demand deposits of $545.5 billion and $531.9 billion with no stated maturities at 

December 31, 2019 and 2018. 

(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 13 – Commitments and Contingencies. 

NOTE 24 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 
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 
revenue-sharing 
and  Global  Markets  under  an 
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. 

Bank of America 2019  177 
Bank of America 2019  177

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
All Other 
All Other consists of ALM activities, equity investments, non-core 
mortgage  loans  and  servicing  activities, liquidating  businesses 
and  certain  expenses  not  otherwise  allocated  to  business 
segments.  ALM  activities  encompass  certain 
residential 
mortgages, debt securities, interest rate and foreign currency risk 
management  activities.  Substantially  all  of  the  results  of  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  substantially  all  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 
2019, 2018 and 2017, and total assets at December 31, 2019 
and 2018 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 

Period-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 

Period-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) 
Period-end total assets 
(1)  There were no material intersegment revenues. 

178 178

Bank of America 2019 

Bank of America 2019

2019 

Total Corporation (1) 
2018 

2017 

2019 

Consumer Banking 
2018 

2017 

$ 

49,486  $ 
42,353 
91,839 
3,590 
54,900 
33,349 
5,919 

48,772  $ 
42,858 
91,630 
3,282 
53,154 
35,194 
7,047 

27,430  $ 

$ 
$  2,434,079  $  2,354,507 

28,147  $ 

46,164  $ 
41,887 
88,051 
3,396 
54,517 
30,138 
11,906 
18,232  $ 
$ 

28,158  $ 
10,429 
38,587 
3,772 
17,618 
17,197 
4,213 

12,984  $ 
804,019  $ 

27,025  $ 
10,593 
37,618 
3,664 
17,672 
16,282 
4,150 

12,132  $ 

768,881 

24,203 
10,101 
34,304 
3,525 
17,847 
12,932 
4,897 
8,035 

Global Wealth & 
Investment Management 
2018 

2019 

2017 

2019 

2018 

2017 

Global Banking 

$ 

6,504 
13,033 
19,537 
82 
13,823 
5,632 
1,380 
4,252  $ 
299,756  $ 

$ 

6,265 
13,188 
19,453 
86 
14,015 
5,352 
1,364 
3,988  $ 

305,907 

$ 

6,152 
12,447 
18,599 
56 
13,770 
4,773 
1,807 
2,966  $ 
$ 

$ 

10,675 
9,808 
20,483 
414 
9,017 
11,052 
2,984 
8,068  $ 
464,032  $ 

$ 

10,993 
9,008 
20,001 
8 
8,745 
11,248 
2,923 
8,325  $ 

442,330 

10,615 
9,510 
20,125 
212 
8,811 
11,102 
4,204 
6,898 

2019 

Global Markets 
2018 

2017 

2019 

All Other 
2018 

2017 

3,915 
11,699 
15,614 
(9) 
10,722 
4,901 
1,397 
3,504 
641,806 

$ 

$ 
$ 

3,857 
12,326 
16,183 
— 
10,835 
5,348 
1,390 
3,958 
641,923 

$ 

$ 

4,264 
11,698 
15,962 
164 
10,997 
4,801 
1,666 
3,135 

$ 

$ 
$ 

234 
(2,616) 
(2,382) 
(669) 
3,720 
(5,433) 
(4,055) 
(1,378) 
224,466 

$ 

$ 
$ 

632 
(2,257) 
(1,625) 
(476) 
1,887 
(3,036) 
(2,780) 
(256) 
195,466 

$ 

$ 

930 
(1,869) 
(939) 
(561) 
3,092 
(3,470) 
(668) 
(2,802) 

$ 

$ 
$ 

$ 

$ 
$ 

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The table below presents noninterest income and the components thereto for 2019, 2018 and 2017 for each business segment, 

All Other and the total Corporation. For more information, see Note 2 – Net Interest Income and Noninterest Income. 

Noninterest Income by Business Segment and All Other 

(Dollars in millions) 

Fees and commissions: 

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 fees 
Underwriting income 
Syndication fees 
Financial advisory services 

Total investment banking fees 
Total fees and commissions 
Market making and similar activities 
Other income 

Total noninterest income 

Fees and commissions: 

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 fees 
Underwriting income 
Syndication fees 
Financial advisory services 

Total investment banking fees 
Total fees and commissions 
Market making and similar activities 
Other income 

Total noninterest income 

(1)  All Other includes eliminations of intercompany transactions. 

Total Corporation 

Consumer Banking 

2019 

2018 

2017 

2019 

2018 

2017 

$  3,834  $  3,866  $  3,777  $  3,174  $  3,196  $  3,038  $ 

1,963 
5,797 

6,588 
1,086 
7,674 

1,958 
5,824 

6,667 
1,100 
7,767 

1,899 
5,676 

6,708 
1,110 
7,818 

10,241 
3,661 
13,902 

10,189 
3,971 
14,160 

9,310 
4,526 
13,836 

1,910 
5,084 

4,219 
— 
4,219 

144 
149 
293 

1,906 
5,102 

4,300 
— 
4,300 

147 
172 
319 

1,846 
4,884 

4,266 
— 
4,266 

Global Wealth & 
Investment Management 
2018 

2019 

2017 

60  $ 
41 
101 

81  $ 
46 
127 

109 
44 
153 

68 
— 
68 

73 
— 
73 

77 
— 
77 

133 
184 
317 

10,130 
1,740 
11,870 

10,042 
1,917 
11,959 

9,177 
2,217 
11,394 

2,998 
1,184 
1,460 
5,642 
33,015 
9,034 
304 

316 
— 
2 
318 
11,942 
144 
361 
$  42,353  $ 42,858  $ 41,887  $  10,429  $ 10,593  $ 10,101  $  13,033  $ 13,188  $ 12,447 

335 
— 
2 
337 
12,496 
112 
580 

2,821 
1,499 
1,691 
6,011 
33,341 
7,102 
1,444 

2,722 
1,347 
1,258 
5,327 
33,078 
9,008 
772 

401 
— 
— 
401 
12,440 
113 
480 

(1) 
— 
— 
(1) 
9,720 
8 
865 

— 
— 
— 
— 
9,467 
3 
631 

— 
— 
— 
— 
9,596 
6 
827 

Global Banking 
2018 

2019 

2017 

2019 

Global Markets 
2018 

2017 

2019 

All Other (1) 
2018 

2017 

$ 

519  $ 

13 
532 

2,121 
894 
3,015 

— 
34 
34 

503  $ 
8 
511 

478  $ 

12 
490 

81  $ 
(1) 
80 

86  $ 
(2) 
84 

86  $ 
(2) 
84 

—  $ 
— 
— 

—  $ 
— 
— 

2,111 
916 
3,027 

2,197 
928 
3,125 

— 
94 
94 

— 
97 
97 

156 
192 
348 

— 
1,738 
1,738 

161 
184 
345 

— 
1,780 
1,780 

147 
182 
329 

— 
2,049 
2,049 

24 
— 
24 

(33) 
— 
(33) 

22 
— 
22 

— 
8 
8 

66 
(1) 
65 

21 
— 
21 

— 
(21) 
(21) 

1,227 
574 
1,336 
3,137 
6,718 
235 
2,855 

(255) 
1 
(1) 
(255) 
(190) 
618 
(2,297) 
$  9,808  $  9,008  $  9,510  $  11,699  $ 12,326  $ 11,698  $  (2,616)  $  (2,257)  $  (1,869) 

(197) 
1 
— 
(196) 
(166) 
1,368 
(3,459) 

(185) 
— 
1 
(184) 
(193) 
1,615 
(4,038) 

1,172 
742 
1,557 
3,471 
7,183 
134 
2,193 

1,090 
648 
1,153 
2,891 
6,523 
260 
2,225 

1,495 
698 
103 
2,296 
4,505 
7,260 
561 

1,588 
756 
133 
2,477 
4,939 
6,203 
556 

1,555 
610 
123 
2,288 
4,454 
7,065 
180 

Bank of America 2019  179 
Bank of America 2019  179

   
 
 
 
 
 
 
Business Segment Reconciliations 

(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 

Segments’ total assets 
Adjustments (1): 

ALM activities, including securities portfolio 
Elimination of segment asset allocations to match liabilities 
Other 

Consolidated total assets 

2019 

2018 

2017 

$ 

94,221  $ 

93,255  $ 

88,990 

241 
(2,623) 
(595) 
91,244  $ 
28,808 

202 
(1,580) 
27,430  $ 

(325) 
(1,300) 
(610) 
91,020  $ 
28,403 

(222) 
(34) 
28,147  $ 

161 
(1,100) 
(925) 
87,126 
21,034 

154 
(2,956) 
18,232 

$ 

$ 

December 31 

2019 
2,209,613  $ 

2018 
2,159,041 

$ 

721,806 
(565,346) 
68,006 
2,434,079  $ 

669,204 
(540,798) 
67,060 
2,354,507 

$ 

(1)  Adjustments include consolidated income, expense and asset amounts not specifically allocated to individual business segments. 

NOTE 25 Parent Company Information 
The following tables present the Parent Company-only financial information. 

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 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 

2019 

2018 

2017 

$ 

$ 

27,820 
— 
9,502 
74 
37,396 

451 
5,899 
1,641 
7,991 
29,405 
341 
29,064 

$ 

28,575 
91 
8,425 
(1,025) 
36,066 

235 
6,425 
1,600 
8,260 
27,806 
(281) 
28,087 

(1,717) 
83 
(1,634) 
27,430  $ 

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 

180 180

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 $4 million and $389 million at December 31, 2019 and 2018. 

Condensed Statement of Cash Flows 

(Dollars in millions) 

Operating activities 
Net income 
Reconciliation of net income to net cash provided by (used in) operating activities: 

Equity in undistributed (earnings) losses of subsidiaries 
Other operating activities, net 

Net cash provided by operating activities 

Investing activities 
Net sales (purchases) of securities 
Net payments to subsidiaries 
Other investing activities, net 

Net cash used in investing activities 

Financing activities 
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 

December 31 

2019 

2018 

$ 

5,695  $ 

656 

173,301 
51 
391 

297,465 
3,663 
9,438 
490,660  $ 

5,141 
628 

152,905 
195 
969 

293,045 
3,432 
14,696 
471,011 

13,381  $ 

8,828 

458 
12,102 
199,909 
225,850 
264,810 
490,660  $ 

349 
13,301 
183,208 
205,686 
265,325 
471,011 

$ 

$ 

$ 

2019 

2018 

2017 

$ 

27,430 

$ 

28,147 

$ 

18,232 

1,634 
16,973 
46,037 

(17) 
(19,121) 
7 
(19,131) 

(1,625) 
29,315 
(21,039) 
3,643 
(2,568) 
(28,144) 
(5,934) 
(26,352) 
554 
5,141 
5,695  $ 

(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 

$ 

Bank of America 2019  181 
Bank of America 2019  181

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NOTE 26 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 

2019 
2018 
2017 
2019 
2018 
2017 
2019 
2018 
2017 
2019 
2018 
2017 
2019 
2018 
2017 
2019 
2018 
2017 

$ 

2,122,734  $ 
2,051,182 

102,440 
94,865 

178,889 
185,285 

30,016 
23,175 

311,345 
303,325 

$ 

2,434,079  $ 
2,354,507 

81,236  $ 
80,777 
74,604 
3,491 
3,507 
3,405 
5,310 
5,632 
7,907 
1,207 
1,104 
1,210 
10,008 
10,243 
12,522 
91,244  $ 
91,020 
87,126 

30,699  $ 
31,904 
25,108 
765 
865 
676 
921 
1,543 
2,990 
369 
272 
439 
2,055 
2,680 
4,105 
32,754  $ 
34,584 
29,213 

25,937 
26,407 
15,550 
570 
520 
464 
672 
1,126 
1,926 
251 
94 
292 
1,493 
1,740 
2,682 
27,430 
28,147 
18,232 

(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. 

182 182

Bank of America 2019 

Bank of America 2019

       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 2019  183 
Bank of America 2019  183

   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Acronyms 

ABS 
AFS 
ALM 
ARR 
AUM 
AVM 
BANA 
BHC 
BofAS 
BofASE 
bps 
CAE 
CAO 
CCAR 
CDO 
CDS 
CET1 
CFPB 
CLO 
CFTC 
CLTV 
CRO 
CVA 
DIF 
DVA 
EAD 
EMRC 
EPS 
ERC 
EU 
FCA 
FDIC 
FDICIA 

FHA 
FHFA 
FHLB 
FHLMC 
FICC 
FICO 
FLUs 
FNMA 
FTE 
FVA 
GAAP 

GDPR 
GLS 
GNMA 

Asset-backed securities 
Available-for-sale 
Asset and liability management 
Alternative reference rates 
Assets under management 
Automated valuation model 
Bank of America, National Association 
Bank holding company 
BofA Securities, Inc. 
BofA Securities Europe SA 
basis points 
Chief Audit Executive 
Chief Administrative Officer 
Comprehensive Capital Analysis and Review 
Collateralized debt obligation 
Credit default swap 
Common equity tier 1 
Consumer Financial Protection Bureau 
Collateralized loan obligation 
Commodity Futures Trading Commission 
Combined loan-to-value 
Chief Risk Officer 
Credit valuation adjustment 
Deposit Insurance Fund 
Debit valuation adjustment 
Exposure at default 
Enterprise Model Risk Committee 
Earnings per common share 
Enterprise Risk Committee 
European Union 
Financial Conduct Authority 
Federal Deposit Insurance Corporation  
Federal Deposit Insurance Corporation  
Improvement Act of 1991  
Federal Housing Administration 
Federal Housing Finance Agency 
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 
General Data Protection Regulation 
Global Liquidity Sources 
Government National Mortgage Association 

GSE 
G-SIB 
GWIM 
HELOC 
HQLA 
HTM 
ICAAP 
IRM 
IBOR 
IRLC 
ISDA 

LCR 
LGD 
LHFS 
LIBOR 
LTV 
MBS 
MD&A 

MLGWM 
MLI 
MLPCC 
MLPF&S 
MRC 
MSA 
MSR 
NOL 
NSFR 
OCC 
OCI 
OREO 
OTC 
OTTI 
PCA 
RMBS 
RSU 
SBLC 
SCCL 
SBSDs 
SEC 
SLR 
SOFR 
TDR 
TLAC 
VA 
VaR 
VIE 

Government-sponsored enterprise 
Global systemically important bank 
Global Wealth & Investment Management 
Home equity line of credit 
High Quality Liquid Assets 
Held-to-maturity 
Internal Capital Adequacy Assessment Process 
Independent Risk Management 
Interbank Offered Rates 
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 
Merrill Lynch Global Wealth Management 
Merrill Lynch International 
Merrill Lynch Professional Clearing Corp 
Merrill Lynch, Pierce, Fenner & Smith Incorporated 
Management Risk Committee 
Metropolitan Statistical Area 
Mortgage servicing right 
Net operating loss 
Net Stable Funding Ratio 
Office of the Comptroller of the Currency 
Other comprehensive income 
Other real estate owned 
Over-the-counter 
Other-than-temporary impairment 
Prompt Corrective Action 
Residential mortgage-backed securities 
Restricted stock unit 
Standby letter of credit 
Single-counterparty credit limits 
Security-based swap dealers 
Securities and Exchange Commission 
Supplementary leverage ratio 
Secured Overnight Financing Rate 
Troubled debt restructurings 
Total loss-absorbing capacity 
U.S. Department of Veterans Affairs 
Value-at-Risk 
Variable interest entity 

184 184

Bank of America 2019 

Bank of America 2019

       
Disclosure Controls and Procedures 

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 
(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 
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. 

Bank of America 2019  185 
Bank of America 2019  185

   
 
 
 
 
 
 
Executive Management Team and Management Committee  
Bank of America Corporation 

Executive Management Team 
Brian T. Moynihan* 
Chairman of the Board and  
Chief Executive Officer 

Management Committee** 
Michael C. Ankrom, Jr. 
Global Banking Chief Risk Officer 
and Enterprise Credit Risk Executive 

Dean C. Athanasia* 
President, Retail and Preferred 
& Small Business Banking 

Catherine P. Bessant* 
Chief Operations and 
Technology Officer 

Sheri B. Bronstein* 
Chief Human Resources Officer 

Paul M. Donofrio* 
Chief Financial Officer 

Anne M. Finucane 
Vice Chairman, Bank of America 

Geoffrey S. Greener* 
Chief Risk Officer 

Christine P. Katziff 
Chief Audit Executive 

Kathleen A. Knox* 
President, Private Bank 

David G. Leitch* 
Global General Counsel 

Thomas K. Montag* 
Chief Operating Officer 

Thong M. Nguyen* 
Vice Chairman, Bank of America 

Andrew M. Sieg* 
President, Merrill Lynch Wealth 
Management 

Andrea B. Smith* 
Chief Administrative Officer 

Bruce R. Thompson 
Vice Chairman and President of 
European Union and Switzerland 

Keith T. Banks 
Vice Chairman, Wealth Management & 
Head of Investment Solutions Group 

Aditya Bhasin 
Consumer, Small Business & Wealth 
Management, Global Human Resources, 
Corporate Audit & Credit Review, Legal 
Technology, Third-Party Management 
and Workspace Services Executive 

Alexandre Bettamio 
President, Latin America 

Rudolf A. Bless 
Chief Accounting Officer 

D. Steve Boland 
Head of Consumer Lending 

Alastair M. Borthwick 
Head of Global Commercial Banking 

Candace E. Browning-Platt 
Head of Global Research 

James P. DeMare 
Co-Head of Global Fixed Income, 
Currencies & Commodities Trading 

Fabrizio Gallo 
Head of Global Equities 

Matthew M. Koder 
Head of Global Corporate and 
Investment Banking 

Aron D. Levine 
Head of Consumer Banking and 
Investments 

Bernard A. Mensah 
President of United Kingdom and 
Central & Eastern Europe, the Middle 
East and Africa and Co-Head of 
Global Fixed Income, Currencies & 
Commodities Trading 

Sharon L. Miller 
Head of Small Business 

Andrei Magasiner 
Treasurer 

E. Lee McEntire 
Investor Relations Executive 

Lauren A. Mogensen 
Global Compliance and Operational 
Risk Executive 

Tram V. Nguyen 
Global Corporate Strategy Executive 

Holly O’Neill 
Head of Consumer, Small Business & 
Wealth Management Client Care 

David Reilly 
Global Banking & Markets, Enterprise 
Risk & Finance Technology, and Core 
Technology Infrastructure Executive 

Lorna R. Sabbia 
Head of Retirement and Personal 
Wealth Solutions 

Robert A. Schleusner 
Head of Wholesale Credit 

April Schneider 
Head of Consumer & Small Business 
Products 

Thomas M. Scrivener 
Consumer, Small Business & Wealth 
Management Operations Executive 

Jiro Seguchi 
Co-President of Asia Pacific, and 
Head of Asia Pacific Global Corporate 
and Investment Banking 

Jin Su 
Co-President, Asia Pacific and 
Co-Head of Asia Pacific Fixed Income, 
Currencies & Commodities 

David C. Tyrie 
Head of Consumer & Small Business 
Advanced Solutions and Digital Banking 

Anne Walker 
Global Real Estate and Strategic 
Initiatives Executive 

Ather Williams III 
Head of Business Banking and Global 
Banking and Markets Anti-Money 
Laundering 

Sanaz Zaimi 
Head of Global Fixed Income, 
Currencies & Commodities Sales and 
Country Executive, France 

* Executive Officer 

** All members of the Executive Management Team are also members of the Management Committee 

184  Bank of America 2019

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Board of Directors 
Bank of America Corporation 

Board of Directors 
Brian T. Moynihan 
Chairman of the Board and  
Chief Executive Officer, 
Bank of America Corporation 

Jack O. Bovender, Jr. 
Lead Independent Director,  
Bank of America Corporation;   
Former Chairman and   
Chief Executive Officer, HCA Inc.  

Sharon L. Allen 
Former Chairman, Deloitte LLP 

Susan S. Bies 
Former Member, Board of Governors 
of the Federal Reserve System 

Frank P. Bramble, Sr. 
Former Executive Vice Chairman,  
MBNA Corporation 

Pierre J.P. de Weck  
Former Chairman and Global Head 
of Private Wealth Management, 
Deutsche Bank AG 

Arnold W. Donald 
President and Chief Executive Officer, 
Carnival Corporation and Carnival plc 

Linda P. Hudson 
Former Chairman and Chief Executive 
Officer, The Cardea Group, LLC;  
Former President and Chief Executive 
Officer, BAE Systems, Inc. 

Monica C. Lozano 
Chief Executive Officer, College 
Futures Foundation; Former Chairman, 
US Hispanic Media Inc. 

Thomas J. May 
Former Chairman, President, and Chief 
Executive Officer, Eversource Energy 

Lionel L. Nowell III 
Former Senior Vice President and 
Treasurer, PepsiCo, Inc. 

Denise L. Ramos 
Former Chief Executive Officer, ITT Inc. 

Clayton S. Rose 
President, Bowdoin College 

Michael D. White 
Former Chairman, President, and 
Chief Executive Officer, DIRECTV 

Thomas D. Woods 
Former Vice Chairman and Senior 
Executive Vice President, Canadian 
Imperial Bank of Commerce 

R. David Yost 
Former Chief Executive Officer, 
AmerisourceBergen Corporation 

Maria T. Zuber 
Vice President for Research and 
E.A. Griswold Professor of Geophysics, 
Massachusetts Institute of Technology 

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Bank of America 2019  185

 
 
 
  
 
 
 
  
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
  
 
 
 
 
 
   
   
 
Corporate Information 
Bank of America Corporation 

Headquarters 
The principal executive offices of Bank of America 
Corporation (the Corporation) are located in the Bank 
of America Corporate Center, 100 North Tryon Street, 
Charlotte, NC 28255. 

Annual Report on Form 10-K 
The Corporation’s 2019 Annual Report on Form 10-K is available 
at http://investor.bankofamerica.com. The Corporation also 
will provide a copy of the 2019 Annual Report on Form 10-K 
(without exhibits) upon written request addressed to: 

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, 2019, there were 163,072 registered holders 
of the Corporation’s common stock. 

Investor Relations 
Analysts, portfolio managers and other investors seeking 
additional information about Bank of America stock 
should contact our Equity Investor Relations group at 
1.704.386.5681 or i_r@bankofamerica.com. For addi-
tional information about Bank of America from a credit 
perspective, including debt and preferred securities, 
contact our Fixed Income Investor Relations group at 
1.866.607.1234 or fixedincomeir@bankofamerica.com. Visit 
the Investor Relations area of the Bank of America website, 
http://investor.bankofamerica.com, for stock and dividend 
information, financial news releases, links to Bank of America 
SEC filings, electronic versions of our annual reports and 
other 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. 

News Media 
News media seeking information should visit our online 
newsroom at http://newsroom.bankofamerica.com for 
news releases, press kits and other items relating to the 
Corporation, including a complete list of the Corporation’s 
media relations specialists grouped by business specialty 
or geography. 

Bank of America Corporation 
Office of the Corporate Secretary 
Bank of America Corporate Center 
100 North Tryon Street  
NC1-007-56-06 
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. 

Electronic Delivery 
As part of our ongoing commitment to reduce paper 
consumption, we offer electronic methods for customer 
communications and transactions. Customers can sign up to 
receive online statements through their Bank of America or 
Merrill Lynch Wealth Management account website. In 2012, 
we adopted the SEC’s Notice and Access rule, which allows 
certain issuers to inform shareholders of the electronic 
availability of Proxy materials, including the Annual Report, 
which significantly reduced the number of printed copies 
we produce and mail to shareholders. Shareholders still 
receiving printed copies can join our efforts by electing to 
receive an electronic copy of the Annual Report and Proxy 
materials. If you have an account maintained in your name at 
Computershare Investor Services, you may sign up for this 
service at www.computershare.com/bac. If your shares are 
held by a broker, bank or other nominee, you may elect to 
receive an electronic copy of the Proxy materials online at 
www.proxyvote.com, or contact your broker. 

186  Bank of America 2019

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Bank of America 2019 Annual Report

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Investment products: 

Are Not FDIC Insured 

May Lose Value 

Are Not Bank Guaranteed 

“Bank of America” and “BofA Securities” are the marketing names used by the Global Banking and Global Markets 
divisions of Bank of America Corporation. Lending, other commercial banking activities, and trading in certain 
financial instruments are performed globally by banking affiliates of Bank of America Corporation, including 
Bank of America, N.A., Member FDIC. Trading in securities and financial instruments, and 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, BofA Securities, Inc. and Merrill 
Lynch Professional Clearing Corp., both of which are registered broker-dealers and Members of SIPC, and, in other 
jurisdictions, by locally registered entities. BofA Securities, Inc. and Merrill Lynch Professional Clearing Corp. are 
registered as futures commission merchants with the CFTC and are members of the NFA. 

Bank of America is a marketing name for the Retirement Services business of Bank of America Corporation 
(“BofA Corp.”). Banking activities may be performed by wholly owned banking affiliates of BofA Corp., including 
Bank of America, N.A., member FDIC. 

Merrill Lynch, Pierce, Fenner & Smith Incorporated (also referred to as “MLPF&S” or “Merrill”) makes available 
certain investment products sponsored, managed, distributed or provided by companies that are affiliates of 
Bank of America Corporation (“BofA Corp.”). MLPF&S is a registered broker-dealer, registered investment adviser, 
Member SIPC, and a wholly owned subsidiary of BofA Corp. 

BofA Global Research is research produced by BofA Securities, Inc. (“BofAS”) and/or one or more of its affiliates. 
BofAS is a registered broker-dealer, Member SIPC, and wholly owned subsidiary of Bank of America Corporation. 
Bank of America Private Bank is a division of Bank of America, N.A., Member FDIC, and a wholly-owned subsidiary 
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. 

Zelle and Zelle-related marks are wholly owned by Early Warning Services, LLC and are used herein under license. 

1. 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 further details. 
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. 

2. Mobile Banking requires that you download the Mobile Banking app and is only available for select mobile 

devices. Message and data rates may apply. 

3. You are not liable for fraudulent Online and Mobile Banking transactions when you notify the bank within 60 days 
of the transaction first appearing on your statement and comply with security responsibilities. See Section 5 of 
our Online Banking Service Agreement for full terms and conditions. 

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. More information can be found at www.bankofamerica.com/awards. 

© 2020 Bank of America Corporation. All rights reserved. 

Printed on 30% recovered fiber content. By using this paper, Bank of America is helping to reduce greenhouse 
gas emissions and water consumption. Leaf icon is a registered trademark of Bank of America Corporation. 

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