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Bank of America

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FY2020 Annual Report · Bank of America
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Coming together  
in new ways

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Annual Report 2020

 
 
 
 
 
 
 
 
 
CONTENTS

  1  A letter from Chairman and CEO 

Brian Moynihan

10  Measuring stakeholder capitalism

11  A message from outgoing  
Lead Independent Director  
Jack Bovender

11  A message from incoming  
Lead Independent Director  
Lionel Nowell

14  Addressing a global health crisis  

as one company

18  Q&A with D. Steve Boland and  

Aron Levine: Working together to 
meet clients’ changing needs in a 
challenging year

19  Growth of digital banking, lending 

and investing at Bank of America

20  Q&A with Matthew Koder:  

Delivering for our clients with  
defining differentiators

21  A message from Bernie Mensah: 
Making significant progress  
internationally

22  Delivering innovative wealth  

solutions and exceptional client 
service

23  What sets us apart:  
BofA Global Research

24  Serving our clients and communities 

through technology

25  Market Presidents deliver our  
global company to each client,  
employee and community

29  Supporting emotional wellness  

and mental health

30  Continuing to be a workplace where 
all teammates can grow and thrive

32  Being a great place to work —  

2020 highlights 

33  Investing $1 billion over four years  
to advance racial equality and  
economic opportunity

34  A conversation with Anne Finucane 

and Karen Fang: Addressing  
the world’s challenges through  
sustainable finance

26  A message from Sheri Bronstein: 

36  2020 ESG highlights

Being a great place for our  
teammates to work  

28  Driving meaningful change when  

the world needs it most

38  Financial highlights

39  Recognition

40  Stakeholder Capitalism Metrics

A letter from Chairman and CEO Brian Moynihan

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 hope this finds you safe and well. 

It is my pleasure to share with you the 2020 Bank of 
America Annual Report. Our report documents how 
your company responded to the impacts — both 
humanitarian and financial — of the global health 
crisis. It describes how we responded to the social 
and racial justice issues that moved to the forefront 
in 2020. The pages also tell the story of how our 
company came together in new ways to deliver 
for our shareholders, our teammates, our clients, 
our communities and to help address society’s 
biggest challenges. 

I begin this letter by thanking my 213,000 
teammates and our senior management team. 
I thank them for their extraordinary efforts over 
the past 12 months, and for everything they do to 
support our clients, and each other, every day. 

outgoing Lead Independent Director, Jack Bovender, 
for all he has done for our company and those we 
serve. As we announced in September 2020, Lionel 
Nowell III takes over this important role. Lionel is an 
experienced leader and has been a valued member 
of our Board for the past eight years. Jack and 
Lionel share their perspectives on the past 
year, and what lies ahead, on page 11.

Looking at our 2020 results, one thing is clear: 
Our decade-long focus on Responsible Growth 
prepared us well for this crisis. It allowed us to be 
a source of stability for our customers and clients 
during challenging times, to continue supporting the 
communities in which we work and live and deliver 
more consistent results for our shareholders through 
a well-understood risk framework. You can see the 
impact of Responsible Growth in the chart below. 

I would also like to thank our Board of Directors for 
their leadership and guidance throughout 2020. In 
particular, I would like to extend my gratitude to our 

Despite the impacts of the global health crisis, 
which resulted in a historically low interest rate 

2010 to 2014: Dramatic  
net income volatility 
(billions)

2015 to 2020: Net income  
reflecting Responsible Growth¹ 
(billions)

$5.5

$3.2

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2010

2011

2012

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2014

2015

2016

2017

2018

2019

2020

BANK OF AMERICA 2020   |   1

¹ 4Q 2017 net income of $5.3B represents a non-GAAP financial measure. GAAP net income of $2.4B excludes $2.9B related to the adoption of the Tax Cuts and Jobs Act. 
 
environment and a period of market volatility, your company 
earned $17.9 billion in net income, or $1.87 per share. 
Moreover, we ended 2020 with more capital, more deposits, 
record liquidity and improved capital ratios. We did this while 
increasing support for our clients. 

In March of 2020, the stock price for banks in general saw 
a sharp drop as the health crisis unfolded and investors 
contemplated potentially large credit losses and revenue 
declines from interest rates and a paucity of economic activity. 
From those lows, bank stocks made a steady recovery as  
fears moderated, ending the year modestly down from the  
start of the year. 

Our stock price declined 49% in March from the beginning 
of 2020 and then saw a 68% recovery, ending the year down 
14%. This was in line with the broader bank index but below 
the broader market rise of 16%. Despite the 2020 decline, 
our stock price has outperformed the broader bank index on a 
3-year and 5-year basis. As we prepare to issue this report in 
late February 2021, the price is up 14% this year, reflecting the 
improved economic outlook.

During 2020, we delivered $12 billion in capital back to 
shareholders through dividends and net share repurchases. We 
did this even as we halted share repurchases late in the first 
quarter of 2020 in line with additional federal bank regulatory 
restrictions. We have resumed share repurchases in the first 
quarter of 2021 from a position of strength with $36 billion of 
capital above our minimum regulatory requirements. 

Our results in 2020 built onto a solid foundation established 
by focusing on Responsible Growth for the past decade. We 
have a strong balance sheet, a best-in-class suite of products 
and capabilities — including our industry-leading digital 
capabilities — and a global team of dedicated professionals 
that is second to none. We are well-positioned to continue 
delivering for our shareholders, and all those we serve, in  
2021 and beyond.

We believe we must continue to deliver these strong results 
and help make progress on important societal priorities. That is 
core to how we run our business and drive Responsible Growth. 

In 2020, we also continued to make meaningful progress 
on important issues that affect us all. During the year, we 
accelerated our longstanding work to promote racial equality 
and economic opportunity, with a $1 billion, four-year 
commitment aimed at supporting jobs, healthcare, housing 
and businesses. While we were pleased to see commitments 
being made by other companies and organizations, we 
have moved quickly to get money moving to our priority 
areas of focus. So far, we have invested in jobs and skills 
training at 11 historically Black colleges and universities and 
11 community colleges. We have delivered over 20 million 
masks and other personal protective equipment (PPE) to 

2   |   BANK OF AMERICA 2020

5-year stock performance

80.1%

45.8%

34.0%

BAC

BKX
Index1

U.S. LC
Peers2

5-year total shareholder return

98.7%

64.7%

53.1%

BAC

BKX
Index1

U.S. LC
Peers2

1 The BKX Index consists of 24 stocks selected from the  

largest U.S. regional and nationwide banking companies.

2 Total shareholder return includes stock price appreciation and dividends 

paid. U.S. Large Cap (LC) Peers include JPM, C, WFC, GS and MS.

Brian Moynihan
Chairman and CEO

community partners, nonprofits, and other venues. We have 
invested in 14 Minority Depository Institutions (MDIs) to help 
them grow and serve their communities. We have increased 
our overall commitment to Community Development 
Financial Institutions (CDFIs) to $1.7 billion — making Bank 
of America the largest private sector CDFI funder. And, we 
have agreed to invest in 61 minority-owned or -focused 
venture capital or private equity funds in communities around 
the U.S., which will deliver more equity into thousands of 
minority-owned small businesses. You can find out more 
about our commitment to racial equality and economic 
opportunity on page 33. 

We also continued to support the transition to a low-carbon, 
sustainable economy, through our operations, our business 
activities and our partnerships. This includes our commitment 
to a goal of achieving net-zero carbon emissions by 2050. 

Responsible Growth 
There are four pillars to Responsible Growth.

•  We must grow in the market, no excuses. 

•  We must grow with a customer focus.

•  We must grow within our risk framework. 

•  We must grow in a sustainable manner. 

I’ll discuss each of these in turn, and the ways our team in 2020 
delivered on these pillars. 

Grow in the market, no excuses
What could we do in an economy to help our clients and grow? 

We supported our clients in lockdown with our various customer 
assistance programs. We supported small businesses with 
Paycheck Protection Program (PPP) loans. We supported wealth 
management clients with advice, expertise and execution in 

BANK OF AMERICA 2020   |   3

volatile markets. We supported commercial clients with our 
strong balance sheet that provided more than $70 billion in loans 
in a few-week period, and raised $772 billion in capital over the 
course of the year. For institutional investors, it meant having the 
market expertise and insights, trading capabilities and access to 
enable them to navigate through. 

All of this, and more, allowed us to continue to serve clients 
relatively uninterrupted by the pandemic, even as volumes 
surged. We played our part, with our industry colleagues, in 
helping ensure economies around the world, and here in the 
U.S., recover more quickly. In the end, that is the role of the 
bank. Your company executed that role well. 

But we believe it was our planning and investments over the 
past decade that made this all work. We supplied needed capital 
and liquidity to borrowers. Our investments in digital client 
interfaces across our client groups allowed us to maintain a 
close relationship with our clients, as they moved seamlessly to 
digital check deposits, payments, banking and investing. On the 
commercial side, we had invested in our CashPro application, 
which allowed our clients to safely and securely move billions 
of dollars every day. We used automated signature capabilities 
to allow clients to complete estate plans, borrow or invest — all 
with the same security as doing it in person. With institutional 
investors, we moved quickly to supply liquidity and a strong and 
resilient platform to support their activities and help assure 
stability of the financial system. 

And we grew. 

In 2020, average deposits increased 18% year-over-year to 
approximately $1.6 trillion. In Consumer Banking, we added 
$115 billion in average deposits during the year, cementing  
our position as the #1 bank in the U.S. by retail deposits.  
We leveraged our leading digital capabilities to serve our 
consumer clients how, when and where they chose to bank  
with us. Across all consumer sales in 2020, 42% of sales  
came through digital channels.

During the year, we also enrolled more than one million clients 
into our flagship loyalty program, Preferred Rewards, driving 
total membership to 7.2 million. Preferred Rewards recognizes 

Revenue¹,² FY2020
(billions)

Net income³ FY2020  
(billions)

$85.5B

$17.9B

 Note: Amounts may not total due to rounding.
¹ Business segment results are reported on a fully taxable-equivalent (FTE) basis with remaining operations recorded in All Other with revenue of ($3.6B). 
² Total revenue, net of interest expense, on a GAAP basis is $85.5B and $86.0B on an FTE basis, a non-GAAP financial measure. The FTE adjustment is $499M. 
³ Net Income of $17.9B includes a net loss of $407M in All Other. 

4   |   BANK OF AMERICA 2020

Global Markets$5.2Global Markets$18.8Consumer$6.5Consumer$33.3Global Banking$3.5Global Banking$19.0GWIM$3.1GWIM$18.6and rewards clients for their entire relationship with us, and we 
continue to see 99% retention rates from our members.

We brought our top retail bank brand to new markets in 
the U.S., including markets in Ohio and Utah, while building 
our presence in existing markets. According to our internal 
research, we continued to gain share in key markets. In 25 of 
the top 30 markets across America — representing over half of 
the U.S. population — we now hold the #1, #2 or #3 position. 
That is twice as many markets as our closest peer and includes 
14 markets in which we hold the #1 position.

During the year, our wealth management team found new 
ways to connect with, and deliver for, our Merrill and Private 
Bank clients. On page 22, we take a closer look at how  
our advisors continued to support clients and helped 
them navigate a changing environment. We added  
roughly 22,000 Merrill and 1,800 Private Bank relationships  
in 2020, and ended the year with client balances at all-time 
highs of $3.3 trillion. 

For the companies we serve, we begin with our small business 
clients. Apart from the role we played as the largest lender 
in the federal government’s PPP by number of loans, we also 
continued as the largest small business lender in the country 
overall, ending the year with more than $32 billion in small 
business loan balances. We also deployed our new merchant 
services capabilities.

For our commercial clients, the year was difficult as they had 
to absorb massive changes to the business cycle brought by 
the health crisis. We were there for them. Early in the year, 
we supported their borrowing rush as they sought liquidity in 
February, March and April. As conditions stabilized, we helped 
with market access for them to raise needed and permanent 
capital. We continued to bring digital capabilities to ensure 
their businesses could run smoothly, even in a work-from-home 
environment. The results for us were a surge in loans to these 
businesses. We peaked at $585 billion in commercial loans; by 
year-end those were down to $499 billion. 

Our investment banking team recorded $7 billion in total 
investment banking fees and posted three of the strongest 
investment banking quarters in our history. Our performance 
in this business helped us gain market share and retain the 
#3 market position, thanks to the efforts of our talented 
team. Matthew Koder, President of Global Corporate 
& Investment Banking, looks back on his team’s 
accomplishments on page 20.

In Global Markets, full-year sales and trading revenue for 2020 
increased 18% year-over-year to $15 billion. During the year 
we continued to push our innovative capabilities in electronic 
trading forward to help win mindshare with some of our largest 
clients. At the same time, our own research team was again 
ranked as one of the top Global Research Firms by Institutional 

Investor—placing as one of the top two firms for each of the 
past 10 years. You can read more about our award-winning 
research capabilities on page 23. 

Each of our businesses contributed to our results, and the 
diversity of our offerings served us well through a dynamic market 
environment. It will continue to serve us well as we look forward. 

Grow by focusing on our clients
Last year, thanks to the commitment of our teammates, the 
strength of our platform and our focus on Responsible Growth, 
we achieved the highest client satisfaction scores in company 
history. That is a credit to each and every member of our global 
team, who work hard to serve our customers and clients — and 
exceed their expectations — in every interaction. 

In 2020, that included far-ranging measures to support those 
impacted by the health crisis, through our own relief programs 
and those provided by the federal government. We processed 
approximately 2 million payment deferral requests as part 
of our Client Assistance Program. We processed more than 
16 million Economic Impact Payments (EIP), totaling more than 
$26 billion in the initial round of U.S. government stimulus 
payments — and continued processing additional payments 
following subsequent relief legislation.

As the largest PPP lender by number of PPP loans in the first 
three rounds of the program, in 2020 we helped more than 
343,000 small business clients — in every industry, every 
market — receive PPP loans, delivering more than $25 billion 
in PPP loan funds to businesses in need. We began accepting 
applications for PPP loans once again in January 2021, in  
line with a new round of federal PPP lending. Once again, we 
are among the top lenders in the program. 

At the same time, we remained focused on supporting the 
everyday financial needs of millions of clients. With additional 
health and safety measures in place, our teams continued to 
serve individuals and businesses across our nationwide network 
of approximately 4,300 financial centers and 17,000 ATMs. I’d 
like to offer a special thanks to my teammates in the financial 
centers who have played an essential role for our clients and 
communities through this health crisis. 

Not surprisingly, we also saw a growing number of clients 
choose to connect with us digitally during 2020. Our ten-plus 
years of sustained investment into technology — such as 

39.3M

digital customers  
at year-end, up 3% over 2019

BANK OF AMERICA 2020   |   5

artificial intelligence (AI) — and our award-winning digital 
platforms ensured we could continue to serve our clients when 
they needed us most. 

In Consumer Banking, we ended 2020 with 39.3 million digital 
customers, up 3% over 2019. They connected with us nearly 
11 billion times. Our roughly 13 million active Zelle® users, both 
consumers and small businesses, sent approximately $141 billion 
in transfers in 2020. To put that into perspective, that’s almost 
50% of the payments made by our 38 million consumers  
and small businesses using their credit cards. 

More than 17 million of our digital banking clients use Erica®, 
our AI-based virtual financial assistant, to do everything from 
checking their balances to paying their bills. Erica will also 
reach out to help if, for example, a client’s balance is at risk 
of going below $0 in the next week, or if a merchant charges 
them twice. Erica continues to gain knowledge and evolve in 
response to client needs. For example, at the beginning of 
the health crisis, Erica learned 60,000 new pandemic-related 
intents in a matter of days. In 2020 alone, Erica completed 
135 million client requests.

In September, we launched LifePlan®, which gives clients the 
power to select what’s most important to them and receive 
personalized insights — through both high-tech and high-touch 
interactions — to help them achieve their financial needs and 
goals. By the end of 2020, our clients had created more than 
2 million plans, one of the fastest product rollouts in our history. 

Our digital platforms also allow us to extend further into our 
communities, allowing millions of clients to access services and 
connect into the broader economy. In 2020, we added Balance 
Assist™, a low-cost, digital-only alternative to payday-type 
loans. Balance Assist, which allows clients to borrow up to 
$500 for a $5 flat fee, joins our existing suite of safe banking 
solutions, including SafeBalance™ and Secured Card. D. Steve 
Boland, President of Retail, joins Aron Levine, President 
of Preferred and Consumer Banking & Investments, to 
discuss how these products can help provide financial 
freedom and stability for clients on page 18. 

$1B

In 2020, our team generated 
more than 1,700 ideas to 
drive operational excellence, 
saving the company nearly 
$1 billion. 

6   |   BANK OF AMERICA 2020

Digital connectivity was also fundamental to our success in 
wealth management, and we saw digital engagement for 
wealth management clients climb to record levels. By the 
end of 2020, 77% of Merrill Lynch households and Private 
Bank clients were using online or mobile banking. Our 
digital platforms also allowed for effective advisor-client 
communications, which became a critical part of relationship 
building as the pandemic continued. 

In Global Banking, our CashPro® platform helped more CFOs 
and other business leaders efficiently and securely manage 
their cash flow from their offices and homes—and on their 
mobile devices. Our roughly 500,000 CashPro users drove a  
40% increase in platform sign-ins in 2020. Here, too, we 
applied the power of AI for our clients, digitally matching 
19 million incoming receivables in a 12-month period using  
our Intelligent Receivables® solution. 

Stepping back, what we saw in 2020 was the impact of years 
of investment in capabilities and digital access across our 
platform and our businesses. And what was unique is that even 
in areas where we had heretofore experienced customers or 
employees traditionally preferring to operate in a face-to-face, 
physical world, we saw dramatic changes. We had a record 
year in new $10 million or higher relationships in Global Wealth 
& Investment Management (GWIM), yet we were unable to 
have many face-to-face meetings. We had a record year in 
investment banking fees, yet all of our “pitch” meetings with 
clients were virtual. We saw record movement in money by our 
consumer customers yet we had up to 30% of our financial 
centers closed for safety. The implications for the long term are 
yet to be borne out. But we are confident that the investments 
we have made set us on the correct course.

I want to call out our technology and operations team, who 
showed creativity and excellence in execution by positioning all 
of our client-facing teammates to be able to operate in a work-
from-home environment. In four weeks, our tech and ops team 
deployed 100,000 computers and screens to those teammates. It 
was no small task, and it enabled us to continue to serve clients 
who themselves were adjusting to the pandemic conditions. 

Grow within our risk framework
Growing within our established risk framework is integral to how 
we drive Responsible Growth. Our principled approach to risk 
management allowed us to continue supporting our customers 
and clients against the backdrop of one of the worst economic 
declines in U.S. history, driven by the global pandemic. 

At the onset on the health crisis, we took immediate action to 
strengthen our reserves for credit losses. We ended 2020 with 
nearly $21 billion in credit reserves, more than twice what we 
had at the end of 2019. Together with our existing capital, we 
have substantial reserves available to manage potential losses. 
Credit losses were much lower than many expected, but we 
were confident our underwriting would hold up, and it did. In 
fact, our actual charge-offs moved from $3.6 billion in 2019 to 
$4.1 billion in 2020, a slight increase.

On the markets side, our team led by Tom Montag and Jim 
DeMare navigated the markets very well and we had a strong 
year of trading revenue. More importantly, we provided support 
for our institutional clients. And we had only a handful of days 
with trading losses.

We continue to actively monitor and assess the impacts — both 
direct and indirect — of the health crisis and other potential 
risks through our risk management framework. And we continue 
to drive out operational risk from the company through our 
focus on operational excellence. 

Grow in a sustainable manner 
To drive Responsible Growth, we must ensure that our growth is 
sustainable. There are three complementary and interdependent 
tenets to how we approach sustainable growth: driving 
operational excellence, being the best place for teammates  
to work and sharing our success with our communities. 

Driving operational excellence 
While “operational excellence,” “organizational health,”  
“simplify and improve” and other terms we use may sound  
a little mechanical, they are instrumental to our success.  
In 2015, your company had $57 billion in expenses. In 2020, 
we had $55 billion, including roughly $1.5 billion in net 
coronavirus-related costs. Compared with 2015, we have 
more customers and clients and more transactions — so more 
work. Yet costs are down and headcount is down. During 
those six years, we invested about $18 billion in technology 
initiatives, added 15% more sales teammates, opened 300 
financial centers and refurbished 2,000 more. All of these 
investments were made while costs came down. We continue 
to apply the practice of operational excellence to enable us 
to produce strong returns above our cost of capital while 
investing back into our company and our capabilities. This 
will provide powerful leverage as interest rates rise and the 
economy continues to recover and grow. 

Operational excellence is as much a mindset as it is a program. It 
describes the ways in which we drive continuous improvement, 
reduce operational risk and seek to find faster, simpler and more 
efficient ways of working and serving our clients. 

This work is fueled by the ingenuity and creativity of our 
teammates, who continuously look for ways we can do things 
better. In total, we’ve approved nearly 8,600 of their ideas, 
which commit to delivering billions in expense savings. In 2020 
alone, our team generated more than 1,700 ideas that helped 
us define commitments to save nearly $1 billion. We reinvested 
those savings back into our team, our capabilities, our client 
experience, our communities and our shareholders. 

For example, savings from operational excellence help fund 
the ongoing modernization of sites across our real estate 
portfolio, including renovating our financial centers to deliver 
a client-focused interior and exterior design and full support 
for digital transactions.

It’s important to note we made investments like these 
in 2020 — and many more described throughout this 
report — while at the same time returning $12 billion in  
net capital to our shareholders. And — as you will see 
discussed elsewhere in this report — we invested in our 
team, including the fourth consecutive year of company-wide 
supplemental bonuses, increasing our minimum hourly rate  
of pay for U.S. employees and keeping medical expenses down 
for our lesser-paid teammates.

Being a great place to work for our teammates 
Attracting and retaining the best talent is key to driving 
Responsible Growth and one of our top priorities. It helps us 
manage our operations, provide the best service for our clients 
and support our communities. 

We strive to make Bank of America a great place to work 
for all teammates. And we fulfill this commitment by being 
a diverse and inclusive workplace, attracting and developing 
talent, recognizing and rewarding performance and supporting 
teammates’ physical, emotional and financial wellness. On 
page 26, Sheri Bronstein, our Chief Human Resources 
Officer, shares her thoughts on our progress in 2020 and 
what it means for the future.

Our workforce must reflect the communities we serve. As 
highlighted in our 2020 Human Capital Management Report, we 
have continued to make progress in our goal to ensure diverse 
representation at all levels of our company. Fifty percent of our 
management team is diverse, and Bank of America is one of 
only five S&P 100 companies with six or more women on the 
Board. And over the past decade, the number of people of color 
we hire in the U.S. from universities has increased by 50%. 

1 of 5

Bank of America is one of 
only five S&P 100 companies 
with six or more women  
on the Board.

$20

In 2020, we raised our 
minimum hourly rate of pay 
for U.S. teammates to $20.

BANK OF AMERICA 2020   |   7

We want our teammates to build long-term careers with Bank 
of America. And that starts with a competitive starting wage 
and benefits. We moved to our minimum hourly rate of pay 
for U.S. teammates of $20 — roughly $42,000 per year — one 
year earlier than planned. And we offer ongoing training and 
development resources to help those teammates grow and 
thrive within our organization. We hire with a career mindset. 
And we work to reskill our teammates.

For teammates earning lower salaries, we provide higher 
company subsidies for medical premiums. Since 2012, there 
has been no increase in medical premiums for teammates 
earning less than $50,000.

To support our teammates during the health crisis, at work and 
at home, we expanded many of our benefits and resources. 
This included additional support for mental health, free virtual 
consultations and no-cost coronavirus testing. 

Sharing our success with our communities
One of the ways we ensure our growth is sustainable is by 
sharing our success with the communities in which we work 
and live. We invest significant time and money to help address 
issues facing our local communities and society at large, and 
commit all of our business activities and operations to the task. 

This begins with our $250 million in annual corporate 
philanthropy. To this, we added another $100 million in 2020 
to increase access to food and medical supplies in local 
communities.

Individual giving by my teammates, combined with matching 
gifts from Bank of America, amounted to more than $65 million 
in additional philanthropic support in 2020. To maximize 
the impact of each employee gift, we lowered the employee 
matching gift minimum to $1 and doubled our match for 
employee donations to 17 organizations through 2020.

As the pandemic hit, we knew our teammates were going to 
be under pressure at home. For most of them, home was their 
workplace. For our 40,000 teammates with children, home was 
often a school or daycare. For many teammates with aging 
parents, home became an assisted living space. Our teammates 
needed help. We offered them $100 per day to hire that help. 
More than 3 million days of care have been provided. This 
helped our teammates immensely — they have told us. And it 
also allowed them to serve our clients better. 

We also support our communities through our lending and 
investing activities. In 2020, for example, we provided a record 
$5.87 billion in loans, tax credit equity investments and other 
real estate development solutions, and deployed $3.62 billion 
in debt commitments and $2.25 billion in investments to help 
build strong, sustainable communities by financing affordable 
housing and economic development across the country. 
Between 2005 and 2020, we financed more than 215,000 
affordable housing units. 

In 2020, we came together to support one another like never 
before. It was a great reflection of the commitments, the 
compassion and the people that make our company a great 
place to work. 

$2B

We issued a $2 billion equality 
progress sustainability bond 
designed to advance racial 
equality, economic opportunity and 
environmental sustainability.

$1B

We launched a $1 billion  
corporate social bond, the first 
issued by a U.S. commercial  
bank to entirely focus on fighting  
the pandemic.

8   |   BANK OF AMERICA 2020

In May of 2020, we launched a $1 billion corporate social 
bond, the first issued by a U.S. commercial bank to entirely 
focus on fighting the pandemic. We followed that up with an 
industry-first $2 billion equality progress sustainability bond 
designed to advance racial equality, economic opportunity and 
environmental sustainability.

Our commitment to racial equality and economic opportunity 
demonstrates the way in which we approach major societal 
issues and align all of our resources to help drive progress 
locally. Our investments and partnerships in this work are 
targeted at strategic areas in which we already are a leader: 
jobs, healthcare, housing and businesses. By providing 
even sharper focus, we seek to make a lasting impact on 
underserved minority entrepreneurs and communities. You 
can read more about how we are executing on our 
$1 billion commitment and a broader update on our work 
in sustainable finance in the discussion between Vice 
Chairman Anne Finucane and Global Sustainable Finance 
Executive Karen Fang on pages 33–35.

The most important way we shape our engagement in local 
communities is through our market president organization. Our 
network of 90 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. We talk more about how our presidents support 
our clients and communities on page 25.

Driving profits and purpose
The principles of stakeholder capitalism are embedded in 
Responsible Growth. We deliver for our clients, our employees, 
our communities and our shareholders and, at the same time, 
do our part to deliver progress against society’s biggest 
challenges. This includes our work to support the health 
and safety of our teammates, the many ways we help the 
communities we serve grow and prosper, our efforts to 
promote racial equality and economic opportunity and our 
ongoing drive toward a clean energy future. 

Stakeholder capitalism is not a new concept, even if its recent 
focus makes it seem that way. As a financial institution, 
our success has always been tied to the success of the 
communities and markets we serve. In recent years, business 
organizations including the U.S. Business Roundtable, the 
World Economic Forum and others have helped create broader 
awareness of the ways that companies must think about 
delivering long-term value — for shareholders, of course, but for 
all of our other stakeholders, too. 

Helping address societal issues can stimulate the commitment 
of private sector capital to help drive even more progress. 
And there’s growing evidence to back that up. As our Global 
Research team has found, companies that pay close attention 
to environmental, social and governance (ESG) priorities are 
much less likely to fail than companies that do not, giving 

investors a significant opportunity to build investment 
portfolios for the long-term. And — through research and our 
own lived experience — we know that ESG commitments can 
translate into a better brand, more client favorability and a 
better place for our teammates to work.

There is an important discussion underway about the role 
capitalism plays in our society and the ways in which it must 
evolve to ensure all participants in our economic system 
are treated fairly and rewards are available equitably. Public 
companies have an important role to play to help drive 
that discussion. At Bank of America, we embrace our dual 
responsibility to drive both profits and purpose. And we work 
with organizations and leaders around the world to champion 
these ideals and drive meaningful progress. We need a way to 
measure that and in 2020 we made substantial progress on 
that front, too.

Measuring and delivering long-term value
To help society make progress toward important goals you 
need to know two things.

First, you need to understand what society’s priorities are.  
And we do. The countries of the world identified those 
priorities in 2015, when nearly 200 countries agreed to the 
United Nations (U.N.) Sustainable Development Goals (SDGs). 
The SDGs reflect 17 categories of societal priorities that 

$2.82

$1.80

$2.43

$2.35

$2.19

$2.28

$1.38

$1.43

$1.26

$1.31

2016

2017

2018

2019

2020

2016

2017

2018

2019

2020

$2.8T

$1.8T

BANK OF AMERICA 2020   |   9

Total assets (trillions)Total deposits (trillions)$2.19$2.28$2.35$2.8220162017201820192020$2.43$1.26$1.31$1.38$1.43$1.8020162017201820192020Measuring  
stakeholder capitalism

The International Business Council, with the 
collaboration of the accounting firms Deloitte, 
KPMG, PwC and EY, compiled a set of common ESG 
Stakeholder Capitalism Metrics disclosures. These 
metrics are compiled from leading ESG standards-
setters, including the Task Force on Climate-related 
Disclosures (TCFD), the Sustainability Accounting 
Standards Board (SASB), the Global Reporting 
Initiative (GRI) and others. As discussed in CEO Brian 
Moynihan’s shareholder letter in this report, the goal 
of the Stakeholder Capitalism Metrics is to provide 
investors and other stakeholders a common set  
of standards by which to evaluate the progress the 
company is making to address the societal priorities 
agreed to in the SDGs. The metrics include  
non-financial disclosures in four categories: people, 
planet, prosperity and principles of governance.

Nearly 70 global companies have agreed to begin 
using the Stakeholder Capitalism Metrics, and many 
more are evaluating them for their own use. Bank of 
America is a founding member of His Royal Highness 
the Prince of Wales’ Sustainable Markets Initiative 
(SMI), which seeks to harness the creativity, the 
innovation and the balance sheets of businesses 
around the world to help drive long-term growth in 
a globally sustainable fashion. In December 2020, 
under the guidance of His Holiness Pope Francis 
and His Eminence Cardinal Peter Turkson, Bank 
of America joined an alliance of business leaders 
and companies around the world as part of the 
Vatican’s Council for Inclusive Capitalism (VCIC). 
Comprising companies that collectively have more 
than 200 million employees from over 163 countries, 
the VCIC illustrates how capitalism can take the lead 
in creating economic growth that is fair, responsible, 
trusted, dynamic and sustainable. The SMI, the VCIC, 
and similar organizations recognize the Stakeholder 
Capitalism Metrics as an important step toward 
providing the disclosures needed to measure the 
progress that private sector capitalism can help deliver 
in addressing important societal priorities.  

Given the cross-industry application of this set of 
common metrics, not each standard will apply to 
each company that is disclosing. Where a disclosure 
is not provided or not linked to another Bank of 
America disclosure, we provide a brief explanation. 
We share the long-term objective of other companies, 
asset owners and asset managers, key government 
regulators and the standards-setters themselves that 
eventually there will be a single set of non-financial 
ESG disclosure standards to help stakeholders 
evaluate companies in the same fashion that standard 
financial disclosures now permit.

address equality of opportunity, affordable housing, 
prosperity, access to clean water, renewable energy, and 
other priorities, with specific goals to be met. Leaders 
in each country agreed these goals are the ones we 
need to address to build a sustainable future and create 
opportunity and prosperity for all.

Second, you need to know how to measure progress. The 
International Business Council (IBC), which I am privileged 
to chair, has compiled a set of Stakeholder Capitalism 
Metrics aligned to the SDGs. These metrics create a 
consistent way of measuring companies’ long-term value, 
across industries. This, in turn, helps direct investment 
toward high performers and align capital to progress on 
the SDG and ultimately defines stakeholder capitalism. It 
also aligns capitalism’s innovation, its entrepreneurship 
and its massive resources to the progress, which won’t be 
made without the private sector.

In September, the IBC — working with the accounting 
firms Deloitte, EY, KPMG and PwC — released a set of 
21 core metrics, and 34 expanded metrics, aligned to 
the themes of people, planet, prosperity and principles 
of governance. As of January 2021, Bank of America 
and nearly 70 other global corporations have agreed 
to implement reporting on the Stakeholder Capitalism 
Metrics, and the coalition continues to grow. Later in 
this Annual Report you can see our initial set of 
Stakeholder Capitalism Metrics disclosures. 

At Bank of America, we drive progress on the SDGs 
through all of our efforts and activities. We do so 
through our operations, our philanthropy, our human 
resources practices, our client financing capabilities 
and the guidance we provide to investor clients. We 
bring our $2.8 trillion balance sheet, our $55 billion 
expense base and the trillions of dollars we raise 
each year for our clients to the task. And, critically, 
we commit the considerable ingenuity, innovation and 
passion of our team.

For over a decade, we have focused on driving 
Responsible Growth so that we can create value for 
every stakeholder and for society — through every 
economic environment. Our focus on Responsible Growth 
positioned us well as we faced the unforeseen challenges 
of 2020, and positions us well as we look to the future. 
We remain committed to delivering for our shareholders, 
our teammates, our clients, our communities and to 
making a positive impact on the world for years to come. 

On behalf of my 213,000 teammates, our management 
team and the Board of Directors, I thank you for your 
support of Bank of America.

10   |   BANK OF AMERICA 2020

Brian Moynihan 
March 1, 2021

A message from outgoing  
Lead Independent Director Jack Bovender

the execution of the strategy through 
regular, systematic interaction with  
company management. In performing 
our duties, we are mindful of 
developments in the markets, the 
economy and geopolitical issues 
that may impact the execution of 
the strategy. 

Our responsibility is to assess 
opportunities and risks and determine 
how well the company is adhering to 
the tenets of Responsible Growth that 
drive the company’s strategy. CEO Brian 
Moynihan discusses this in greater 
detail in his nearby letter and you will 
see it brought to life in the articles 
and disclosures throughout this report. 
The tenets of Responsible Growth 
include the company’s ESG practices. 
Our Corporate Governance, ESG and 
Sustainability Committee reviews and 
reports to the board on the company’s 
activities in these areas. This includes, 
for instance, the company’s 
recently 
announced commitment to net-zero 
greenhouse gas emissions by 2050. 

As many of you know, I will be retiring 
from our board at the time of the 
annual meeting. Since becoming 
the Lead Independent Director of 
Bank of America, I have had the privilege 
of meeting annually with many of our 
shareholders. The feedback from these 
meetings has been invaluable and I  
have routinely shared it with the 
board. It has significantly shaped our 
approach to fulfilling our governance 
responsibilities. For more detailed 
information, please review this 
2020 Annual Report, our 2021 Proxy 
Statement and our Human Capital 
Management Report. 

At the annual meeting, Lionel Nowell  
will assume the role of Lead 
Independent Director. Lionel is totally 
committed to his new role and  
will continue our practice of meeting 
regularly with our shareholders.

It has been both an honor and pleasure 
to serve as Lead Independent Director. 
On behalf of Brian, Lionel and the  
other directors, thank you for investing 
in Bank of America.

Dear shareholders: 

Thank you for investing in Bank of  
America. The directors bring 
independent and diverse perspectives  
to our task of helping create long-term  
value for you. We represent a range 
backgrounds and skills, 
of expertise, 
including chief executives and others 
who have served in senior risk, 
operations, finance, technology and 
human resources positions. 

This mix of expertise and experience is 
beneficial throughout the year, including 
in the fall when the management team 
presents the company strategy for the  
board to review and approve. We oversee  

A message from incoming  
Lead Independent Director Lionel Nowell

director in January 2013, and I have 
appreciated the opportunity to oversee 
the development and execution of  
the company’s strategy for long-term 
Responsible Growth. Fifteen of the 
company’s 16 directors are independent 
and we bring our unique perspectives  
to each of our board and committee 
meetings. 

Our discussions among ourselves  
and with the company’s management 
are grounded in facts and data. I  
am particularly pleased with the level 
of detail we regularly disclose to our 
investors, including in the 2020 Human 

Capital Management Report and other 
non-financial disclosures we make 
to give you as clear a piCture of our 
company as we can. 

I also value the insights I receive when  
I speak with shareholders; I intend to  
maintain a consistent rhythm of 
engagement in the same fashion as my  
predecessor, Jack Bovender. I want to  
thank Jack for his impressive leadership as 
our Lead Independent Director, and I look 
forward to assuming those responsibilities 
after the 2021 annual meeting. 

Thank you again for your investment in 
our company. 

BANK OF AMERICA 2020   |   11

To my fellow shareholders:

I join Brian Moynihan, Jack Bovender and 
the other directors in thanking you for  
choosing to invest in Bank of America.  
I began my service as a Bank of America 

Bank of America  
Board of Directors

Brian T. Moynihan
Chairman of the Board and 
Chief Executive Officer

Sharon L. Allen

Susan S. Bies

Jack O. Bovender, Jr.

Frank P. Bramble, Sr.

Pierre J.P. de Weck

Arnold W. Donald

Linda P. Hudson

Monica C. Lozano

Thomas J. May

Lionel L. Nowell III

Denise L. Ramos

Clayton S. Rose

Michael D. White

Thomas D. Woods

R. David Yost

Maria T. Zuber

We set the tone at the top through oversight by our Board 
of Directors, who oversee our corporate strategy. In addition, 
the heads of our eight lines of business as well as key 
leadership for International and our institutional client base 
make up our Executive Management Team.

12   |   BANK OF AMERICA 2020

Bank of America  
Executive Management Team

Brian T. Moynihan
Chairman of the Board and 
Chief Executive Officer

Raul A. Anaya
President, Business Banking

Dean C. Athanasia
President, Retail and Preferred 
& Small Business Banking

Catherine P. Bessant
Chief Operations and 
Technology Officer

D. Steve Boland
President, Retail

Alastair M. Borthwick
President, Global  
Commercial Banking

Sheri B. Bronstein
Chief Human Resources 
Officer

James P. DeMare
President, Global Markets

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

Matthew M. Koder
President, Global Corporate  
& Investment Banking

David G. Leitch
Global General Counsel

Aron D. Levine  
President, Preferred and 
Consumer Banking & 
Investments

Bernard A. Mensah
President, International

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,  
Bank of America

Sanaz Zaimi
Head of Global Fixed Income, 
Currencies and Commodities 
Sales; CEO of BofA Securities 
Europe SA, and Country 
Executive for France

BANK OF AMERICA 2020   |   13

Addressing a global health  
crisis as one company

We’re united in helping our teammates, clients and communities — when and 
where they need us most.

In 2020, our company rallied as we never have before — across every business and in 
cities and towns around the world — to respond to the health and humanitarian crisis 
affecting individuals, families and business owners in the communities where we live 
and work. Our services are essential to our clients and to the economy. Through our 
global presence and longstanding focus on addressing critical social issues, we’ve taken 
care of our teammates and their families, delivered for our clients when and where  
they needed it most and supported relief efforts around the world. And, together, we 
ended 2020 stronger and more committed to the people and causes we care about.

14   |   BANK OF AMERICA 2020

Supporting the health and safety  
of our teammates

Our teammates’ health and safety is always our top priority. 
Since the coronavirus was first identified, we have taken many 
broad-ranging steps to protect all of our teammates and to 
support their families.

to teammates impacted by the coronavirus, and we continue 
to offer 24/7 confidential counseling through our Employee 
Assistance Program (EAP) for teammates and their 
immediate family members. 

• We seamlessly transitioned about 85% of our employees 
to work from home, including any teammate who identified 
as high-risk. For employees who identify as high-risk, many 
have been redeployed to roles they can perform remotely. 

• To ensure our employees maintain access to critical 

medical resources, we have provided no-cost telehealth  
resources with 24/7 virtual access to general medicine 
doctors and mental health specialists, home delivery service 
of preventative prescription medications with a temporarily 
waived refill waiting period and no-cost coronavirus testing. 

• To help address the personal impacts the environment has 
had on teammates and their families, we have expanded 
our back-up childcare for employees in the U.S., 
including providing nearly three million days of back-up child 
and adult care and an investment of nearly $300 million  
in child and adult care reimbursements in 2020 to help offset 
costs for our teammates. We have continued that support 
in 2021.

• Additionally, we have provided a variety of resources to help  

parents and caregivers as their children return to 
school (whether in-person or virtually), including a dedicated 
back-to-school website with webinars, articles, weekly tips 
and discounts on computers, devices and school supplies. 

• We also have added new physical and mental health  
resources, such as training for stress management, 
resiliency and mindfulness — and provided additional 
vacation and personal day flexibility. 

• We have expanded our dedicated team of Life Event  

Services (LES) specialists to provide personalized support 

Additionally, we have taken specific actions to support 
the health of our thousands of teammates working in the 
office — in our financial centers, operations centers and  
trading floors — and to recognize all our employees are doing 
in support of our clients, including: 

• Temperature checks, daily health screenings and  

onsite nurses at many of our sites. We will continue to 
expand these measures prior to additional employees 
returning to the office.

• Onsite coronavirus testing introduced for employees 
working in our financial centers and administrative 
buildings with more than 100 employees working in 
the office

• Enhanced deep cleanings of our facilities, installing 
thousands of wellness barriers and putting physical 
distancing markings in place for our employees and clients 

• Special compensation programs, including supplemental 
pay, enhanced overtime pay and other special incentives 
for employees working in our offices and buildings to 
serve clients 

• Transportation and meal subsidies, delivering more than 

three million meals to employees to-date 

These are just some examples of how we have supported our 
teammates and their families during this critical time. For 
more information on these and other programs and benefits 
we provide, read about our response to the coronavirus in  
our 2020 Human Capital Management Report.

BANK OF AMERICA 2020   |   15

Delivering for our clients

When our clients needed us most, our teammates redoubled 
efforts to help clients navigate the changes and challenges  
of 2020 in new and creative ways: transitioning from in-person 
to virtual interactions, using new technologies and launching 
client relief efforts. 

Specifically, we helped 343,000 small business clients receive  
loans through the Small Business Administration’s Paycheck 
Protection Program — extending more than $25 billion — and 
processed more than $26 billion of EIP for clients in 2020. We 
also processed nearly two million payment deferral requests. 

Employees around the world continued to provide advice, 
guidance and access to all our capabilities to help clients 
meet their financial needs. In particular, teammates have 
been proactively reaching out to clients across all businesses, 
including by sending millions of emails and placing outbound 
calls to Consumer & Small Business clients, holding thousands 
of calls, meetings and broadcasts to actively advise and 
connect with Merrill Lynch Wealth Management and Private 
Bank clients, and issuing proactive guidance and market 
insight from our BofA Global Research and Investment Insights 
teams through multiple channels, including virtual investor 
conferences. 

Our employees have also delivered critical financial relief for 
clients through our programs as well as efforts launched by the 
federal government. 

16   |   BANK OF AMERICA 2020

343,000

We have helped 343,000 small 
business clients receive loans 
through the Small Business 
Administration’s PPP.

Investing in our communities 

Additionally, to help address the impact of the coronavirus in our  
communities, we donated important PPE to communities 
across the U.S., including more than 22 million face coverings, 
nearly 3 million gloves and more than 17,000 cases of sanitizer 
through early February 2021.

We pledged $100 million toward medical supplies, food 
security and other vital support, and an additional $250 million 
to community development financial institutions (CDFIs) 
to provide more companies and not-for-profits access to 
important capital.

And, in recognition of the broad and deep impact the 
humanitarian crisis is having on communities and people of 
color, we have made a $1 billion, four-year commitment to 
accelerate work underway to help advance racial equality  
and economic opportunity — specifically focused on workforce 
development, healthcare, housing and small-business 
assistance.

22M+

face coverings

3M

gloves

17,000+

cases of hand sanitizer

$100M

toward medical supplies,  
food security and other  
vital support

$250M

to CDFIs to provide more 
companies and not-for-profits 
access to important capital

$1B

4-year commitment to 
accelerate work underway  
to help advance racial equality 
and economic opportunity

Looking ahead to 2021 

While we made a tremendous impact in supporting our 
teammates, clients and communities in 2020, our work isn’t 
finished. The health crisis continues to affect the global 
economy as well as individuals and communities around the 
world. Our focus now is what else we can do — and how we 
can do it better. Throughout 2021 and beyond, we remain 
resolute in how we meet our clients’ changing needs, how we 
take care of our teammates and how we help our communities 
move forward in meaningful ways. 

BANK OF AMERICA 2020   |   17

Donating PPE in our communitiesInvesting in our communitiesWorking together to meet clients’  
changing needs in a challenging year

Q&A with D. Steve Boland, President, Retail and  
Aron Levine, President, Preferred and Consumer Banking & Investments

In 2020, Steve and Aron worked together to deliver exceptional service and a full suite of  
products and platforms to help make our clients’ financial lives better.

in our financial centers, we believe we can quickly adapt 
and respond to clients’ evolving needs. In 2020, we used 
our Client Assistance Program to help clients experiencing 
hardships related to the impact of the coronavirus and 
provided financial relief through the Coronavirus Aid, Relief 
and Economic Security Act and the PPP, as well as by 
processing EIP. 

Q. How is Bank of America meeting the needs of today’s 
mass affluent clients?  

Aron: Mass affluent clients have more diverse needs than 
ever before and are looking for advice and education to help 
them meet their banking, lending and investing goals. Our 
Preferred business is designed to provide these clients with 
streamlined ways to manage their finances and obtain advice 
and guidance when and wherever they want. We provide 
extensive rewards and benefits across their entire relationship 
with us — the more they do with us, the more their benefits 
grow. Throughout 2020, our high-tech digital capabilities 
together with our personalized high-touch approach allowed us 
to deliver a more intuitive and efficient banking experience for 
our clients across all of our channels, providing the expertise 
of financial professionals in our financial centers, Merrill 
offices, digitally and over the phone.

Q. Bank of America launched Balance Assist last year. 
What is it, and why was it the right thing to do? 

Steve: Balance Assist provides a unique low-cost, digital way 
for our clients to manage their short-term liquidity needs, 
borrowing only the amount they need, up to $500. We believe 
people want the power to achieve financial freedom and 
stability, and are seeking simple, clear solutions and advice  

Q. What did you learn from clients last year, and how did 
you respond to their changing needs? 
Steve: Our clients needed to know that we would stand by 
them and help provide safe and reliable ways to help them 
manage their finances any time and any way they choose.  
We found that the best way to do this — and what our 
clients are most comfortable with — is through our award-
winning digital capabilities. Our high-tech and high-touch 
approach means that between our full-featured mobile and 
online platforms and the expert, personal service we offer 

“We’re in an advantageous 
position to provide the solutions 
and advice our clients need  
while helping them build their 
financial acumen.”

18   |   BANK OF AMERICA 2020

 
to help them along the way. Balance Assist is the latest in  
a set of transparent, easy-to-use solutions to help our clients 
budget, save, spend and borrow carefully and confidently.  
With solutions like SafeBalance Banking®, the Keep the Change®  
savings program, our secured credit cards and our affordable 
homeownership options, we’re in an advantageous position to 
provide the solutions and advice our clients need while helping 
them build their financial acumen.

Q. Clients often begin a financial relationship with Bank 
of America as young adults then progress to Retail, 
Preferred and beyond. How is Bank of America equipped 
to help clients at every stage of life? 

Aron: We are committed to meeting the full range of our 
clients’ needs, at every stage of their financial lives. To do so, 
we strive to develop strong partnerships across our Retail and 
Preferred businesses, as well as with Merrill and the Private 
Bank, to serve the needs of our clients along the full wealth 
spectrum. We introduced Bank of America Life Plan® to help 
clients set and track progress on their short- and long-term 
financial goals based on their life priorities and relationship 
with us. We’ve also invested heavily in providing quality 
financial education and developing industry-leading tools and 
resources, like Better Money Habits® and our new Idea Builder 
to help ensure clients are banking and investing with their 
financial goals in mind. Together, we offer a comprehensive 
relationship, and provide a streamlined way for clients to 
manage their finances with advice and guidance that grows 
along with them.

17.2

12.9

10.3

9.7

6.7

4.8

2018

2019

2020

 Zelle 

 Erica

“We are committed to meeting the  
full range of our clients’ needs, at every 
stage of their financial lives.”

Growth of digital banking, lending 
and investing at Bank of America

In 2020, our clients depended on our digital capabilities more  
than ever before, with 69% of our Consumer, Small 
Business and Wealth Management households generating 
nine billion logins. 

To better serve our clients, we invested in new technologies 
and enhanced our industry-leading digital capabilities, 
developed and deployed by Head of Digital David Tyrie and  
his team, in partnership with Chief Information Officer  
and Head of Consumer, Small Business & Wealth Management 
Technology Aditya Bhasin and his organization in Global 
Technology & Operations. 

Digital accounted for 42% of consumer sales, and our 
Consumer & Small Business households were reliant on  
our core digital capabilities, such as our digital financial 

assistant Erica®, Zelle® and Mobile Check Deposit, among 
many others, as well as our virtual (phone, video and chat) 
channels. The number of Erica users grew 67% over the course 
of the year, and Erica has helped clients with over 200 million 
requests since launch in 2018. Notably, Zelle transaction 
volume grew 71% year-over-year. Our automated channels 
(mobile, online and ATMs) accounted for 84% of deposits  
in 2020, up from 78% in 2019. 

We deliver a wealth of services through our mobile and online 
banking, ATM and Erica platforms, and are constantly exploring 
ways to expand, interconnect and perfect these tools to  
deliver a more seamless, personalized experience for each client  
that spans and supports their entire relationship with us.

BANK OF AMERICA 2020   |   19

Growth in Zelle and Erica users (millions)Delivering for our clients  
with defining differentiators

Q&A with Matthew Koder
President, Global Corporate & Investment Banking

For our Global Corporate & Investment Banking 
teammates and operational specialists, close 
coordination and enhanced communication 
was key to providing optimal financing and 
strategic solutions for clients while winning 
their confidence in 2020.

Q. How did your business stand out in 2020?

Matthew: Despite last year’s unprecedented uncertain market 
environment, we were relentless in helping our clients and 
distinguishing our business with many leading, innovative 
solutions. We provided support by advising across the entire 
capital structure and executing transactions across loans, 
bonds, convertibles, follow-ons, IPOs, private capital markets, 
mergers and acquisitions and more. Through it all, we believe 
the high volume of deals and transactions we completed on 
behalf of our clients repeatedly showed we had their trust  
and that our integrated corporate banking, investment banking 
and capital market services — along with the bank’s strong 
balance sheet, highly developed global platform and innovative 
solutions — were our defining differentiators. 

While 2020 may have physically separated us from our clients, 
it didn’t dampen the opportunity to stay connected, deepen 
relationships and drive enhanced value. We significantly 
increased the level of our communications with our clients  
and expanded our client base by leveraging local coverage 
teams and cross-business integration opportunities. We 
believe the more clients do with us, the more value we can 
offer them from our integrated resources and expertise.  
In addition, despite the complexities of the environment, we 
continued to enhance our client-facing platforms at a record 
pace to drive connectivity and efficiency and deliver smarter, 
faster and more secure digital experiences for clients.

Q. What were some of your key accomplishments 
in 2020?

Matthew: When our clients needed a strong financial partner 
through the crisis, we were committed to be there — approving 
over $100 billion in credit across approximately 500 requests. 
In addition, our team’s resilience and the seamless strength  
of our connections positioned us as the industry leader in  
re-opening the capital markets after the initial market 
dislocation resulting from the pandemic. By the end of 2020, 
we helped raise approximately $772 billion of capital in the 

20   |   BANK OF AMERICA 2020

global capital markets. This leadership and experience 
further provided us with critical insight into investor 
receptivity, which allowed us to advise our clients on 
optimal financing solutions across products, markets and 
geographies throughout the year. 

We believe all of these efforts resonated with our clients 
and translated into our ability to increase our investment 
banking fees by 27% in 2020. This resulted in a total  
of $7.2 billion in fees, which was a record for a full-year 
and also included three of the strongest quarters in 
our company’s history. In addition, we increased our 
investment banking industry ranking to #3 and grew our  
market share by 70 bps — including our highest ever 
share in equity capital markets and mergers and 
acquisitions. We see all of these as valuable indicators 
of our clients’ confidence in our people and capabilities.

Q. What impact did your business make on 
sustainable finance in 2020?

Matthew: Leadership in ESG and sustainable finance 
are valuable competitive differentiators for Bank of 
America. We’re always looking for innovative solutions 
for investors to support social and environmental 
change. The past year was particularly meaningful to 
us because our bankers and operations teams drove a 
number of industry-leading achievements. 

For example, we were the #1 global underwriter of 
corporate ESG-related bonds. In addition, we helped 
launch the world’s first sustainability-linked bond and 
led the first green convertible bond in the U.S. with 
a designated green use of proceeds. This particular 
accomplishment represented an important, innovative 
landmark, as it was the first time sustainable finance 
tools crossed over into the equity-linked market.  
We also underwrote nearly $50 billion in coronavirus-
related social bonds, helping a broad audience from 
corporations to national governments finance their 
pandemic responses.

Strong interest from our clients in these bonds shows 
that companies can do good and do well. There is a 
growing desire around the globe to support investments 
that have a positive societal impact. And, we’re proud to 
be at the forefront in delivering these solutions.

Q. Looking to 2021 and beyond, what do you want 
your clients to know?

Matthew: That we will continue to be there for them. In 
the long shadow of the health crisis and amidst so many 
transformational changes, we will continue to be there 
for our clients as their steadfast and trusted partner. We 
are committed to leveraging our resources and franchise 
to deliver for them — and grow with them — as the 
recovery takes root. 

Making significant  
progress internationally

A message from Bernie Mensah  
President, International

Our international presence, which spans approximately 
35 countries and territories, is vital to the thousands 
of corporate and institutional clients that we serve. We 
strive to provide rapid, on-the-ground access to our 
expansive platform and capabilities, exceptional market 
insight and a talented, diverse and dedicated employee 
base. Never has this been more important than in 
2020, a year of significant progress for our company 
internationally, notwithstanding the challenges of the 
health crisis. 

In Asia Pacific, we generated record revenues 
participating in the rapid growth of capital markets 
in the region and connecting investment capital to 
significant opportunities presented in many of the 
world’s fastest growing large economies. From China  
to Australia, and India to Japan, we provided critical 
advice on multiple transactions, helping clients to  
access primary capital and market liquidity as needed.

In Europe, Africa and the Middle East, despite the 
backdrop of more challenging economic conditions and  
political uncertainties, we continued to see our franchise 
advance with important new client gains in many 
product areas. In addition, after nearly four years of 
preparation, we successfully completed our thorough 
Brexit planning, making the necessary adjustments  
to ensure we could continue to seamlessly and 
efficiently service all clients in both the E.U. and the  
U.K. from our key hubs in Dublin, Paris and London  
and additional local offices. With Brexit uncertainties 
behind us, we now look forward to continuing to expand 
our market share across all our lines of business in 
the region.

We now are focused on building on our current 
momentum by continuing to drive Responsible Growth 
globally and meeting client needs in the year ahead.

BANK OF AMERICA 2020   |   21

Delivering innovative wealth solutions  
and exceptional client service 

The bank’s digital leadership also made it easier for us 
to provide more comprehensive service. With one click, 
clients can deposit checks, make transfers, pay their 
mortgage and see their credit card activity. During 2020, 
77% of wealth management clients used our online or 
mobile platforms and opened 107,000 bank accounts.

The importance of advice and guidance in a  
changing environment 
Throughout 2020, our clients and families expressed 
a greater need for comprehensive and personalized 
financial advice than at any time in the past. Our 
Chief Investment Office helped answer the call by 
providing valuable insights through its rapid-response 
commentaries, as well as through its industry-leading 
thought leadership and investment strategies, the 
latter comprising more than 100 managed investment 
platforms. 

Building wealth management for the future
In 2020, we continued to carry out our vision to be our 
clients’ trusted partners — providing support, helping 
them meet their needs and achieve their goals by 
providing helpful advice and service at every stage of 
their financial lives. We are led by advisor teams with a 
passion to serve and excel. Our exceptional colleagues 
are winning more top rankings than any other firm 
and multiple awards for their customer service and 
philanthropy expertise. And we are becoming more 
diverse, better reflecting the families, enterprises, 
institutions and communities we serve.

We believe Bank of America’s wealth management 
businesses are strongly positioned for the future, ready 
to answer the next set of challenging questions that 
comes. We will continue to strive to be an industry leader, 
and we will judge our performance on our success in 
helping our clients achieve their goals. 

Our focus on supporting our clients in  
Merrill Lynch Wealth Management and  
Bank of America Private Bank is stronger 
 — and more important — than ever 
before. To meet clients’ diverse needs and 
maintain the highest level of service as we 
helped them navigate the changes 2020 
presented, our advisors created new ways 
to deliver innovative solutions and the 
power of Bank of America’s capabilities 
and technology. As a result, we forged even 
deeper, more meaningful connections with 
our existing clients, while adding thousands 
of new relationships — and improving 
client satisfaction across the board.

Running a relationship business when people  
can’t come together 
As the environment changed, our wealth management 
businesses quickly transitioned to connecting with clients  
in new ways, including meeting virtually. Through rapid  
deployment of Webex video conferencing, 25,000 wealth 
teammates held approximately 375,000 virtual client  
meetings — five times more than the year before —  
engaging clients in wealth, estate and philanthropic 
planning conversations. Our teams also stayed connected 
virtually, setting strategy, sharing peer-to-peer learning 
and insights and recognizing success in new ways.

Expanding digital capabilities to meet clients’ needs
Throughout the year, we added a steady stream of digital 
enhancements to transform how we deliver advice and 
service. Working closely with our clients, we empowered 
them to embrace our digital innovations so they could 
access information, execute transactions and seamlessly 
collaborate with their advisors. 

For example, clients now use Mobile Easy Sign digital 
signatures for more than 80% of account opening and 
maintenance tasks. Through the Client Engagement 
Work Station, advisors can view all critical information 
regarding clients’ accounts which helps deliver a great 
experience. Another innovation, the Personal Wealth 
Analysis, is a single tool connecting clients’ goals to 
investment solutions. 

22   |   BANK OF AMERICA 2020

What sets us apart:  
BofA Global Research

Candace Browning 
Head of Global Research

Under the leadership of Candace Browning, BofA Global Research is constantly evolving  
with a singular focus — to best serve the needs of our clients. The division was named  
Top Global Research Firm by Institutional Investor magazine from 2011-2016 and in 2019,  
and the No. 2 firm in 2017, 2018 and 2020. More information about these awards can be  
found at https://go.bofa.com/awards.

A team of more than 675 analysts located in 20 countries 
provides recommendations on 3,300 stocks and 1,350 
corporate bond issuers globally across 24 sectors, as well as 
forecasts for 56 economies, forecasts for 26 commodities 
and recommendations on 47 currencies. The goal is to create 
innovative, collaborative and forward-looking research and 
deliver it in a variety of ways that suit our clients. 

44,000+

Delivered more than 44,000 
research reports

“Through strategic innovation and collaboration across regions,  
sectors and disciplines, our mission is to transform information  
into actionable investment insight,” said Browning. 

From major world events to deep-dives into sectors and 
industry-leading research on ESG impacts, the team leverages 
its knowledge, relationships and cutting-edge technology to 
uncover insights and trends. 

In 2020, during a year of unprecedented market volatility,  
BofA Global Research demonstrated its commitment to our 
clients by delivering more than 44,000 research reports and 
hosting nearly 3,000 conference calls. 

BANK OF AMERICA 2020   |   23

Serving our clients and  
communities through technology

Through our Global Technology & 
Operations team, we’re providing industry-
leading capabilities to drive client service 
and deepen relationships, faster and better.

There is no question that the events of the past year 
accelerated the use of digital capabilities by our clients 
across every line of business, with nine billion online and 
mobile logins in our consumer and wealth management 
businesses alone. We saw record-setting levels of use 
of our digital and electronic channels to conduct every 
element of our clients’ business — investing, savings, all 
the way up to our large institutional customers. 

invest approximately $3 billion annually in technology 
growth — especially in digital, mobile and online platforms.

Further driving the digital transformation is our culture 
of innovation. Last year, the bank ranked 108th on the 
Intellectual Property Owners Association’s list of the top 
300 U.S. organizations receiving patents, our highest 
ranking ever. That ranking reflects our company’s 
record-high 443 patents for innovations related to 
money transfers, bill payments, ATM transactions, check 
verification using augmented reality and authentication 
technology. The bank’s patent portfolio consists of more 
than 4,600 patents and applications, resulting from the 
work of more than 5,700 inventors from 12 countries.

People are interested in virtual connectivity and its 
ability to augment and, in some cases, replace physical 
connectivity. Add in the fact that we had no choice but 
to connect virtually, and our digital capabilities really 
worked to our advantage. 2020 has shown us that digital 
adoption will continue to grow. 

“Innovating is essential to making life easier for our 
clients,” said Cathy Bessant, chief operations and 
technology officer. “We do not have an innovation lab or 
an innovation team, because it’s everyone’s job. These 
numbers demonstrate our unmatched commitment to 
making sure innovation is part of our DNA.” 

Our clients’ rapid adoption of digital capabilities was  
made possible by work we began a decade ago. Back  
then, we started to simplify and modernize our  
technology and infrastructure, an intensive transformation  
that would support our businesses, help reduce risk and 
improve our competitive cost position. Through that 
work, we removed $2 billion annually from our operating 
expenses while replacing core platforms to create 
modern operations. 

During the world health crisis this past year, we realized 
the importance of connectivity, bandwidth and technical 
tools. We are using technology to bridge divides by 
helping to make sure connectivity is universal and equally 
available to all. We believe equity of access and service 
will drive economic mobility and equality going forward, 
and Bank of America will strive to be at the forefront  
of that change.

“Merrill benefits tremendously from the technology 
investments made by Bank of America over the past 
several years,” said Andy Sieg, president of Merrill  
Lynch Wealth Management. “Our best-in-industry  
digital capabilities continue to set Merrill apart from  
the competition, enabling clients to work with us  
when they want, how they want, while providing the 
seamless experience they demand.”

Shared platforms and a common infrastructure across 
the enterprise brought together company data and 
emerging technology to improve service, drive speed 
to market and increase data accuracy, while decreasing 
risk and improving cost to serve our clients. Our modern 
infrastructure and simplified operations underscore 
the importance of smart investments. We continue to 

24   |   BANK OF AMERICA 2020

Market Presidents deliver our global company 
to each client, employee and community

Hong Ogle
President, Bank of America Houston

In cities and towns across the U.S., Bank of 
America’s more than 90 market presidents and 
their teams lead the local work of the company 
to serve clients, support teammates and 
strengthen communities. In 2020, the efforts 
of our market presidents were more critical 
than ever, particularly in cities like Houston, 
Texas, that faced challenges on multiple fronts. 

“2020 will be a year to remember,” said Hong Ogle, 
president of Bank of America Houston, who also leads 
the Central South Division for the Private Bank region, 
overseeing offices in Texas, Kansas, Oklahoma, Arkansas 
and the surrounding states. “In addition to the health 
crisis, oil and gas price volatility added extra stress on 
Houston, the energy capital of the world. And, being the 
hometown to George Floyd pushed our city to the front 
lines of the racial justice movement.” 

Through it all, Hong says, the team remained undeterred, 
rising to the challenge to support teammates, serve  
clients and help the Houston community. Hong is especially 
complimentary of the financial center teammates who 
expertly cared for clients who needed our support and 
services throughout the health crisis and of commercial 
banking client managers, financial advisors and personal 
bankers who rallied to help their clients manage through 
changing conditions. 

Integrating our full capabilities for the benefit of each 
client is among the chief responsibilities of our market 
presidents, who help to ensure all lines of business are 
working together seamlessly. 

For example, last year, Houston teammates in Business 
Banking and the Private Bank came together to help a  
20-year, Houston-based client sell their company to another 
client in Ohio. The Houston-based client manager connected 
the Texas client to a local Private Bank advisor, ultimately 
helping them entrust the proceeds of the sale, along with 
other assets, to the Private Bank. This interaction highlights 
the value and importance of integration across our businesses 
in markets across the country.

Integrating our capabilities and expertise influences how 
market presidents and their teams address challenges  
facing their communities. After our four-year, $1 billion  
commitment to drive racial equality and economic  
opportunity was announced, the Houston team went to  
work, partnering with local elected officials and  
community leaders to help ensure the collective resources  
were spent wisely.

Hong also feels a personal connection to the commitment 
the company has made to driving equality and helps further 
these efforts locally in the Houston community. She came 
to the U.S. from China when she was 24, and is a leader 
in several company diversity groups as well as the city’s 
Greater Houston Partnership Racial Equity Committee. “I feel 
a strong responsibility to help make sure dollars are spent 
where it makes a difference,” she said. “It’s not just about 
giving money — it’s helping people and communities. And it’s 
helping not just those individuals who benefit directly from 
these programs; it’s also helping their families and future 
generations.”

This focus on clients and community led Bank of America  
to be named Large Corporation of the Year by the Association 
of Fundraising Professionals Greater Houston and Hong  
to be recognized as a Houston Business Journal Most Admired 
CEO in 2019, accolades that reflect the team’s work carrying 
forward the bank’s mission while making an impact locally. 

BANK OF AMERICA 2020   |   25

Being a great place  
for our teammates to work

A message from Sheri Bronstein  
Chief Human Resources Officer 

We know 2020 will be remembered for many 
reasons, including the global health crisis and  
the social and racial inequalities that were 
exacerbated by it. At Bank of America, it 
was a year that strengthened our resolve to 
identify additional opportunities to support 
our teammates and address societal issues. 
Together, we continued driving progress, and 
we have much to be hopeful for as we look 
ahead. And importantly, in 2020 we were 
reminded how critical it is that we take care 
of ourselves, our families, our clients, our 
communities and each other.

As a company, we have a long history of supporting our 
teammates and their families by investing in their physical, 
emotional and financial well-being. In response to the global 
health crisis, we took significant steps to provide enhanced 
resources and benefits to help our teammates stay healthy 
and balance the competing priorities of work and home. Those 
benefits include access to virtual medical and behavioral 
consultations, robust emotional wellness training through 
our partnership with Thrive Global and child and adult care 
resources designed to help our teammates ensure their loved 
ones were cared for. You can read more about our support for 
teammates on page 15. 

We also felt the urgency to address the ongoing impacts of 
racial inequality in the communities where we live and work. 
While diversity and inclusion is and has been core to our values 
as a company for multiple decades, it was a year in which 
we needed to bring together our efforts with our teammates 
and marry those with the work we do with our communities 
and clients. Our courageous conversations series served as a 
foundation for dialogue amongst our leaders, our teammates, 
visiting speakers and authors, and gave a platform for our  
$25 million charitable donation to the Smithsonian so they 
could facilitate conversations on race across our country 
through the eyes of one of our most important educational 

26   |   BANK OF AMERICA 2020

museums and institutions. Our longstanding efforts to 
drive economic opportunity and upward mobility provided 
the foundation for us to quickly accelerate efforts we had 
underway to create greater opportunities for people and 
communities of color. While we have much more to do, I am 
proud of the initiatives we’re advancing in connection to our 
$1 billion, four-year initiative focused on addressing systemic 
gaps in education, healthcare, workforce development, housing 
and other important areas. You can learn more about these 
efforts on page 33. 

Our deep appreciation for our teammates, their dedication to 
living our purpose and their support for each other remained 
at the core of every decision we made in 2020. And from last 
year, we learned incredible lessons: thanks to our teammates, 
our ability to remain resilient and the importance of our 
decade-long commitment to Responsible Growth, we were 
able to serve our clients and communities when they needed 
us most. As we begin a new year, our focus on supporting our 
teammates, their families and the clients and communities we 
serve will continue to guide everything we do. 

I also encourage you to read about our efforts to support 
the health and safety of our teammates as well as the 
work we’re doing to advance racial equality and economic 
opportunity in our 2020 Human Capital Management Report. 
We initially launched this report in 2019 as a means to provide 
transparency into our employee practices, our workforce 
diversity metrics and all that we do for our teammates to be a 
great place to work. It was the first-of-its-kind in the industry 
and has been met with overwhelmingly positive responses 
from our shareholders, our teammates and our clients. 

200,000+

We support our more than 
200,000 global teammates 
and their families through 
comprehensive benefits,  
programs and resources.

2020 Human Capital Management Report

In November, we released our 2020 Human Capital 
Management Report, which continues our efforts to 
provide clarity and transparency around all we do  
to be a great place to work and to support our more 
than 200,000 teammates and their families. Building 
on our inaugural Human Capital Management Report 
from 2019, our 2020 report shares the many programs 
and resources, as well as supporting data, in our 
primary focus areas: being a diverse and inclusive 
workplace; attracting and retaining exceptional talent; 
providing holistic benefits supporting our teammates’ 
physical, emotional and financial wellness; and 
recognizing and rewarding performance. 

New in this year’s report is information on the many 
unprecedented steps we have taken during the ongoing 
health crisis and to advance work underway to drive 
racial equality and economic opportunity. In addition, 
we continue to share metrics on diverse representation 
across our company, a practice we have had in place for 
many years. We will continue to report on these items 
and the progress we’re making as part of our ongoing 
focus on driving Responsible Growth and making this 
the best place for our teammates to work.

BANK OF AMERICA 2020   |   27

Driving meaningful change  
when the world needs it most

Our ongoing work to foster a diverse and inclusive 
environment took on greater meaning for our more than 
200,000 global teammates during a year that brought issues 
of racial inequality and social injustice to the forefront. The 
global health crisis has exposed longstanding disparities in 
our society and inspired one of the greatest social justice 
movements in modern history. 

These realities strengthened our resolve and inspired our work 
to right the injustices we’ve witnessed. We have a greater 
clarity of purpose for where we want to go as a company and 
in the communities where we live and work — as well as the 
work we need to do to get there.

This starts with being a great place for our teammates to 
work, which is foundational to continuing to drive Responsible 
Growth. We know we must reflect the diversity of the clients 
and communities we serve and continue to take meaningful 
steps to ensure diverse representation at all levels of our 
company. Attracting diverse talent is a priority, and we achieve 
this through a variety of recruiting efforts, including through 
internships and campus programs, targeted partnerships with 
diverse organizations, support for military and veterans, and 
hiring and reskilling individuals from low-and-moderate income 
(LMI) communities. “We know that just because you have 
diversity in representation does not mean you have inclusion. 
That’s why we continue to work to ensure we have a culture 
where our teammates feel comfortable bringing who they are 
to work each day and why we offer equal access to opportunity 

at all levels of our company,” says our Chief Diversity & 
Inclusion and Talent Acquisition Officer Cynthia Bowman. 

We also look to address societal priorities that impact 
communities around the world. In 2020, building on 
longstanding work underway, we made a $1 billion, four-year 
commitment to help drive racial equality and economic 
opportunity for people and communities of color with a focus 
on healthcare, jobs, small businesses and housing. We’ve also 
continued to deploy capital to businesses and communities 
in need of economic revitalization through CDFIs and issuing 
social bonds. 

Another way we actively promote these principles is by 
engaging each other through courageous conversations —  
sharing perspectives on our differences and establishing 
connections to create greater empathy and understanding. 
Last year, we held courageous conversations, reaching 
more than 165,000 employees with civil rights, social 
justice and inclusion leaders focused on racial, social and 
economic injustices. 

As we look to the work and road ahead, investing in our 
teammates, our clients and communities will always be core 
to who we are and how we drive Responsible Growth. By first 
looking inward and holding ourselves accountable to increasing 
diversity across our teams, we will continue taking steps 
forward to help drive inclusion and meaningful progress in the 
communities we serve.

28   |   BANK OF AMERICA 2020

Supporting emotional wellness  
and mental health

Supporting our teammates’ emotional wellness and mental 
health has always been a critical focus for us. In 2020, people’s 
daily lives and routines were impacted in many ways, bringing 
the conversation of emotional wellness and mental health 
to the forefront. Given the new stressors and demands our 
teammates faced over the year, it was important employees 
understood the range of resources available to support their 
emotional wellness and mental health. We enhanced our 
ongoing offerings to include innovative, industry-leading and 
flexible programs and resources to help our teammates and 
their families.

In 2020, we provided no-cost consultations with Teladoc’s® 
behavioral health specialists for employees on a national U.S. 
bank medical plan. We also expanded training and education 
to help teammates build key skills to enhance their well-being. 
Additionally, through our partnership with Thrive Global, a  
corporate and consumer well-being firm, we launched 
emotional wellness and resiliency training for employees. 
These virtual courses address stress management as well as 
ways to build resiliency and avoid burnout. Our mindfulness 
daily practice sessions and introductory courses hosted by 
internal specialists help teammates create and maintain peace 
of mind. In addition, ongoing mental health tips from experts, 
mindfulness apps and open conversations about mental health 
helped teammates prioritize their own wellness. 

Our ongoing work to care for our teammates’ emotional 
wellness and mental health includes confidential counseling 
and unlimited telephone consultations, available 24/7, through 
our Employee Assistance Programs for both teammates 
and members of their household. And, for support for 
major life events, our internal, highly specialized Life Event 
Services team connects employees to resources, benefits 
and counseling. 

“The last year taught us that prioritizing our  
emotional wellness and mental health  
was incredibly important. It was critical to 
ensure that our employees knew they,  
and their loved ones, were supported. As 
we move into 2021, our focus will stay  
the same — offering benefits, programs 
and resources to meet their diverse needs.”

—  Chris Fabro, Global Head of Compensation,  

Benefits and Executive Development

BANK OF AMERICA 2020   |   29

 
Continuing to be a workplace where  
all teammates can grow and thrive

In a year unlike any before, the diversity and broad perspectives of our teammates enabled us  
to make a positive impact for our clients and communities. We continue to invest heavily  
in our people — bringing diverse talent to our company, supporting their well-being and giving 
opportunities to grow and develop. Meet four exceptional women who bring their diversity  
of thought and experiences to life across our company.

Helping teammates  
care for their families 

Jessica Cullen
Global Banking & Markets
Global Commercial Banking Relationship Manager

Hiring the next  
generation of leaders 

Reena Shukla
Global Technology & Operations
EMEA Operations Executive 

Jessica Cullen, a relationship manager in Global Commercial 
Banking, and her husband started working from home in 
early 2020 due to the health crisis, while also caring for their 
two young daughters. With daycare centers closed, Jessica 
needed care for her children while working from home, 
so she looked into Bank of America’s expanded childcare 
benefits after hearing about them from her manager. Eligible 
teammates can take advantage of the bank’s expanded 
back-up care benefits, which include reimbursement of up 
to $100 a day when securing their own care provider. “It 
was super easy to sign up for the childcare benefit, and the 
reimbursement process is quick,” explains Jessica. She took 
advantage of the opportunity to hire someone from her 
personal network, and was thrilled to be able to help one of 
the teachers at her daughters’ daycare center who had lost 
income due to the coronavirus-related closures. “It’s good 
for her and good for us,” Jessica said. “The best part is my 
entire management team has been extremely supportive. 
The resources and empathy toward working parents make 
me really proud to work for Bank of America.”

30   |   BANK OF AMERICA 2020

London-based Reena Shukla believes exceptional talent can 
be found at all levels. After completing Merrill’s graduate 
recruitment program, she has grown her career and is now 
a managing director, leading the EMEA Client Services team 
for Global Markets. Reena is passionate about recruiting 
others early in their careers whose contributions can 
challenge the status quo and inspire new ways of thinking to 
strengthen our teams and client relationships — something 
she can relate to given her own experience with the  
bank’s recruiting efforts. Reena is focused on hiring 
teammates who demonstrate a natural curiosity to learn 
and challenge themselves. “Recruiting fresh talent pushes 
boundaries within our teams and enables new ideas for  
the ways we serve our clients,” explains Reena. Through  
Bank of America’s Africa recruitment initiative and the U.K. 
government apprenticeship program, Reena has built a 
balanced team with both experienced and new talent, with 
each providing significant contributions for future success. 
“Hiring talent early in their careers helps develop our  
future leaders, something that I have experienced firsthand 
at our company.”

Leading the way to a  
more inclusive environment 

Adrienne Hughes
Merrill
Client Experience Executive

As Merrill’s client experience executive, Adrienne Hughes 
recognizes the power of strong, authentic connections. She 
is personally committed to creating an inclusive culture 
that values, encourages and leverages the strength of our 
diversity. “Inclusion comes from celebrating our uniqueness 
and creating an environment where people are valued and 
encouraged to bring who they are to the workplace —
creatively collaborating to strengthen our business,” says 
Adrienne. Involved in several Bank of America Employee 
Networks, which help teammates be heard, develop 
leadership skills, build ties with peers and local communities 
and advance diversity recruitment, Adrienne has embraced 
her advocacy for inclusion in the workplace by using her 
voice and encouraging others to do the same. She has taken 
advantage of Bank of America’s passion for open and honest 
discussions and hosted several courageous conversations 
around race, equality and economic opportunity in the 
Chicago market. As a member of our Women’s Leadership 
Council and the Multicultural Women Ready to Lead 
Initiative, Adrienne also continues to be a leader for women’s 
equality in the workplace. “I am proud to work for a company 
that invests in creating a culture where every individual 
is valued. I’m inspired to lead by example and drive that 
commitment forward.” 

Helping teammates grow and  
develop fulfilling careers 

Evelyn Castillo
Consumer & Small Business
Consumer Banking Region Executive

After joining Bank of America in 2009, Evelyn Castillo, a 
Consumer Banking region executive, never imagined she 
would still be working at the same company nearly a decade 
later. Motivated by support from mentors as well as the 
many development opportunities she’s discovered, Evelyn 
has grown her career at Bank of America in a way that 
takes advantage of her strengths and builds new skills. “I 
have been blessed to have great leaders and mentors who 
invested in me and my abilities. I see the impact this has 
had on my career, and I want to give that same opportunity 
to others,” says Evelyn. Inspired by her experiences at the 
bank, she has made it her mission to mentor her teammates 
and develop their leadership skills. By taking advantage of 
the bank’s many career development resources, Evelyn has 
been able to help develop and promote the next generation 
of leaders. Additionally, as a market president lead for 
Consumer & Small Business and member of the Hispanic/
Latino Organization for Leadership and Advancement 
Employee Network, Evelyn is able to interact with  
diverse employees and connect them to areas of interest. 
“Making connections enables career mobility, which helps 
retain our talent. I’m proof you can have a lifelong career  
at Bank of America.”

Representation of people of color across our company

18%

20%

48%

54%

of our management team 
are people of color

of our management levels  
1–3 are people of color

of our U.S. workforce  
are people of color

of our full-time campus 
hires are people of color

BANK OF AMERICA 2020   |   31

Being a great place to work —2020 highlights
A critical component of how we drive Responsible Growth is making Bank of America a great place 
to work. See how we fulfill that commitment to our employees.

$20 minimum 
hourly rate
In the first quarter of 2020, we raised 
our minimum hourly rate of pay for 
U.S. employees to $20, one year earlier 
than planned.

Medical premiums 
for employees
Since 2012, there has been no increase 
in medical premiums for employees 
earning less than $50,000.

Sharing  
our success 
For the fourth time since 2017, we
recognized teammates with a special
award in cash or restricted stock. In the 
first quarter of 2021, approximately 
97% of teammates received a 
Delivering Together award, in addition 
to any regular annual incentives.

Equal pay for  
equal work
For teammates in comparable 
positions, compensation received by 
women, on average, was greater than 
99% of that received by men; and 
compensation received by people of 
color was, on average, greater than 
99% of that received by teammates 
who are not people of color.

$500 wellness 
credit 
We provide a $500 credit toward 
medical plan premiums following 
completion of a wellness screening and 
questionnaire (or $1,000 if a covered 
spouse or partner also completes).

Employee  
Relief Fund 
Employees can receive up to $2,500 
in financial assistance through our 
Employee Relief Fund for a qualified 
disaster and up to $5,000 for an 
emergency hardship.

Hired 10K+  
military veterans
We surpassed our goal of hiring over 
10,000 military veterans, achieving 
our five-year commitment, with plans 
to maintain hiring momentum for 
the future.

Supporting career 
development 
We provide an extensive portfolio of 
learning and leadership development 
opportunities to our more than 200,000 
employees, including foundational and 
skills-based training and an enterprise-
wide focus on manager development. 

Hiring 10K+ from 
LMI communities 
We hired more than 10,000 employees 
from LMI communities since 2018 —  
ahead of our commitment to do so 
by 2023. 

Up to $7,500  
in tuition  
reimbursement 
Through our tuition reimbursement 
program, we provide up to $7,500 (up 
to $5,250 tax-free) annually for eligible 
undergraduate or graduate courses.

32   |   BANK OF AMERICA 2020

 Investing $1 billion over  
four years to advance racial equality  
and economic opportunity 

In 2020, we saw intensified passion to address the obstacles to true racial equality in the U.S. In 
response, we accelerated work already underway to announce a $1 billion, four-year initiative to 
help advance racial equality and economic opportunity with a focus on four areas: 

• Jobs and reskilling the workforce

• Supporting minority small business owners

• Making home ownership and rental housing more affordable 

• Addressing inequities in health services

This work is being led by Vice Chairman Anne Finucane and developed by a cross-functional team led by Global Head of ESG 
Andrew Plepler with the expertise and perspective of the company’s Black and Hispanic Leadership councils, our local market teams 
and other business leaders. It recognizes that issues of racial equality and economic opportunity are deeply connected, and that 
understanding the past is critical to charting a path forward. Our objective is to address systemic barriers where they exist and help 
drive more opportunity and sustained progress.

Already, we’ve allocated more than $300 million (or one-third) across 91 markets and globally, including:

Investments in 61 private 
equity funds across the U.S.
$150 million in funds focused 
on minority entrepreneurs and 
predominantly led by diverse fund 
managers

Partnerships with more 
than 20 higher education 
institutions and major 
employers 
Jobs initiatives with community 
colleges, historically Black colleges 
and universities and Hispanic-serving 
institutions to connect students 
to career success

Launched Smithsonian’s 
“Race, Community and Our 
Shared Future” 
Program to deliver thought leadership 
on civil rights, social justice and 
economic mobility to communities 
across the country

Expanding opportunities  
for 50,000 women 
Bank of America Institute for Women’s 
Entrepreneurship at Cornell, with a 
focus on women of color

Capital investments in  
14 MDIs and CDFI banks 
Toward lending, housing, neighborhood 
revitalization and other banking 
services 

Partnerships with CVS 
Health and local nonprofits 
Flu vaccine vouchers in under-
resourced communities and donations 
of PPE to community partners across 
the country

“We must not let the current intense demand for action die down. And we will not. Our 
management team, our market presidents and market executives, leaders of our company 
at every level, all of us can and will do more.” — CEO Brian Moynihan 

BANK OF AMERICA 2020   |   33

Addressing the world’s challenges 
through sustainable finance

A conversation with Anne Finucane, Vice Chairman and  
Karen Fang, Global Head of Sustainable Finance 

At Bank of America, sustainability is embedded in our operating model. This extends to how we  
support our clients through core lending and investments; equity and debt capital markets 
activities; the advisory services we offer; how we manage our supply chain and how we conduct  
our own operations. In 2020, after meeting our goal to be carbon-neutral a year early, we finalized 
our commitment to achieve net-zero greenhouse gas (GHG) emissions before 2050 across  
all scopes of emissions including those from our operations, financing activities and supply chain. 

Central to our purpose as a financial services company, we 
will need to assist our clients in their own carbon reduction 
journey. To accelerate our sustainable finance work and help 
create a consistent perspective across all of our capabilities 
and product offerings, in January 2020, we established the 
Sustainable Markets Committee, which I co-chair along with 
Chief Operating Officer Tom Montag. To lead this effort, we 
named Karen Fang as the Global Head of Sustainable Finance. 
Karen and I sat down recently to talk about our progress, the 
business, and our goals for 2021.

Anne: Karen, we have developed a leadership position in 
clean energy finance, and we will discuss that later. This 
year, though, we saw particular interest in other aspects of 
sustainable finance, against a backdrop of economic and social 
challenges during the global health crisis. We mobilized and 
deployed approximately $100 billion of sustainable finance 
capital aligned with the United Nations (U.N.) SDGs in 2020, a 
significant increase from 2019 despite the global challenges, 

with approximately $55 billion allocated to climate finance. In 
addition, approximately $45 billion was allocated to Inclusive 
Development. This includes our significant lending and 
investing in affordable housing, healthcare, education and 
other social infrastructure as a part of our support for local 
communities across the U.S. Also included are the deposits 
and equity capital we provided to CDFIs and MDIs, and equity 
and fund investments into minority-owned businesses as a 
part of our $1 billion racial equality and economic opportunity 
initiative. And the global health crisis and associated 
challenges did offer the opportunity for some unique offerings 
by our company. Can you discuss that a little bit?

Karen: Yes, we are particularly proud of two innovative 
transactions we completed in 2020 for Bank of America that 
demonstrate the creativity and strength of collaboration 
across many of our lines of business in an effort to deliver for  
our clients. In May 2020, we issued a $1 billion corporate social 
bond focused on the coronavirus response, the first such 

34   |   BANK OF AMERICA 2020

“The Sustainable Markets Committee 
gathers our capabilities across every line 
of business and puts them to work for our 
clients who are innovating and investing  
in the low carbon, sustainable economy.” 

— Tom Montag, Chief Operating Officer

platinum Leadership in Energy and Environmental Design 
(LEED) skyscraper and continue to make progress in our own 
real estate footprint. So our own track record means we are 
well positioned to (i) have a comprehensive discussion with 
our clients about carbon neutrality and net-zero as a business 
imperative; (ii) encourage clients to establish a concrete and 
credible glide path plan to reduce their own carbon footprints; 
and (iii) offer clients advisory services and financial tools to 
support their decarbonization efforts toward net-zero.

offering by a U.S. bank. This bond was designed to provide 
targeted lending to healthcare institutions that are on the 
front lines of combatting the health crisis, and it paved the 
way for Bank of America to underwrite and distribute more 
than $50 billion of social bonds for numerous governments, 
agencies and public companies. This speaks to our ability  
to scale capital deployment for important societal needs.

In September 2020, we issued a $2 billion equality progress 
sustainability bond to advance racial equality, economic 
opportunity and environmental sustainability. The social side 
of the proceeds were exclusively allocated to make new and 
impactful investments and lending in affordable housing, 
healthcare, and small businesses in Black and Hispanic-Latino 
communities. This first-of-its-kind transaction again inspired 
other issuers to follow similar approaches, scaling capital  
for wealth creation and socioeconomic empowerment of 
these communities.

Some highlights on the environmental transition side include 
underwriting and distributing green and sustainability bonds, 
completing some of the largest asset finance transactions 
for renewable energy generation and providing financing and 
leasing solutions for energy efficiency projects and electric 
vehicles (EVs).

Bank of America’s commitment to sustainable finance runs  
deeper than just doing transactions. Thanks to the commitment  
and leadership from you, our whole Management Team and  
all of our teammates, we are at the forefront of climate 
change thought leadership. We are key members of various 
global alliances focused on sustainable development, such 
as the U.N. Global Investors for Sustainable Development, 
the World Economic Forum Net-Zero Transition Finance 
Committee, His Royal Highness the Prince of Wales’ 
Sustainable Markets Initiative, the Rocky Mountain Institute 
Center for Climate Aligned Finance and the 1t.org U.S. 
Steering Council, among others.

Anne: Let’s talk a little more about “traditional” sustainable 
finance, if I can use that term since we’ve been at it now 
for so many years. We reached carbon neutrality in our own 
footprint and are on a path toward net-zero before 2050. We 
have reduced our energy use by 40% and our location-based 
GHG emissions by 50%, sourced renewable energy to power 
our facilities, and purchased and retired carbon offsets for 
those final amounts of unavoidable emissions. In keeping 
with our focus on the environment, we even erected the first 

Karen: Exactly. In 2020, we developed the “4 R’s” approach 
to decarbonization for our corporate clients: Reduce, 
Renew, Retire, and Realign. We financed energy efficiency 
projects that helped clients reduce their energy usage; we 
helped shift clients’ electricity footprints from fossil fuels 
to renewable energy by providing debt financing, tax equity 
and leasing capital for wind and solar power generation; we 
mobilized capital for more EV production and leasing; and 
we financed LEED-certified construction of office facilities 
and manufacturing sites. We are also helping develop a more 
robust, voluntary carbon-offset market.

Anne: Whether it is Environmental Transition or Inclusive 
Development, our business focus has been to expand 
current activities and innovate to help advance emerging 
technologies. New domains and possibilities seem to be 
emerging at an ever faster pace. In the area of Environmental 
Transition, we are looking at solutions for the next frontier 
beyond wind, solar, and EVs including (i) clean hydrogen, 
fuel cells, sustainable aviation fuels and waste-to-energy; 
(ii) EV charging and battery infrastructure; (iii) nature and 
engineered solutions for carbon capture and offsets; and 
(iv) sustainable agriculture and better water infrastructure. 
Let’s talk about what we’re focused on in the Inclusive 
Development side of things.

Karen: We’ll continue to help advance racial and gender 
equality, support healthcare as we focus on continued 
coronavirus response and vaccine delivery, and investing in  
job training and reskilling. Certain projects that we are 
pursuing include working with developers to create affordable 
housing projects that incorporate more environmental and 
social sustainability features and materials. Also, we are 
expanding our supply chain financing and banking services  
to more minority-owned and operated businesses.

BANK OF AMERICA 2020   |   35

2020 ESG highlights*
Our strong focus on environmental, social and governance (ESG) is key to how we drive 
Responsible Growth. We’re addressing society’s greatest challenges through our investments, 
philanthropy and responsible business operations. This helps us to serve clients, deliver  
returns for our shareholders and contribute to a more sustainable future.

Sustainable finance 
We mobilized and deployed 
approximately $100 billion in capital  
to support the environmental transition 
to a low-carbon economy, as well as 
inclusive development focusing on 
affordable housing, healthcare, education 
and racial/gender equality. 

Environmental business 
commitment
Our Environmental Business Initiative 
will direct at least $445 billion to 
low-carbon, sustainable business 
activities by 2030. Since 2007 when  
it was launched, we have mobilized  
more than $200 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 Tax Equity 
renewable energy portfolio at the end of 
2020 was approximately $10.1 billion. 
Our investments have contributed to 
the development of approximately 17% 
(33GW) of total installed renewable wind 
and solar energy capacity in the U.S.

Blended Finance  
Catalyst Pool 
Our Blended Finance Catalyst Pool will 
provide $60 million from Bank of America 
to leverage additional private capital to 
help address the U.N. SDGs. We finalized 
commitments totaling $15 million in four 
different blended finance vehicles that 
will help mobilize more than $500 million 
in total investor funds. 

36   |   BANK OF AMERICA 2020

Affordable homeownership 
Having surpassed our initial 
commitment, we tripled our Bank of 
America Community Homeownership 
Commitment® to $15 billion through 
2025, aiming to help more than 
60,000 LMI individuals and families 
purchase a home. Since 2019, the  
initiative has helped nearly 
21,000 individuals and families purchase 
a home and over $180 million in  
down payment and closing cost grants. 

Community  
Development Banking 
We provided a record $5.87 billion in 
loans, tax credit equity investments 
and other real estate development 
solutions through $3.62 billion in 
debt commitments and $2.25 billion 
in investments to help build strong, 
sustainable communities by financing 
affordable housing and economic 
development across the country. 
Between 2005 and 2020, we financed 
more than 215,000 affordable 
housing units.

Community development 
financial institutions (CDFI) 
lending 
We originated over $394 million in loans 
and investments as part of our more 
than $1.8 billion portfolio in 256 CDFIs 
to finance affordable housing, economic 
development projects, small businesses, 
healthcare centers, charter schools, and 
other community facilities and services.

Small business lending  
We provide dedicated support to meet 
the needs of our 13 million small 
business owners and are a top lender 
in the SBA’s 504 and 7(a) programs, 
according to the FDIC. More than half 
(54%) of all small business loans booked 
in 2020 were made to LMI borrowers.

Sustainable client balances 
We have $36.8 billion in assets in our 
wealth management business with 
a clearly defined ESG investment 
approach.

Green, social and  
sustainability bonds 
We issued a $1 billion corporate social 
bond to support those on the front 
lines of the health crisis; and a first-
of-its kind $2 billion equality progress 
sustainability bond to help advance 
racial equality, economic opportunity 
and environmental sustainability. Since 
2013, Bank of America has issued 
$9.85 billion in eight corporate Green, 
Social and Sustainability Bonds. We 
have also been a leader in ESG-themed 
bond underwriting globally since 
2007, having underwritten more than 
$75 billion on behalf of more than 
225 clients, supported more than 
400 deals and provided critical funding 
to environmental and social projects.

*Data and metrics are as of year-end 2020 unless otherwise noted. 

 
 
 
 
 
 
 
 
 
 
Net-zero commitment 
We are carbon neutral and purchase 
100% renewable electricity. We have 
committed to achieving net-zero 
greenhouse gas emissions in our 
financing activities, operations and 
supply chain before 2050.

Climate risk and 
ESG disclosure
We disclose our risk and governance 
practices under several frameworks. On 
page 40, we have reported under new 
ESG Stakeholder Capitalism Metrics 
developed by the World Economic 
Forum’s International Business Council. 
We issued our first report under the 
recommendations of the TCFD, and our 
first SASB report. This is in addition to 
publicly disclosed information about 
how we manage climate risk in the 
Management Discussion & Analysis 
section of our Annual Report on Form 
10-K and reporting through the GRI 
and CDP (formerly known as Carbon 
Disclosure Project) global disclosure 
system. We also disclose our ESG 
strategy, policies and practices in 
our Environmental and Social Risk 
Policy Framework and Human Capital 
Management Report.

Women’s economic  
empowerment  
We expanded opportunities for 50,000 
women entrepreneurs, with a focus on 
women of color, to participate in the 
Bank of America Institute for Women’s 
Entrepreneurship at Cornell, the only 
online Ivy League certificate program for 
women business owners in the world. 
More than 20,000 women are currently 
enrolled, representing over 85 countries, 
including the U.S..

Philanthropic giving 
We increased our philanthropy to more 
than $350 million, including $100 million 
to support communities impacted by 
the health and humanitarian crisis and 
$250 million to drive economic mobility 
and social progress in the communities 
we serve. We continue to advance 
economic mobility and nonprofit 
leadership through our Neighborhood 
Builders and Neighborhood Champions 
programs, investing $256 million to 
support more than 1,000 nonprofits and 
2,000 nonprofit executives since 2004. 
Last year, through local partnerships 
and our own Student Leaders program, 
we connected more than 4,000 young 
people to early employment.

Arts and culture 
We remain steadfast in our support  
of arts and culture, providing more than  
$50 million in support to arts and culture 
nonprofits around the world last year. 
We fulfilled all commitments in 2020, 
whether or not partners were open and/
or their programming had been digitized, 
postponed or canceled. 

Employee giving  
and volunteering 
In response to the health and 
humanitarian crisis and the need to 
advance racial equality, we lowered 
our matching gift minimum to $1 and 
doubled our match for donations to 

17 organizations focused on racial 
equality and economic opportunity. 
Last year, despite shifting to a 
virtual environment, our employees 
volunteered over 1.1 million hours and 
directed $65 million to communities 
through individual giving and the bank’s 
matching gifts program.

Pathways 
Since 2018, Bank of America’s 
Pathways program has fueled our 
enterprise-wide talent pipeline, hiring 
more than 10,000 employees from 
LMI neighborhoods — well ahead of 
our commitment to do so by 2023. 
We do this through partnerships with 
community colleges and long-time 
partners such as Year Up, UnidosUS  
and the National Urban League. 

Better Money Habits® 
Through our Better Money Habits 
platform, we continue to connect people 
to relevant advice, tools and guidance 
that empowers them to take control of 
their finances. Content on the Better 
Money Habits website was accessed for 
free over 6 million times, and consumers 
clicked through to make an appointment 
more than 23,000 times. Mejores Habitos  
Financieros, our Spanish site, was 
accessed more than 1 million times. To 
further extend these resources in LMI 
communities, more than 4,300 employee 
volunteers serve as Better Money Habits 
Volunteer Champions, delivering financial 
know-how in partnership with local 
nonprofits across the U.S. 

BANK OF AMERICA 2020   |   37

  
 
 
 
 
 
 
 
Bank of America Corporation —  Financial highlights

Bank of America Corporation (NYSE: BAC) is headquartered in Charlotte, North Carolina. As of December 31, 2020, 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 common equity
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 capitalization
Market price per common share
Common shares issued and outstanding
Tangible common equity ratio1

2020
$  85,528
  17,894 
1.88 
1.87 
0.72 
0.67%  
6.76%  
 9.48 
 64.55 
 8,797 

2020
$  927,861
  2,819,627 
   1,795,480 
  272,924 
 28.72 
 20.60 
  262,206 
 30.31 
 8,651 
6.5

$ 

2019
91,244
27,430 
2.77 
2.75 
0.66 
1.14%  
10.62%  
14.86 
60.17 
9,443 

2019
$  983,426
  2,434,079 
   1,434,803 
   264,810 
 27.32 
 19.41 
   311,209 
 35.22 
 8,836 
7.3

$ 

2018
91,020
28,147
2.64
2.61
0.54
1.21%
11.04%
15.55
58.40
10,237

2018
$  946,895
  2,354,507 
  1,381,476 
 265,325 
 25.13 
 17.91 
 238,251 
 24.64 
 9,669 
7.6

Total Cumulative Shareholder Return²

BAC Five-Year Stock Performance

$250

$200

$150

$100

$50

$0

2015

2016

2017

2018

2019

2020

December 31

2015

2016

2017

2018

2019

2020

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

$100
100
100

$133
112
129

$181
136
152

$154
130
125

$225
171
171

$199
203
153

KBW

S&P

B of A

$40

$30

$20

$10

$0

2016 

2017 

2018 

2019 

2020

  HIGH  $23.16  

$29.88  

$32.84 

$35.52 

$35.64

  LOW 

 11.16  

 22.05  

  CLOSE 

 22.10  

 29.52  

 22.73  

 24.64  

 24.56 

 35.22 

18.08

 30.31

Book Value Per Share/ 
Tangible Book Value Per Share¹

.

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
$

.

2
7
8
2
$

.

0
6
0
2
$

1 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 54 and Non-GAAP Reconciliations on page 111 of the 2020 Financial Review section.

² This graph compares the yearly change in the Corporation’s total cumulative shareholder return on its common stock with (i) the Standard & Poor’s 500 Index and (ii) the KBW Bank Index 
for the years ended December 31, 2015 through 2020. The graph assumes an initial investment of $100 at the end of 2015 and the reinvestment of all dividends during the years indicated.

38   |   BANK OF AMERICA 2020

2016

2017

Book Value Per Share

2018

2019
Tangible Book Value Per Share

2020

 
 
 
 
 
  
  
 
 
 
  
 
  
 
 
 
  
 
  
 
 
 
  
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
  
 
 
 
  
 
  
 
 
 
  
 
  
 
 
 
 
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Recognition

We are honored to be recognized by organizations and media around the world for our work in driving Responsible Growth, including 
our ESG commitments and initiatives and our efforts to be a great place to work.

In 2020, we were recognized by Fortune as one of their 100 Best Companies to Work For, Working Mother as the number-one best 
company for Dads and Euromoney as the World’s Best Bank for Corporate Responsibility, among several others. Below are some  
of our most recent awards.

Fortune
100 Best Companies to Work For (2020, 2019)

Best Big Companies to Work For (2020, 2019)
only financial services company recognized two 
years in a row

The Banker
Most Innovative Investment Bank of the Year for 
Corporate Social Responsibility (2019)

Climate Leadership Awards
Innovative Partnership Certificate (2019)

Best Workplaces for Women (2020, 2019)

Best Workplaces in Financial Services & 
Insurance (2020, 2019)

Best Workplaces for Diversity (2019)

Best Workplaces for Parents (2020, 2019) 

Best Workplaces for Giving Back (2018)

Change the World (2020, 2019) 
named the top global bank two years in a row

Euromoney
World’s Best Bank for Corporate Responsibility 
(2020)

Excellence in Leadership—North America (2020) 

Best Digital Bank—North America (2020)

Best Bank for Transaction Services—North 
America and Latin America (2020)

Best Bank for Small and Medium-Sized 
Enterprises—North America (2020)

World’s Best Bank for Diversity and Inclusion 
(2019) 

World’s Best Bank (2018)

World’s Best Bank for Corporate Social 
Responsibility (2017)

Asia’s Best Bank for Corporate Social 
Responsibility (2019)

Barron’s
100 Most Sustainable Companies (2020)

Top Women Advisors (2020) 
recognized for the 15th consecutive year

LinkedIn
50 Top Companies in the U.S. (2019)  
top ranking financial institution

Working Mother
Top Wealth Advisor Moms (2020)  
125 Merrill advisors recognized

100 Best Companies (32 consecutive years)

Best Companies for Multicultural Women  
(2020, 2019)

Best Companies for Dads (2020, 2019) 

Diversity Best Practices Inclusion Index (2020)

U.S. Environmental Protection Agency 
EPA Green Power Leadership Award for 
Excellence in Green Power (2019)

Investing in Women Initiative
Catalyst Award Winner (2019)

Forbes
Corporate Responders (2020)

Top Women Advisors (2020)  
240 Merrill advisors recognized

World’s Best Employers (2019)

Bloomberg
Gender-Equality Index (2019)

Financial Services Gender-Equality Index (2017)

Brandon Hall
25 Human Capital Management Excellence 
Awards (2020)

RateMyPlacement
100 Undergraduate Employers (2019-2020)

PEOPLE Magazine
Companies that Care (2020, 2019)

AnitaB.org
Top Companies for Women Technologists (2019)

Diversity MBA Magazine
50 Out Front: Best Places for Women & Diverse 
Managers to Work (2020, 2019)

JUST Capital
America’s Most JUST Companies (2020, 2019)

JUST 100 (2020)

Military Times
Best for Vets: Employers (2020, 2019)

Stonewall UK Workplace
Equality Index (2020, 2019)

Fatherly
Certified Best Place to Work for Dads (2019)

American Council on Renewable Energy 
(ACORE)
Renewable Energy Leadership Award (2019)

Dow Jones Sustainability Index
World Index (top 10% of banks) (2019)

North America Index (top 20% of banks) (2019)

UK Armed Forces Covenant 
Employer Recognition Scheme Gold Award 
(2016-2020)

U.S. Veterans Magazine
Top Veteran-Friendly Company (2020)

Equileap
U.S. and Global Gender Equality Reports (2019) 
named the leading company in U.S. for gender 
equality

Black Enterprise
50 Best Companies for Diversity (2018)

Dave Thomas Foundation for Adoption
100 Best Adoption-Friendly Workplace  
(2020, 2019)

Disability:IN and the American Association 
of People with Disabilities 
Disability Equality Index (2020) scored 100%

Global Employer of the Year (2019)

National Association of Asian American 
Professionals
Milestone Honor Award (Asian Leadership 
Network, 2016)

Global Finance Magazine
Best Bank in the United States (2020) 

Best Bank in North America (2020)

Best Consumer Digital Bank in the United States 
(2020)

Best Bank in the World (2019)

LATINA Style
Company of the Year (2020)

Top 50 Best Companies for Latinas to Work for 
in the U.S. (21 consecutive years)

Top 12 Companies of the Year (2019)

Top 12 Employee Resource Groups of the Year 
(Hispanic-Latino Organization for Leadership & 
Advancement, 2019)

National Association for Female Executives 
(NAFE)
Top Companies for Executive Women (12 years)

PR News
CSR Award for Employee Relations (2019)

CDP
A list named for the ninth year (2019) 

Supplier Engagement Leaderboard (2019)

Center for Political Accountability
Trendsetter on CPA-Zicklin Index of Corporate 
Political Disclosure and Accountability  
(2016-2019)

BANK OF AMERICA 2020   |   39

STAKEHOLDER CAPITALISM METRICS

The index reflects our report in alignment with the Stakeholder Capitalism Metrics (the Metrics) published by the International 
Business Council of the World Economic Forum. We believe these Metrics help to demonstrate how our sustainable business model 
drives progress towards inclusive capitalism and the U.N.’s Sustainable Development Goals. In this index, we either reference 
existing disclosures or respond directly. We currently do not report on all of the Metrics but will continue to evaluate both core 
and expanded metrics for potential future additional disclosure. Our commitment is to provide investors with useful, relevant and 
meaningful sustainability information and we expect our disclosures to evolve over time. All reported data is as of and for year  
end December 31, 2020, unless otherwise noted.

INDICATES CORE METRIC

THEME

METRIC

RESPONSE

Principles of Governance

Governing Purpose

Quality of  
Governing Body

Ethical Behavior

Setting Purpose: The company’s stated purpose, as the 
expression of the means by which a business proposes 
solutions to economic, environmental, and social issues. 
Corporate purpose should create value for all stakeholders, 
including shareholders. 

Purpose-led management: How the company’s stated purpose 
is embedded in company strategies, policies, and goals. 

Governing Body Composition: Composition of the highest 
governance body and its committees by: competencies relating 
to economic, environmental, and social topics; executive or 
non-executive; independence; tenure on the governance body; 
number of each individual’s other significant positions and 
commitments, and the nature of the commitments; gender; 
membership of under-represented social groups; stakeholder 
representation. 

Progress against strategic milestones: Disclosure of 
the material strategic economic, environmental, and social 
milestones expected to be achieved in the following year,  
such milestones achieved from the previous year, and how 
those milestones are expected to or have contributed to  
long-term value. 

Remuneration:  
1. How performance criteria in the remuneration policies 
relate to the highest governance body’s and senior executives’ 
objectives for economic, environmental and social topics, as 
connected to the company’s stated purpose, strategy, and 
long-term value. 
2. Remuneration policies for the highest governance body  
and senior executives for the following types of remuneration: 
Fixed pay and variable pay, including performance-based pay, 
equity-based pay, bonuses, and deferred or vested shares,  
Sign-on bonuses or recruitment incentive payments, 
termination payments, clawback and retirement benefits.

Anti-corruption:  
1. Total percentage of governance body members, employees 
and business partners who have received training on the 
organization’s anti-corruption policies and procedures, broken 
down by region. 
2.   (a)  Total number and nature of incidents of corruption 

confirmed during the current year but related to previous 
years and

  (b) Total number and nature of incidents of corruption 
confirmed during the current year, related to this year.
3. Discussion of initiatives and stakeholder engagement to 
improve the broader operating environment and culture, in 
order to combat corruption.

Protected ethics advice and reporting mechanisms: A 
description of internal and external mechanisms for:  
1. Seeking advice about ethical and lawful behaviour and  
organizational integrity
2. Reporting concerns about unethical or unlawful behaviour 
and organizational integrity

Monetary losses from unethical behaviour: Total amount 
of monetary losses as a result of legal proceedings associated 
with: fraud, insider trading, anti-trust, anti-competitive 
behaviour, market manipulation, malpractice, or violations of 
other related industry laws or regulations. 

Our Responsible Growth strategy referenced in this 2020 Annual 
Report and our 2021 Proxy Statement articulates how our purpose  
and environmental, social and governance leadership creates 
stakeholder value.

Refer to the section entitled “Proposal 1: Electing directors” in our 
2021 Proxy Statement available on the Bank of America Investor 
Relations website at www.bankofamerica.com/investor.

Refer to our 2019 ESG Performance Data Summary available at  
www.bankofamerica.com/ESGData.

Refer to the section entitled “Compensation discussion and analysis”  
in our 2021 Proxy Statement available on the Bank of America Investor 
Relations website at www.bankofamerica.com/investor.

1. 100% of Bank of America employees are required to take training 
on anti-bribery and anti-corruption policies as part of Bank of 
America’s Code of Conduct training.

2. For disclosure of significant litigation and regulatory matters, see 
Note 12 — Commitments and Contingencies on page 161 of the 2020 
Financial Review section. 
3. Refer to our Code of Conduct on the Bank of America Investor 
Relations website available at www.bankofamerica.com/investor.

Refer to page 13 in our Code of Conduct on the Bank of America 
Investor Relations website available at www.bankofamerica.com/
investor.

For disclosure of significant litigation and regulatory matters, see 
Note 12 — Commitments and Contingencies on page 161 of the 2020 
Financial Review section. 

40   |   BANK OF AMERICA 2020

 
THEME

METRIC

RESPONSE

Ethical Behavior 
(continued)

Risk and Opportunity 
Oversight

Alignment of strategy and policies to lobbying: The 
significant issues that are the focus of the company’s 
participation in public policy development and lobbying; the 
company’s strategy relevant to these areas of focus; and any 
differences between its lobbying positions, purpose, and any 
stated policies, goals, or other public positions. 

Integrating risk and opportunity into business process: 
Company risk factor and opportunity disclosures that clearly 
identify the principal material risks and opportunities facing 
the company specifically (as opposed to generic sector risks), 
the company appetite in respect of these risks, how these risks 
and opportunities have moved over time and the response to 
those changes. These opportunities and risks should integrate 
material economic, environmental, and social issues, including 
climate change and data stewardship. 

Refer to our Political Activities disclosure available on the Bank of 
America Investor Relations website at www.bankofamerica.com/
investor.

Refer to our Environmental and Social Risk Policy Framework available 
at www.bankofamerica.com/ESRPF.

Stakeholder  
Engagement

Material issues impacting stakeholders: A list of the topics 
that are material to key stakeholders and the company, how the 
topics were identified, and how the stakeholders were engaged. 

Refer to our ESG Materiality disclosure available at  
www.bankofamerica.com/ESGMateriality.

THEME

Climate Change

Fresh water  
availability

METRIC

RESPONSE

Planet*

Greenhouse Gas (GHG) emissions: For all relevant 
greenhouse gases (e.g. carbon dioxide, methane, nitrous 
oxide, F-gases etc.), report in metric tonnes of carbon 
dioxide equivalent (tCO₂e) GHG Protocol Scope 1 and 
Scope 2 emissions. Estimate and report material upstream 
and downstream (GHG Protocol Scope 3) emissions where 
appropriate.

Bank of America’s 2019 greenhouse gas emissions (tCO₂e) are as 
follows. Since 2010, we have reduced location-based emissions 56% 
globally. For more information, refer to our ESG Performance Data 
Summary (2019) available at www.bankofamerica.com/ESGData. 

•  Scope 1: 62,639
•  Location-based Scope 2: 728,771
•  Market-Based Scope 2: 17,523
•  Total net Scope 1 and Market-Based Scope 2: 0
•  Scope 3 Purchased Goods and Services: 2,329,208
•  Scope 3 Capital Goods: 251,336
•  Scope 3 Fuel- and Energy-Related Activities: 161,151
•  Scope 3 Upstream Transportation and Distribution: 140,215
•  Scope 3 Waste (Traditional Disposal): 22,386
•  Scope 3 Business Travel: 162,457
•  Scope 3 Employee Commuting: 378,088
•  Scope 3 Downstream Transportation and Distribution: 1,400,000
•  Scope 3 Use of Sold Products: 4,000
•  Scope 3 End of Life Treatment of Sold Products: 19,000

TCFD implementation: Fully implement the recommendations 
of the Task Force on Climate-related Financial Disclosures 
(TCFD). If necessary, disclose a timeline of at most three years 
for full implementation. Disclose whether you have set, or have 
committed to set GHG emissions targets that are in line with 
the goals of the Paris Agreement — to limit global warming to 
well-below 2°C above pre-industrial levels and pursue efforts 
to limit warming to 1.5°C — and to achieve net-zero emissions 
before 2050. 

In 2020, Bank of America released its Task Force on  
Climate-related Financial Disclosures (TCFD) Report available  
at www.bankofamerica.com/TCFD.
In early 2021, Bank of America took the next step in our climate 
journey by publicly committing to achieve net zero greenhouse  
gas emissions before 2050 across our operations, supply chain,  
and financing activities. For more information, refer to  
www.bankofamerica.com/NetZero.

Paris-aligned GHG emissions targets: Define and 
report progress against time-bound science-based GHG 
emissions targets that are in line with the goals of the Paris 
Agreement — to limit global warming to well-below 2°C above 
pre-industrial levels and pursue efforts to limit warming to 
1.5°C. This should include defining a date before 2050 by which 
you will achieve net-zero greenhouse gas emissions and interim 
reduction targets based on the methodologies provided by the 
Science Based Targets initiative if applicable.

To reach the goals of the Paris Agreement, we are developing a 
strategy across our entire value chain which includes setting interim 
emission reduction targets based on science, engaging with clients 
on climate goals and supporting climate innovation. Our net zero goal 
includes operations (Scope 1 and 2), supply chain (Scope 3 upstream 
emissions) and all material emissions attributed to our loans and 
investments (Scope 3 investments). For more information, refer to 
www.bankofamerica.com/NetZero. 

Impact of Greenhouse gas emissions: Report wherever 
material along the value chain (GHG protocol Scopes 1, 2 & 3), 
the valued societal impact of greenhouse gas emissions. 
Disclose the estimate of the social/societal cost of carbon used 
and the source or basis for this estimate.

The societal impact of Bank of America’s Scope 1, Scope 2 (location-
based), and Scope 3 (Categories 1–7, 9, 11–12) emissions in 2019 
was estimated to be $238 million. This figure was calculated using the 
EPA’s 2020 social cost of carbon of $42/metric ton CO₂ (3% discount 
rate, reported in 2007 USD).

Water consumption and withdrawal in water-stressed 
areas: Report for operations where material, mega litres of 
water withdrawn, mega litres of water consumed and the 
percentage of each in regions with high or extremely high 
baseline water stress according to WRI Aqueduct water risk 
atlas tool. Estimate and report the same information for the 
full value chain (upstream and downstream) where appropriate. 

In 2019, Bank of America withdrew 7,550 and consumed 1,630 mega 
liters of water from our global operations. Of this, 38% of withdrawals 
and 41% of consumption were from regions with high or extremely 
high baseline water stress according to the WRI Aqueduct water risk 
atlas tool.

BANK OF AMERICA 2020   |   41

THEME

Nature Loss

Air pollution

METRIC

RESPONSE

Land use and ecological sensitivity: Report the number 
and area (in hectares) of sites owned, leased or managed in or 
adjacent to protected areas and/or key biodiversity areas (KBA).

In 2019, Bank of America had 8 active U.S. sites that intersected 
with areas protected for biodiversity. The area of these buildings is 
6,900 square meters. Only U.S. sites are included in this analysis; U.S. 
sites make up over 90% of Bank of America’s real estate footprint. 
Sites were overlaid on the U.S. Geological Survey’s Protected Areas 
Database (PADUS) to understand intersection with protected areas.

Air pollution: Report wherever material along the value chain: 
Nitrogen oxides (NOx), sulphur oxides (SOx), particulate matter 
and other significant air emissions. Wherever possible, estimate 
the proportion of specified emissions that occur in or adjacent 
to urban/densely populated areas.

Bank of America’s 2019 air pollution emissions (metric tons) are 
as follows. These air pollution emissions are from all of our sites 
globally and are not specific to urban/densely populated areas. For 
more information, refer to our 2019 ESG Performance Data Summary 
available at www.bankofamerica.com/ESGData. 

•  SOx: 1
•  NOx: 20
•  CO: 32
•  VOC: 2
•  Particulate Matter: 3 

Impact of air pollution: Report wherever material along 
the value chain, the valued impact of air pollution, including 
nitrogen oxides (NOx), sulfur oxides (SOx), particulate matter 
and other significant air emissions.

The valued impact of Bank of America’s air pollution (SOx, NOx, CO, 
VOCs, and PM) in 2019 was estimated to be $146,000. This figure was 
calculated using the social cost factors of each pollutant as reported 
in the World Resources Institute’s Transport Emissions & Social Cost 
Assessment (TESCA) Tool v1.0. These social cost factors are weighted 
averages based on a meta-analysis of international academic studies.

*2020 Environmental Data will be published in Q2 2021. 

THEME

METRIC

RESPONSE

Prosperity

External Hires

Diversity

Region

Female
POC
Black/
African American
Hispanic/Latino

51% U.S.
59% APAC
EMEA
17% LATAM
27% Canada

Turnover

Diversity

Region

Total
Female

POC
Black/
African American
Hispanic/Latino

7% U.S.
6% APAC

7% EMEA
LATAM
7% Canada
7%

84%
12%
3%
0%
0%

7%
5%

5%
4%
4%

In 2020, turnover was at extremely low levels given the pandemic, 
however we would not assume these levels to remain in the future. 
While external research has found that women are dropping out  
of the workforce at a higher rate than men, we have not experienced 
this turnover at Bank of America. 

1a–d. Refer to Financial Statements and Notes beginning on page 116 
of the 2020 Financial Review section.

1e. Refer to Total tax paid metric.
1f. 2020 Total philanthropic giving was $350 million.
2. See the company’s response for the Total Tax Paid metric for more 
information about certain income tax credits that the company does 
not consider to be nor includes in the response as financial assistance 
received from a government.

Employment and wealth 
generation

Absolute number and rate of employment:  
1. Total number and rate of new employee hires during the 
reporting period, by age group, gender, other indicators of 
diversity and region. 
2. Total number and rate of employee turnover during the 
reporting period, by age group, gender, other indicators of 
diversity and region. 

Economic Contribution:  
1. Direct economic value generated and distributed (EVG&D) —  
on an accrual basis, covering the basic components for the 
organization’s global operations, ideally split out by: 

a. Revenue  
b. Operating Costs  
c. Employee wages and benefits  
d. Payments to providers of capital  
e. Payments to government  
f. Community Investment. 

2. Financial assistance received from the government —  
Total monetary value of financial assistance received by the 
organization from any government during the reporting period. 

42   |   BANK OF AMERICA 2020

 
 
 
 
 
 
THEME

METRIC

RESPONSE

Wealth creation and 
Employment

Financial investment contribution disclosure:  
1. Total capital expenditures (CapEx) minus depreciation 
supported by narrative to describe the company’s investment 
strategy. 
2. Share buybacks plus dividend payments supported by 
narrative to describe the company’s strategy for returns of 
capital to shareholders. 

Community and  
social vitality

Total tax paid: The total global tax borne by the company, 
including corporate income taxes, property taxes, non-
creditable VAT and other sales taxes, employer-paid payroll 
taxes and other taxes that constitute costs to the company, by 
category of taxes. 

Innovation in better 
products and services

Total R&D expenses ($): Total costs related to research and 
development.  

1. We made $2.74 billion in fixed asset capital investments 
($0.83 billion net of depreciation) primarily related to our real estate 
portfolio and technology expenditures. Our real estate investments 
focused on items that will allow us to bring teammates together to 
drive greater collaboration and efficiencies in support of our effort to 
deliver one company to our clients. We invested in modernizing sites 
across the portfolio while also providing health and safety resources to 
all locations to support our teammates. We also continue to invest  
in the expansion and modernization of our financial center network. 
Additionally, our technology purchases represent hardware and 
software to support ongoing investments in the Bank of America 
technology infrastructure and represent efforts to continue to support 
customers, clients, and employees.

2. For more information outlining our return of capital to shareholders, 
see Note 13 — Shareholders’ Equity on page 166 of the 2020 Financial 
Review section. 

The following table reflects the approximate amount of each category 
of tax borne by the company globally. U.S. income tax law provides 
investors in affordable housing projects, renewable energy projects 
and other activities that further ESG principles with credits that can 
reduce income taxes otherwise owed. These investments generally 
involve substantial pre-tax losses. The amount shown in the table for 
Corporate Income Taxes paid would have been approximately $3 billion 
higher were it not for these credits.

Global Tax Paid in 2020
($ in billions)

Corporate Income Taxes
Property Taxes
Non-creditable VAT and Other Sales Taxes
Employer-paid Payroll Taxes
Other Taxes
Total

2.9
0.2
0.6
1.7
0.8
6.2

While R&D expenses are indicative of a company’s investment in 
innovation and producing better products and services for their clients, 
it is not the only way to measure a company’s efforts to innovate new 
products and services and to be fit for the future. 
For example, Bank of America is in the midst of a 10-year $300B 
commitment to finance the transition to a low-carbon economy 
including the adoption of low-carbon technologies such as resource-
efficient building construction, renewable energy generation, 
sustainable transportation such as electric vehicles and charging 
infrastructure, and resource-efficient agriculture. We are also 
dedicating significant financial, intellectual, philanthropic and catalytic 
capital to support the advancement of developing technologies, 
such as carbon finance, sustainable agriculture and biofuels, water 
infrastructure, clean hydrogen, waste-to-energy, and carbon capture 
sequestration.

In addition to our financing commitment referenced above, we 
invest heavily in technology development to meet the needs of 
the Corporation in support of LRR (Laws, Rules, Regulations), Data 
Remediation, Resiliency and Stability, clients / new products and 
efficiencies. We spent $3.5B on these items during 2020. 

Bank of America is also granted patents by the U.S. Patent Office. In 
2020, we filed 722 patent applications and separately received 444 
patents for the products and services we bring to our clients including 
innovations in information security, ATM technology, data integrity and 
monitoring using artificial intelligence (AI) or machine learning, fully 
functioning payment instruments, network management and network 
traffic analysis. The bank is one of the top 15 holders of U.S. banking-
related patents and applications.

BANK OF AMERICA 2020   |   43

THEME

METRIC

RESPONSE

Dignity and equality

Diversity and inclusion (%): Percentage of employees per 
employee category, per age group, gender and other indicators 
of diversity (e.g. ethnicity). 

Refer to pages 11 & 27 in our 2020 Human Capital Management 
Report available on the Bank of America Investor Relations website  
at www.bankofamerica.com/investor.

People

Pay equality: Ratio of the basic salary and remuneration for 
each employee category by significant locations of operation 
for priority areas of equality: women to men; minor to major 
ethnic groups; and other relevant equality areas. 

Wage level (%):  
1. Ratios of standard entry-level wage by gender compared to 
local minimum wage
2. Ratio of CEO’s total annual compensation to median total 
annual compensation of all employees (excluding the CEO) 

Risk for incidents of child, forced or compulsory labor: An 
explanation of the operations and suppliers considered to have 
significant risk for incidents of child labor, forced or compulsory 
labor. Such risks could emerge in relation to type of operation 
(such as manufacturing plant) and type of supplier; or countries or 
geographic areas with operations and suppliers considered at risk.

Discrimination and Harassment Incidents (#) and 
the Total Amount of Monetary Losses ($): Number 
of discrimination and harassment incidents, status of the 
incidents and actions taken and the total amount of monetary 
losses as a result of legal proceedings associated with (1) law 
violations and (2) employment discrimination.

Freedom of Association and Collective Bargaining  
at Risk (%):
1. Percentage of active workforce covered under collective 
bargaining agreements
2. An explanation of the assessment performed on suppliers 
for which the right to freedom of association and collective 
bargaining is at risk including measures taken by the 
organization to address these risks. 

Health and Safety (%):
1. The number and rate of fatalities as a result of work-related 
injury; high-consequence work-related injuries (excluding 
fatalities); recordable work-related injuries, main types of work-
related injury; and the number of hours worked. 
2. An explanation of how the organization facilitates workers’ 
access to non-occupational medical and healthcare services 
and the scope of access provided for employees and workers. 

Training provided (#, $):
1. Average hours of training per person that the organization’s 
employees have undertaken during the reporting period, by 
gender and employee category (total number of trainings 
provided to employees divided by the number of employees).
2. Average training and development expenditure per full time 
employee. 

Number of unfilled “Skilled” positions (#, %):
1. Number of unfilled “Skilled” positions (#)
2. Percentage of unfilled “Skilled” positions for which the 
company will hire unskilled candidates and train them. (%). 

Refer to the Equal Pay for Equal Work Section in our 2021 Proxy 
Statement available on the Bank of America Investor Relations website  
at www.bankofamerica.com/investor. 
We conduct rigorous analysis with outside experts to examine individual 
employee pay before year-end compensation decisions are finalized 
adjusting compensation where appropriate. The results of our equal pay 
for equal work review are disclosed in the Proxy Statement. Our analysis 
focuses on total compensation and includes geographies where we have 
significant operations for women and covers the U.S. for people of color. 

1. 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 was raised to $20 in the 
first quarter of 2020, more than one year earlier than planned. 

We compare our average U.S. hourly pay and benefits to living wage 
standards utilizing MIT’s Living Wage Calculator. The Living Wage 
calculator is a market based approach that measures the basic needs 
of a family including items such as food, childcare, health insurance 
and housing costs. We are above the living wage for a family of four in 
all of our U.S. markets when we consider our average hourly pay plus 
benefits in alignment with the living wage definition.

2. Refer to the section entitled “CEO pay ratio” in our 2021 Proxy 
Statement on the Bank of America Investor Relations website available  
at www.bankofamerica.com/investor. 

Refer to our 2019 Modern Slavery Act Statement available at  
www.bankofamerica.com/ModernSlaveryAct.

For disclosure of significant litigation and regulatory matters, see 
Note 12 — Commitments and Contingencies on page 161 of the 2020 
Financial Review section. 

1. No U.S.-based employees are subject to collective bargaining 
agreements.
2. We do not currently conduct this assessment. 

1. This metric is not material for the banking industry. 

2. Refer to pages 20–23 of our 2020 Human Capital Management 
Report on the Bank of America Investor Relations website available at 
www.bankofamerica.com/investor.

1. Training Hours Per Person

Total
Female
POC
Black/
African American
Hispanic/Latino

2. $1,600 per employee

42
47
54

53
66

Bank of America is committed to creating opportunities for our current 
and prospective employees to grow and develop, including creating 
avenues for reskilling for specialized jobs. For example, we have hired 
more than 10,000 individuals from low- to moderate-income commu-
nities through our Pathways career program. For more information on 
how we attract and develop talent, refer to pages 15–18 of our Human 
Capital Management report available on the Bank of America Investor 
Relations website at www.bankofamerica.com/investor.

Health and well being

Skills for the future

44   |   BANK OF AMERICA 2020

2020 Financial Review

BANK OF AMERICA 2020   |   45

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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
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
Climate Risk Management
Complex Accounting Estimates
Non-GAAP Reconciliations
Statistical Tables

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(the  “Corporation”)  and 

Bank  of  America  Corporation 
its 
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 
current 
expectations,  plans  or  forecasts  of  its  future  results,  revenues, 
provision  for  credit  losses,  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. 

the  Corporation’s 

statements 

represent 

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 2020 Annual Report on Form 
10-K: the Corporation’s potential judgments, 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,  and  regulatory  and  government  actions, 
including  as  a  result  of  our  participation  in  and  execution  of 
government  programs  related  to  the  Coronavirus  Disease  2019 
(COVID-19)  pandemic;  the  possibility  that  the  Corporation  could 
face  increased  claims  from  one  or  more  parties  involved  in 
mortgage  securitizations;  the  Corporation’s  ability  to  resolve 
representations  and  warranties  repurchase  and  related  claims; 
the  risks  related  to  the  discontinuation  of  the  London  Interbank 
Offered  Rate  and  other  reference  rates,  including  increased 
litigation  and  the  effectiveness  of  hedging 
expenses  and 
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 
financial  condition  and  results  of 
Corporation’s  business, 
operations; the possibility that future credit losses may be higher 
than  currently  expected  due 
in  economic 
assumptions,  customer  behavior,  adverse  developments  with 
respect  to  U.S.  or  global  economic  conditions  and  other 
uncertainties;  the  Corporation's  concentration  of  credit  risk;  the 
Corporation’s  ability 
targets  and 
expectations regarding revenue, 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 

to  changes 

its  expense 

to  achieve 

in  applying 

and  liabilities;  the  estimated  or  actual  impact  of  changes  in 
accounting  standards  or  assumptions 
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, 
stress  capital  buffer  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, 
derivatives  regulations  and  the  Coronavirus  Aid,  Relief,  and 
Economic  Security  Act  and  any  similar  or  related  rules  and 
regulations;  a 
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 climate change; the 
federal  government  shutdown  and 
impact  of  any 
uncertainty  regarding  the  federal  government’s  debt  limit  or 
changes to the U.S. presidential administration and Congress; the 
emergence  of  widespread  health  emergencies  or  pandemics, 
including the magnitude and duration of the COVID-19 pandemic 
and  its  impact  on  the  U.S.  and/or  global,  financial  market 
conditions  and  our  business,  results  of  operations,  financial 
condition and prospects; the impact of natural disasters, extreme 
weather  events,  military  conflict,  terrorism  or  other  geopolitical 
events; and other matters. 

failure  or  disruption 

in  or  breach  of 

future 

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

forward-looking  statement 

reflect 

the 

to 

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 
various bank and 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

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including 

financial  markets, 

resulted  in,  among  other  things,  higher  rates  of  unemployment 
and  underemployment  and  caused  volatility  and  disruptions  in 
the  global 
the  energy  and 
commodity markets. Although vaccines have been approved for 
immunization  against  COVID-19 
in  certain  countries  and 
restrictive  measures  have  been  eased  in  certain  areas, 
COVID-19 cases have significantly increased in recent months in 
the  U.S.  and  many  regions  of  the  world  compared  to  earlier 
levels. Businesses, market participants, our counterparties and 
clients,  and  the  U.S.  and  global  economies  have  been 
negatively  impacted  and  are  likely  to  be  so  for  an  extended 
period  of  time,  as  there  remains  significant  uncertainty  about 
the timing and strength of an economic recovery. 

To address the economic impact in the U.S., in March and 
April  2020,  four  economic  stimulus  packages  were  enacted  to 
provide  relief  to  businesses  and  individuals,  including  the 
Coronavirus Aid, Relief, and Economic Security Act (CARES Act). 
Among  other  measures,  the  CARES  Act  established  the  Small 
Business  Administration  (SBA)  Paycheck  Protection  Program 
(PPP),  which  provides  loans  to  small  businesses  to  keep  their 
employees  on  payroll  and  make  other  eligible  payments.  The 
original  funding  for  the  PPP  under  the  CARES  Act  was  fully 
allocated  by  mid-April  2020,  with  additional  funding  made 
available  on  April  24,  2020  under  the  Paycheck  Protection 
Program and Health Care Enhancement Act. In December 2020, 
an additional economic stimulus package was included as part 
of 
(the 
the  Consolidated  Appropriations  Act  of  2021 
Consolidated  Appropriations  Act),  which  provides  relief  to 
individuals  and  businesses.  This  relief  included  additional 
funding  for  the  PPP  under  the  Economic  Aid  to  Hard-Hit  Small 
Businesses, Nonprofits, and Venues Act (the Economic Aid Act). 
In  response  to  the  pandemic,  the  Corporation  has 
implemented  protocols  and  processes  to  execute  its  business 
continuity plans and help protect its employees and support its 
clients.  The  Corporation  is  managing  its  response  to  the 
pandemic  according  to  its  Enterprise  Response  Framework, 
which  invokes  centralized  management  of  the  crisis  event  and 
the  integration  of  its  response.  The  CEO  and  key  members  of 
the  Corporation’s  management  team  meet  regularly  with  co-
leaders of the Executive Response Team, which is composed of 
senior  executives  across  the  Corporation,  to  help  drive 
decisions, communications and consistency of response across 
all  businesses  and  functions.  We  are  also  coordinating  with 
global,  regional  and  local  authorities  and  health  experts, 
including  the  U.S.  Centers  for  Disease  Control  and  Prevention 
(CDC) and the World Health Organization. 

Additionally,  we  have  implemented  a  number  of  measures 
to assist our employees, clients and the communities we serve 
as discussed below. 

Employees 
We are providing support to our teammates to help promote the 
health  and  safety  of  our  employees  and  help  to  ensure  our 
protocols  remain  aligned  to  current  guidance  by  monitoring 
guidance  from  the  CDC,  medical  boards  and  health  authorities 
and  sharing  such  guidance  with  our  employees.  We  are  also 
operating our businesses from remote locations and leveraging 
our business continuity plans and capabilities. 

The Corporation has globally implemented a work-from-home 
posture,  which  has  resulted  in  the  substantial  majority  of  our 
employees  working  from  home,  and  pre-planned  contingency 
strategies 
remaining 
employees.  We  continue  to  evaluate  our  continuity  plans  and 
work-from-home  strategy  in  an  effort  to  best  protect  the  health 
and safety of our employees.

for  site-based  operations 

for  our 

America,  National  Association  (Bank  of  America,  N.A.  or  BANA) 
charter.  At  December  31,  2020,  the  Corporation  had  $2.8 
trillion  in  assets  and  a  headcount  of  approximately  213,000 
employees. 

As  of  December  31,  2020,  we  served  clients  through 
operations across the U.S., its territories and approximately 35 
countries.  Our  retail  banking  footprint  covers  all  major  markets 
in  the  U.S.,  and  we  serve  approximately  66  million  consumer 
and  small  business  clients  with  approximately  4,300  retail 
financial  centers,  approximately  17,000  ATMs,  and  leading 
digital  banking  platforms  (www.bankofamerica.com)  with  more 
than 39 million active users, including approximately 31 million 
active  mobile  users.  We  offer  industry-leading  support  to 
approximately  three  million  small  business  households.  Our 
GWIM  businesses,  with  client  balances  of  $3.3  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 

(Federal  Reserve)  notified  BHCs  of 

Capital Management 
In  June  2020,  the  Board  of  Governors  of  the  Federal  Reserve 
their  2020 
System 
Comprehensive Capital Analysis and Review (CCAR) supervisory 
stress  test results. Due  to  economic uncertainty resulting from 
the  Coronavirus  Disease  2019  (COVID-19)  pandemic  (the 
pandemic),  the  Federal  Reserve  required  all  large  banks  to 
update  and  resubmit  their  capital  plans  in  November  2020 
based on the Federal Reserve’s updated supervisory stress test 
scenarios. The results of the additional supervisory stress tests 
were published in December 2020. 

The Federal Reserve also required large banks to suspend 
share  repurchase  programs  during  the  second  half  of  2020, 
except  for  repurchases  to  offset  shares  awarded  under  equity-
based  compensation  plans,  and  to  limit  common  stock 
dividends  to  existing  rates  that  did  not  exceed  the  average  of 
the  last  four  quarters’  net  income.  In  December  2020,  the 
Federal Reserve announced that beginning in the first quarter of 
2021,  large  banks  would  be  permitted  to  pay  common  stock 
dividends  at  existing  rates  and  to  repurchase  shares  in  an 
amount  that,  when  combined  with  dividends  paid,  does  not 
exceed the average of net income over the last four quarters. 

On  January  19,  2021,  we  announced  that  the  Board  of 
Directors  (the  Board)  declared  a  quarterly  common  stock 
dividend  of  $0.18  per  share,  payable  on  March  26,  2021  to 
shareholders  of  record  as  of  March  5,  2021.  We  also 
announced  that  the  Board  authorized  the  repurchase  of  $2.9 
billion  in  common  stock  through  March  31,  2021,  plus 
repurchases  to  offset  shares  awarded  under  equity-based 
compensation  plans  during  the  same  period,  estimated  to  be 
approximately  $300  million.  This  authorization  equals  the 
maximum amount allowed by the Federal Reserve for the period. 
For more information, see Capital Management on page 73. 

COVID-19 Pandemic 
In  the  first  quarter  of  2020,  the  World  Health  Organization 
declared the outbreak of COVID-19 a pandemic. In an attempt to 
contain the spread and impact of the pandemic, travel bans and 
restrictions,  quarantines,  shelter-in-place  orders  and  other 
limitations on business activity were implemented. Additionally, 
there  has  been  a  decline  in  global  economic  activity,  reduced 
U.S.  and  global  economic  output  and  a  deterioration  in 
macroeconomic  conditions  in  the  U.S.  and  globally.  This  has 

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Clients 
We  continue  to  leverage  our  business  continuity  plans  and 
capabilities to service our clients and meet our clients’ financial 
needs  by  offering  assistance  to  clients  affected  by  the 
pandemic, 
including  providing  access  to  credit  and  the 
important  financial  services  on  which  our  clients  rely.  We  are 
also participating in the programs created by the CARES Act and 
Federal  Reserve  lending  programs  for  businesses,  including 
originating  PPP  loans.  We  have  also  participated  in  the  Main 
Street Lending Program, which ended on January 8, 2021. While 
most  of  our  deferral  programs  expired  in  the  third  quarter  of 
2020, we continue to offer assistance on a case-by-case basis 
when requested by clients affected by the pandemic. 

As  of  December  31,  2020,  we  had  approximately  332,000 
PPP  loans  outstanding  with  a  carrying  value  of  $22.7  billion, 
which were recorded in the Consumer, GWIM and Global Banking 
segments.  Since  the  PPP's  inception  through  February  17, 
2021, borrowers have submitted applications for forgiveness to 
us for approximately 113,000 PPP loans with balances totaling 
$10.9  billion.  We  have  submitted  approximately  72,000  PPP 
loans  with  balances  totaling  $8.5  billion  to  the  SBA  for 
repayment,  of  which  we  have  received  to  date  $5.4  billion  in 
repayment from the SBA. Additionally, as of February 17, 2021, 
we have originated $4.1 billion in PPP loans under the Economic 
Aid  Act.  For  more  information  on  PPP  loans,  see  Credit  Risk 
Management  on  page  84,  and  for  more  information  on 
accounting  for  PPP  loans  and  loan  modifications  under  the 
CARES  Act,  see  Note  1  –  Summary  of  Significant  Accounting 
Principles to the Consolidated Financial Statements. 

Community Partners 
We continue to support the communities where we live and work 
by  engaging  in  various  initiatives  to  help  those  affected  by 
COVID-19.  These  initiatives  include  committing  resources  to 
provide  medical  supplies,  food  and  other  necessities  for  those 
in  need.  We  are  also  supporting  racial  equality,  economic 
opportunity  and  environmental  sustainability  through  direct 
equity  investments  in  minority-owned  depository  institutions, 
equity  investments  in  minority  entrepreneurs,  businesses  and 
funds, as well as other initiatives. 

Risk Management 
We continue to manage the increased operational risk related to 
the  execution  of  our  business  continuity  plans  in  accordance 
with  our  Enterprise  Response  Framework,  Risk  Framework  and 
Operational  Risk  Management  Program.  For  more  information, 
see Managing Risk on page 70. 

Loan Modifications 
The  Corporation  has  implemented  various  consumer  and 
commercial loan modification programs to provide its borrowers 
relief  from  the  economic  impacts  of  COVID-19.  Based  on 
guidance  in  the  CARES  Act  that  the  Corporation  adopted, 
COVID-19  related  modifications  to  consumer  and  commercial 
loans  that  were  current  as  of  December  31,  2019  are  exempt 
from  troubled  debt  restructuring  (TDR)  classification  under 
accounting principles generally accepted in the United States of 
America  (GAAP).  In  addition,  the  bank  regulatory  agencies 
issued  interagency  guidance  stating  that  COVID-19  related 
short-term  modifications  (i.e.,  six  months  or  less)  granted  to 
consumer or commercial loans that were current as of the loan 
modification  program  implementation  date  are  not  TDRs.  In 
December 2020, the Consolidated Appropriations Act amended 
from  TDR 
the  CARES  Act  by  extending 
classification for COVID-19 related modifications from December 
31, 2020 to the earlier of January 1, 2022 or 60 days after the 
national emergency has ended. For more information, see Note 

the  exemption 

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49

1  –  Summary  of  Significant  Accounting  Principles  and  Note  5  – 
Outstanding  Loans  and  Leases  and  Allowance  for  Credit  Losses 
to the Consolidated Financial Statements. 

We  have  provided  borrowers  with  relief  from  the  economic 
impacts of COVID-19 through payment deferral and forbearance 
programs.  A  significant  portion  of  deferrals  expired  during  the 
second half of 2020, reflecting a decline in customer requests 
for  assistance.  As  of  February  17,  2021,  deferred  consumer 
and small business loans recorded on the Consolidated Balance 
Sheet  totaled  $6.8  billion,  predominantly  consisting  of  $6.4 
billion of residential mortgage and home equity loans, including 
loans serviced by others, that are well-collateralized. 

Other Related Matters 
Although the macroeconomic outlook improved modestly during 
the second half of 2020, the future direct and indirect impact of 
COVID-19 on our businesses, results of operations and financial 
condition  of  the  Corporation  remains  highly  uncertain.  Should 
current  economic  conditions  persist  or  deteriorate, 
this 
macroeconomic  environment  will  have  a  continued  adverse 
effect  on  our  businesses  and  results  of  operations  and  could 
have  an  adverse  effect  on  our  financial  condition.  For  more 
information  on  how  the  risks  related  to  the  pandemic  may 
adversely  affect  our  businesses,  results  of  operations  and 
financial  condition,  see  Item  1A.  Risk  Factors  of  our  2020 
Annual Report on Form 10-K. 

financial 

industry  working  groups  have 

LIBOR and Other Benchmark Rates 
Following  the  2017  announcement  by  the  U.K.’s  Financial 
Conduct  Authority  (FCA)  that  it  would  no  longer  compel 
participating  banks  to  submit  rates  for  the  London  Interbank 
Offered Rate (LIBOR) after 2021, regulators, trade associations 
and 
identified 
recommended  replacement  rates  for  LIBOR,  as  well  as  other 
Interbank  Offered  Rates 
(IBORs),  and  have  published 
recommended  conventions  to  allow  new  and  existing  products 
to  incorporate  fallbacks  or  that  reference  these  Alternative 
Reference  Rates  (ARRs).  The  continuation  of  all  British  Pound 
Sterling,  Euro,  Swiss  Franc  and  Japanese  Yen  LIBOR  settings 
and one-week and two-month U.S. dollar LIBOR settings on the 
current basis are expected to terminate at the end of December 
2021,  and  the  remaining  U.S.  dollar  LIBOR  settings  (i.e., 
overnight,  one  month,  three  month,  six  month  and  12  month) 
are expected to terminate at the end of June 2023. 

As  a  result  of  this  and  other  announcements,  financial 
benchmark  reforms,  regulatory  guidance  and  changes  in  short-
term  interbank  lending  markets  more  generally,  a  major 
transition is in progress in global financial markets with respect 
to  the  replacement  of  IBORs  and  certain  benchmarks.  The 
transition  of  IBORs  to  ARRs  is  a  complex  process  impacting  a 
variety  of  global  financial  markets  and  our  business  and 
operations. 

IBORs  are  used  in  many  of  the  Corporation’s  products  and 
contracts,  including  derivatives,  consumer  and  commercial 
loans,  mortgages,  floating-rate  notes  and  other  adjustable-rate 
products  and  financial  instruments.  The  discontinuation  of 
IBORs  requires  us  to  transition  a  significant  number  of  IBOR-
including  related  hedging 
based  products  and  contracts, 
arrangements.  In  response,  the  Corporation  established  an 
enterprise-wide 
led  by  senior 
management  in  early  2018.  This  program,  which  is  led  by  the 
Corporation's  Chief  Operating  Officer, 
includes  active 
involvement  of  senior  management  and  regular  reports  to  the 
Enterprise  Risk  Committee  (ERC).  The  program  is  intended  to 
address  the  Corporation's  industry  and  regulatory  engagement, 
client  and  financial  contract  changes,  internal  and  external

transition  program 

IBOR 

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communications,  technology  and  operations  modifications, 
introduction  of  new  products,  migration  of  existing  clients,  and 
program  strategy  and  governance.  In  addition,  the  program  is 
designed to monitor a variety of scenarios, including operational 
risks  associated  with  insufficient  preparation  by  individual 
market  participants  or  the  overall  market  ecosystem,  volatility 
along  the  Secured  Overnight  Financing  Rate  (SOFR)  curve, 
development  and  adoption  of  credit-sensitive  and  other  rates, 
regulatory and legal uncertainty with respect to various matters 
including  contract  continuity,  access  by  market  participants  to 
liquidity  in  certain  products,  and  IBOR  continuity  beyond 
December 2021. 

industry-recommended 

As  of  February  1,  2021,  a  significant  majority  of  the 
aggregate  notional  amount  of  our  LIBOR-based  products  and 
contracts maturing after 2021 include or have been updated to 
include  fallbacks  to  ARRs  based  on  market  driven  protocols, 
regulatory  guidance  and 
fallback 
provisions and related mechanisms. For certain of the remaining 
products  and  contracts,  the  transition  will  be  more  complex, 
particularly  where  there  is  no  industry-wide  protocol  or  similar 
mechanism.  The  Corporation  is  executing  transition  plans  that 
are  intended  to  be  in  line  with  applicable  major  industry-wide 
IBOR  product  cessation  and  launch  milestones  recommended 
by  the  Alternative  Reference  Rates  Committee,  a  group  of 
private market participants and official sector entities convened 
by  the  Federal  Reserve  and  the  Federal  Reserve  Bank  of  New 
York, and the Bank of England Sterling Risk Free Rate Working 
Group, other than the cessation of LIBOR-based adjustable-rate 
consumer  mortgages.  The  Corporation  plans  to  no  longer  offer 
these  mortgages  and 
launch  SOFR-based  adjustable-rate 
consumer mortgages by the end of the first quarter of 2021. 

The  Corporation  is  executing  product  and  client  roadmaps 
that it believes align with industry-recommended and regulatory 
milestones,  and  the  Corporation  has  developed  employee 
training programs as well as other internal and external sources 
of information on the various challenges and opportunities that 
the  replacement  of  IBORs  presents.  As  the  transition  to  ARRs 
evolves, the Corporation continues to monitor and participate in 
the  development  and  usage  of  certain  ARRs,  including  SOFR, 
the  Euro  Short  Term  Rate  and  the  Sterling  Overnight  Index 
Average (SONIA). The Corporation’s key transition efforts to date 
include  issuances  of  debt  and  deposits  linked  to  SOFR  and 
SONIA by the  Corporation, facilitating debt issuances  linked  to 
ARRs  by  clients  and  secondary  market  liquidity  for  products 
linked to ARRs, originating and arranging loans linked to ARRs, 
including  hedging  arrangements,  executing,  trading,  market 
making  and  clearing  ARR-based  derivatives,  and  launching 
capabilities and services to support the issuance and trading in 
products  indexed  to  certain  ARRs.  The  Corporation  updated  its 
operational  models,  systems,  procedures  and 
internal 
infrastructure  in  connection  with  the  transition  to  ARRs  by  the 
the 
central  clearing  counterparties. 
Corporation  and  certain  of  its  subsidiaries  adhered  to  the 
International  Swaps  and  Derivatives  Association,  Inc.  2020 
IBOR  Fallbacks  Protocol,  effective  January  25,  2021,  which 
provides  a  mechanism  to  enable  market  participants  to 
incorporate  fallbacks  for  certain  legacy  non-cleared  derivatives 
linked to certain IBORs. 

In  October  2020, 

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.  For  more  information  on  the 
expected replacement of LIBOR and other benchmark rates, see 
Item 1A. Risk Factors of our 2020 Annual Report on Form 10-K. 

U.K. Exit from the EU 
On  January  31,  2020,  the  U.K.  formally  exited  the  European 
Union (EU), and a transition period began during which time the 
U.K. and the EU negotiated a trade agreement and other terms 
associated  with  their  future  relationship.  The  transition  period 
ended 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 
and  implemented  changes  to  enable  us  to  continue  to  operate 
in the region, including establishing a bank and broker-dealer in 
the  EU,  as  well  as  minimize  the  potential  for  any  operational 
disruption.  As  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  operational,  regulatory  and  legal  risks.  For 
more information, see Item 1A. Risk Factors of our 2020 Annual 
Report on Form 10-K. 

Financial Highlights 
Effective  January  1,  2020,  we  adopted  the  new  accounting 
standard on current expected credit losses (CECL), under which 
the  allowance  is  measured  based  on  management’s  best 
estimate  of  lifetime  expected  credit  losses  (ECL).  Prior-year 
periods presented reflect measurement of the allowance based 
on  management’s  estimate  of  probable  incurred  credit  losses. 
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)
Income statement 

Net interest income
Noninterest income

Total revenue, net of interest expense

Provision for credit losses
Noninterest expense

Income before income taxes

Income tax expense

Net income

Preferred stock dividends

Net income applicable to common 

shareholders

Per common share information 

Earnings
Diluted earnings
Dividends paid
Performance ratios 

Return on average assets (1)
Return on average common shareholders’ 

equity (1)

Return on average tangible common 

shareholders’ equity (2)

Efficiency ratio (1)

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

$

$

$

2020

2019 

43,360
42,168
85,528
11,320
55,213
18,995
1,101
17,894
1,421

$ 

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

16,473

$ 

25,998 

$

1.88
1.87
0.72

2.77 
2.75 
0.66 

0.67 %

1.14 % 

6.76

9.48
64.55

10.62 

14.86 
60.17 

$  927,861
2,819,627
1,795,480
2,546,703
248,414
272,924

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

(1)  For definitions, see Key Metrics on page 196. 
(2)  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 111.

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Net income was $17.9 billion or $1.87 per diluted share in 
2020  compared  to  $27.4  billion  or  $2.75  per  diluted  share  in 
2019.  The  decline  in  net  income  was  primarily  due  to  higher 
provision  for  credit  losses  driven  by  the  weaker  economic 
outlook related to COVID-19 and lower net interest income. 

For  discussion  and  analysis  of  our  consolidated  and 
business  segment  results  of  operations  for  2019  compared  to 
2018,  see  the  Financial  Highlights  and  Business  Segment 
Operations  sections  in  the  MD&A  of  the  Corporation's  2019 
Annual Report on Form 10-K. 

Net Interest Income 
Net  interest  income  decreased  $5.5  billion  to  $43.4  billion  in 
2020  compared  to  2019.  Net  interest  yield  on  a  fully  taxable-
equivalent (FTE) basis decreased 53 basis points (bps) to 1.90 
percent  for  2020.  The  decrease  in  net  interest  income  was 
primarily  driven  by  lower  interest  rates,  partially  offset  by 
reduced  deposit  and  funding  costs,  the  deployment  of  excess 
deposits  into  securities  and  an  additional  day  of  interest 
accrual. Assuming continued economic improvement and based 
on the forward interest rate curve as of January 19, 2021, when 
we  announced  quarterly  and  annual  results  for  the  periods 
ended December 31, 2020, we expect net interest income to be 
higher  in  the  second  half  of  2021  as  compared  to  both  the 
second  half  of  2020  and  the  first  half  of  2021.  For  more 
information  on  net  interest  yield  and  the  FTE  basis,  see 
Supplemental  Financial  Data  on  page  54,  and  for  more 
information on interest rate risk management, see Interest Rate 
Risk Management for the Banking Book on page 105. 

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

2020

2019 

$

$

5,656  $
7,141
14,574
7,180
34,551
8,355
(738)
42,168  $

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

Noninterest  income  decreased $185  million  to  $42.2  billion  in 
2020 compared to 2019. The following highlights the significant 
changes. 
•  Card  income  decreased  $141  million  primarily  due  to  lower 
levels  of  consumer  spending  driven  by  the  impact  of 
COVID-19,  partially  offset  by  higher  income  related  to  the 
processing of unemployment insurance. 

•  Service  charges  decreased  $533  million  primarily  due  to 
higher  deposit  balances  and  lower  client  activity  due  to  the 
impact of COVID-19. 
Investment  and  brokerage  services  income  increased  $672 
million  primarily  due  to  higher  client  transactional  activity, 
higher  market  valuations  and  assets  under  management 
(AUM) flows, partially offset by declines in AUM pricing. 

• 

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• 

Investment  banking  fees  increased  $1.5  billion  primarily 
driven by higher equity issuance fees. 

•  Market making and similar activities decreased $679 million 
primarily  due  to  the  impact  of  lower  U.S.  interest  rates  on 
certain  risk  management  derivatives,  partially  offset  by 
increased  client  activity  and  strong  trading  performance  in 
fixed income, currencies and commodities (FICC). 

•  Other  income  decreased  $1.0  billion  primarily  due  to  lower 
equity  investment  income,  higher  partnership  losses  on  tax 
credit 
investments,  primarily  affordable  housing  and 
renewable  energy,  partially  offset  by  higher  gains  on  loan 
sales and sales of debt securities. 

Provision for Credit Losses 
The  provision  for  credit  losses  increased  $7.7  billion  to  $11.3 
billion in 2020 compared to 2019 primarily driven by higher ECL 
due  to  a  weaker  economic  outlook  related  to  COVID-19.  For 
more  information  on  the  provision  for  credit  losses,  see 
Allowance for Credit Losses on page 99. 

Noninterest Expense 

Table 3  Noninterest Expense 

(Dollars in millions)
Compensation and benefits 
Occupancy and equipment
Information processing and communications
Product delivery and transaction related
Marketing
Professional fees
Other general operating

2020

2019 

$

 $

32,725
7,141
5,222
3,433
1,701
1,694
3,297

31,977 
6,588 
4,646 
2,762 
1,934 
1,597 
5,396 
54,900 

Total noninterest expense

$

55,213  $

Noninterest expense increased $313 million to $55.2 billion in 
2020  compared  to  2019.  The  increase  was  primarily  due  to 
higher  operating  costs  related  to  COVID-19,  merchant  services 
expenses,  which  were  previously  recorded  in  other  income  as 
part  of  joint  venture  net  earnings,  and  higher  activity-based 
expenses  due  to  increased  client  activity,  partially  offset  by  a 
$2.1  billion  pretax  impairment  charge  related  to  the  notice  of 
termination of the merchant services joint venture in 2019. 

Income Tax Expense 

Table 4  Income Tax Expense 

(Dollars in millions)
Income before income taxes
Income tax expense
Effective tax rate

$ 

2020
18,995
1,101

2019 
$  32,754 
5,324 

5.8 %

16.3 % 

Income  tax  expense  was  $1.1  billion  for  2020  compared  to 
$5.3  billion  in  2019,  resulting  in  an  effective  tax  rate  of  5.8 
percent compared to 16.3 percent.

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The change in the effective tax rate for 2020 was driven by 
the  impact  of  our  recurring  tax  preference  benefits  on  lower 
levels of pretax income. These benefits primarily consist of tax 
credits  from  environmental,  social  and  governance  (ESG) 
investments  in  affordable  housing  and  renewable  energy, 
aligning  with  our  responsible  growth  strategy  to  address  global 
sustainability  challenges.  Excluding  tax  credits  related  to  our 
ESG  investment  activity,  the  effective  tax  rate  for  2020  would 
have been 21 percent. 

The 2020 rate also included the impact of the U.K. tax law 
change, whereby on July 22, 2020, the U.K. enacted a repeal of 
the  final  two  percent  of  scheduled  decreases  in  the  U.K. 
corporation  tax  rate,  which  had  been  previously  enacted.  This 
change will unfavorably affect income tax expense on future U.K. 

Balance Sheet Overview 

Table 5  Selected Balance Sheet Data 

earnings, and requires a reversal of the adjustment to the U.K. 
net  deferred  tax  assets  recognized  at  the  time  the  tax  rate 
decreases  were originally enacted. Accordingly,  during the third 
quarter of 2020, the Corporation recorded an income tax benefit 
of  approximately  $700  million  along  with  a  corresponding 
increase to the U.K. net deferred tax assets. 

The  effective  tax  rate  for  2019  included  net  tax  benefits 
primarily  related  to  the  resolution  of  various  tax  controversy 
matters. 

Absent  unusual  items,  we  expect  the  effective  tax  rate  for 
2021  to  be  in  the  range  of  10  –  12  percent,  reflecting  tax 
credits related to our ESG investment activity. 

(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 

2020

2019

% Change 

$

380,463  $
304,058
198,854
684,850
927,861
(18,802)
342,343

161,560
274,597
229,826
472,197
983,426
(9,416)
321,889
$  2,819,627  $  2,434,079

$  1,795,480  $  1,434,803
165,109
83,270
24,204
240,856
221,027
2,169,269
264,810
$  2,819,627  $  2,434,079

170,323
71,320
19,321
262,934
227,325
2,546,703
272,924

135 % 
11 
(13) 
45 
(6) 
100 
6 
16 

25 
3 
(14) 
(20) 
9 
3 
17 
3 
16 

Assets 
At  December  31,  2020,  total  assets  were  approximately  $2.8 
trillion,  up  $385.5  billion  from  December  31,  2019.  The 
increase  in  assets  was  primarily  due  to  higher  cash  held  at 
central  banks  that  was  primarily  funded  by  deposit  growth  and 
debt securities, partially offset by a decline in loans and leases. 

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 decreased $31.0 billion 
due to a decline in inventory within Global Markets. 

Cash and Cash Equivalents  
Cash  and  cash  equivalents  increased  $218.9  billion  driven  by 
deposit growth. 

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  $29.5  billion 
primarily due to deployment of deposit inflows. 

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  $212.7  billion  primarily 
driven  by  the  deployment  of  deposit 
inflows.  For  more 
information  on  debt  securities,  see  Note  4  –  Securities  to  the 
Consolidated Financial Statements.

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Loans and Leases 
Loans  and  leases  decreased  $55.6  billion  primarily  driven  by 
commercial  loan  paydowns,  lower  credit  card  spending  and 
lower  residential  mortgages  due  to  higher  paydowns  and  a 
decline  in  originations.  For  more  information  on  the  loan 
portfolio, see Credit Risk Management on page 84. 

Allowance for Loan and Lease Losses 
The allowance for loan and lease losses increased $9.4 billion 
primarily  due  to  the  weaker  economic  outlook  related  to 
COVID-19 and the impact of the adoption of the new credit loss 
accounting  standard.  For  more  information,  see  Allowance  for 
Credit Losses on page 99. 

Liabilities 
At December 31, 2020, total liabilities were approximately $2.5 
trillion,  up  $377.4  billion  from  December  31,  2019,  primarily 
due to deposit growth. 

Deposits 
Deposits  increased  $360.7  billion  primarily  due  to  an  increase 
in 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 
repurchase  are  collateralized  borrowing 
transactions  utilized  to  accommodate  customer  transactions, 
earn  interest  rate  spreads  and  finance  assets  on  the  balance 
sheet.  Federal  funds  purchased  and  securities  loaned  or  sold 
under agreements to repurchase increased $5.2 billion primarily 
driven by client activity within Global Markets. 

to 

Trading Account Liabilities 
Trading account liabilities consist primarily of short positions in 
equity  and  fixed-income  securities  including  U.S.  Treasury  and 
agency  securities,  corporate  securities  and  non-U.S.  sovereign 
debt.  Trading  account 
liabilities  decreased  $12.0  billion 
primarily  due  to  lower  levels  of  short  positions  within  Global 
Markets. 

Short-term Borrowings 
Short-term borrowings provide an additional funding source and 
primarily consist of Federal Home Loan Bank (FHLB) short-term 
borrowings,  notes  payable  and  various  other  borrowings  that 
generally  have  maturities  of  one  year  or  less.  Short-term 
borrowings decreased $4.9 billion due to higher deposit levels. 
For  more  information  on  short-term  borrowings,  see  Note  10  – 
Federal  Funds  Sold  or  Purchased,  Securities  Financing 
Agreements,  Short-term  Borrowings  and  Restricted  Cash  to  the 
Consolidated Financial Statements. 

Long-term Debt 
Long-term  debt  increased  $22.1  billion  primarily  due  to  debt 
issuances  and  valuation  adjustments,  partially  offset  by 
maturities  and  redemptions.  For  more  information  on  long-term 
debt,  see  Note  11  –  Long-term  Debt  to  the  Consolidated 
Financial Statements. 

Shareholders’ Equity 
Shareholders’  equity  increased  $8.1  billion  driven  by  net 
income,  market  value 
increases  on  debt  securities  and 
issuances of preferred and common stock, partially offset by the 
return  of  capital  to  shareholders  totaling  $14.7  billion  through 
share repurchases and common and preferred stock dividends, 
as  well  as  the  impact  of  the  adoption  of  the  new  credit  loss 
accounting standard and the redemption 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 80.

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shareholders’  equity  as  key  measures  to  support  our  overall 
growth objectives. These ratios are as follows: 

•  Return  on  average  tangible  common  shareholders’  equity 
measures  our  net 
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. 

income  applicable 

•  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  ratios  utilizing  tangible  equity  provide  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 

financial  measures 
measures, see Non-GAAP Reconciliations on page 111. 

the  corresponding  GAAP 

to 

Key Performance Indicators 
We  present  certain  key  financial  and  nonfinancial  performance 
indicators  (key  performance  indicators)  that  management  uses 
when  assessing  our  consolidated  and/or  segment  results.  We 
believe  they  are  useful  to  investors  because  they  provide 
additional 
information  about  our  underlying  operational 
performance  and  trends.  These  key  performance  indicators 
(KPIs)  may  not  be  defined  or  calculated  in  the  same  way  as 
similar  KPIs  used  by  other  companies.  For  information  on  how 
these metrics are defined, see Key Metrics on page 196. 

Our  consolidated  key  performance  indicators,  which  include 
various  equity  and  credit  metrics,  are  presented  in  Table  1  on 
page 50 and/or Tables 6 and 7 on pages 55 and 56. 

For  information  on  key  segment  performance  metrics,  see 

Business Segment Operations on page 59.

Supplemental Financial Data 

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

We view net interest income and related ratios and analyses 
on an FTE basis, which when presented on a consolidated basis 
are  non-GAAP  financial  measures.  To  derive  the  FTE  basis,  net 
interest income is adjusted to reflect tax-exempt income on an 
equivalent  before-tax  basis  with  a  corresponding  increase  in 
income  tax  expense.  For  purposes  of  this  calculation,  we  use 
the federal statutory tax rate of 21 percent 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. 

equity 

represents 

shareholders’ 

We also evaluate our business based on certain ratios that 
utilize  tangible  equity,  a  non-GAAP  financial  measure.  Tangible 
equity 
common 
shareholders’  equity  reduced  by  goodwill  and  intangible  assets 
(excluding  mortgage  servicing  rights  (MSRs)),  net  of  related 
deferred  tax  liabilities  ("adjusted"  shareholders'  equity  or 
common  shareholders'  equity).  These  measures  are  used  to 
evaluate our use of equity. In addition, profitability, relationship 
and  investment  models  use  both  return  on  average  tangible 
common  shareholders’  equity  and  return  on average tangible 

or 

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Table 6  Five-year Summary of Selected Financial Data 

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(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 (1) 
Return on average common shareholders’ equity (1) 
Return on average tangible common shareholders’ equity (2) 
Return on average shareholders’ equity (1) 
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 (1) 
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 (3) 

2020

2019

2018

2017

2016 

$  43,360
42,168
85,528
11,320
55,213
18,995
1,101
17,894
16,473
8,753.2
8,796.9

$  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 

0.67 %
6.76
9.48
6.69
9.07
9.68
9.96
38.18

$

1.88
1.87
0.72
28.72
20.60
$  262,206

$  982,467
2,683,122
1,632,998
220,440
243,685
267,309

1.14 %

1.21 %

10.62
14.86
10.24
13.85
10.88
11.14
23.65

$

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

11.04
15.55
10.63
14.46
11.27
11.39
20.31

$

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

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 

$

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 

Allowance for credit losses (4) 
Nonperforming loans, leases and foreclosed properties (5) 
Allowance for loan and lease losses as a percentage of total loans and leases 

outstanding (5) 

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

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

$  20,680
5,116

$  10,229
3,837

$  10,398
5,244

$  11,170
6,758

$  11,999 
8,084 

2.04 %

0.97 %

1.02 %

1.12 %

1.26 % 

$

380
4,121

0.42 %

$

265
3,648

194
3,763

161
3,979

$

$

$

149 
3,821 

0.38 %

0.41 %

0.44 %

0.43 % 

Capital ratios at year end (6) 

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

11.9 %
13.5
16.1
7.4
7.2
7.4
6.5

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 

(1)  For definitions, see Key Metrics on page 196 
(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 54 and Non-GAAP Reconciliations on page 111. 

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

(4) 
(5)  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 90 and corresponding Table 28 and Commercial Portfolio Credit Risk Management 
– Nonperforming Commercial Loans, Leases and Foreclosed Properties Activity on page 94 and corresponding Table 35. 

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

information, including which approach is used to assess capital adequacy, see Capital Management on page 73. 

n/a = not applicable

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Table 7  Selected Quarterly Financial Data 

(In millions, except per share information)

Fourth

Third

Second

First

Fourth

Third

Second

First 

2020 Quarters

2019 Quarters 

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 (1) 
Four-quarter trailing return on average assets (2) 
Return on average common shareholders’ equity (1) 
Return on average tangible common shareholders’ equity (3) 
Return on average shareholders’ equity (1) 
Return on average tangible shareholders’ equity (3) 
Total ending equity to total ending assets
Total average equity to total average assets
Dividend payout

Per common share data 

Earnings
Diluted earnings
Dividends paid
Book value (1) 
Tangible book value (3) 

Market capitalization
Average balance sheet 

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

Asset quality 

$  10,253
9,846
20,099
53
13,927
6,119
649
5,470
5,208
8,724.9
8,785.0

$  10,129
10,207
20,336
1,389
14,401
4,546
(335)
4,881
4,440
8,732.9
8,777.5

$  10,848
11,478
22,326
5,117
13,410
3,799
266
3,533
3,284
8,739.9
8,768.1

$  12,130
10,637
22,767
4,761
13,475
4,531
521
4,010
3,541
8,815.6
8,862.7

$  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 

0.78 %
0.67
8.39
11.73
8.03
10.84
9.68
9.71
30.11

0.71 %
0.75
7.24
10.16
7.26
9.84
9.82
9.76
35.36

0.53 %
0.81
5.44
7.63
5.34
7.23
9.69
9.85
47.87

0.65 %
0.99
5.91
8.32
6.10
8.29
10.11
10.60
44.57

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 

$

0.60
0.59
0.18

$

0.51
0.51
0.18

$

0.38
0.37
0.18

$

0.40
0.40
0.18

$

0.75
0.74
0.18

$

$

0.57
0.56
0.18

0.75
0.74
0.15

$

0.71 
0.70 
0.15 

28.72
20.60
$ 262,206

$ 934,798
2,791,874
1,737,139
225,423
246,840
271,020

28.33
20.23
$ 208,656

27.96
19.90
$ 205,772

27.84
19.79
$ 184,181

27.32
19.41
$ 311,209

26.96
19.26
$ 264,842

26.41
18.92
$ 270,935

25.57 
18.26 
$ 263,992 

$ 974,018
2,739,684
1,695,488
224,254
243,896
267,323

$1,031,387 
2,704,186
1,658,197
221,167
242,889
266,316

$ 990,283
2,494,928
1,439,336
210,816
241,078
264,534

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

$ 964,733
2,412,223
1,375,052
202,620
246,630
270,430

$ 950,525
2,399,051
1,375,450
201,007
245,438
267,975

$ 944,020 
2,360,992 
1,359,864 
196,726 
243,891 
266,217 

Allowance for credit losses (4) 
Nonperforming loans, leases and foreclosed properties (5) 

$  20,680
5,116

$  21,506
4,730

$  21,091
4,611

$  17,126
4,331

$  10,229
3,837

$  10,242
3,723

$  10,333
4,452

$  10,379 
5,145 

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

and leases outstanding (5) 

Allowance for loan and lease losses as a percentage of total 

nonperforming loans and leases (5) 

Net charge-offs

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

leases outstanding (5) 
Capital ratios at period end (6) 

Common equity tier 1 capital
Tier 1 capital

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

Total loss-absorbing capacity and long-term debt metrics 
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 exposure

2.04 %

2.07 %

1.96 %

1.51 %

0.97 %

0.98 %

1.00 %

1.02 % 

380
881 

$

431
972

441
1,146

 $

389
1,122

 $

 $

265
959

 $

271
811

 $

228
887

 $

197 
991

$

0.38 %

0.40 %

0.45 %

0.46 %

0.39 %

0.34 %

0.38 %

0.43 % 

11.9 %
13.5

16.1
7.4
7.2

7.4
6.5

27.4 %
14.5
13.3
7.1

11.9 %
13.5

16.1
7.4
6.9

7.4
6.6

26.9 %
13.7
12.9
6.6

11.4 %
12.9

14.8
7.4
7.1

7.3
6.5

26.0 %
14.2
12.4
6.7

10.8 %
12.3

14.6
7.9
6.4

7.7
6.7

24.6 %
12.8
11.6
6.1

11.2 %
12.6

14.7
7.9
6.4

8.2
7.3

24.6 %
12.5
11.5
5.8

11.4 %
12.9

15.1
8.2
6.6

8.4
7.4

24.8 %
12.7
11.4
5.8

11.7 %
13.3

15.4
8.4
6.8

8.7
7.6

25.5 %
13.0
11.8
6.0

11.6 % 
13.1 

15.2 
8.4 
6.8 

8.5 
7.6 

24.8 % 
12.8 
11.4 
5.9 

(1)  For definitions, see Key Metrics on page 196. 
(2)  Calculated as total net income for four consecutive quarters divided by annualized average assets for four consecutive quarters. 
(3)  Tangible  equity  ratios  and  tangible  book  value  per  share  of  common  stock  are  non-GAAP  financial  measures.  For  more  information  on  these  ratios  and  corresponding  reconciliations  to  GAAP 

financial measures, see Supplemental Financial Data on page 54 and Non-GAAP Reconciliations on page 111. 
Includes the allowance for loan and lease losses and the reserve for unfunded lending commitments. 

(4) 
(5)  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 91 and corresponding Table 28 and Commercial Portfolio Credit Risk Management 
– Nonperforming Commercial Loans, Leases and Foreclosed Properties Activity on page 95 and corresponding Table 35. 
(6)  For more information, including which approach is used to assess capital adequacy, see Capital Management on page 73.

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Table 8  Average Balances and Interest Rates - FTE Basis 

(Dollars in millions)

Earning assets 

Average 
Balance 

Interest 
Income/ 
Expense (1) 

2020

Yield/ 
Rate 

Average 
Balance 

Interest 
Income/ 
Expense (1) 

2019

Yield/ 
Rate 

Average 
Balance 

Interest 
Income/ 
Expense (1) 

2018 

Yield/ 
Rate 

Interest-bearing deposits with the Federal Reserve, non-

U.S. central banks and other banks

$  253,227 

$

Time deposits placed and other short-term investments

8,840

359

29

903

4,185

9,868

7,338

1,290

8,759

2,545

19,932

9,712

2,208

1,790

559

14,269

34,201

2,539

52,084

0.14 %  $  125,555  $ 

1,823

1.45 %  $  139,848  $ 

1,926

0.33

0.29

2.83

1.87

3.10

3.37

10.30

2.83

4.43

2.82

2.07

2.82

3.02

2.68

3.48

3.06

2.25

9,427

207

2.19

9,446

216

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

10,166

3,261

23,272

13,161

3,402

2,741

718

20,022

43,294

4,478

71,831

3,176

4,901

11,837

7,294

2,573

9,579

3,104

22,550

11,937

3,220

2,618

698

18,473

41,023

4,300

67,379

1.73

3.56

2.65

3.47

4.92

10.76

3.60

5.17

4.09

3.27

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

1,980,231

25,830 

319,185 

$ 2,325,246 

1.38 % 

2.29 

1.26 

3.69 

2.66 

3.51 

4.77 

10.12 

3.34 

5.02 

3.92 

3.30 

4.34 

3.24 

3.82 

4.40 

5.62 

3.40 

309,945

148,076

532,266

236,719

38,251

85,017

89,974

449,961

344,095

106,487

63,428

18,496

532,506

982,467

83,078

2,317,899

31,885

333,338

$  2,683,122

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
Direct/Indirect and other consumer (3) 

Total consumer
U.S. commercial (4) 
Non-U.S. commercial (4) 
Commercial real estate (5) 

Commercial lease financing

Total commercial

Total loans and leases

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

Demand 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

$

58,113 

$

829,719

47,780

64,857

6

977

405

323

1,000,469

1,711

1,476

184

75,386

77,046

4

—

228

232

0.01 %  $

52,020  $

5

0.01 %  $

54,226  $

6

0.01 % 

0.12

0.85

0.50

0.17

0.27

0.01

0.30

0.30

0.18

0.34

2.35

1.96

0.50

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

979,057

7,188

276,432

45,449

201,623

7,208

1,249

6,700

1,502,561

22,345

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 

401,269

234,111

267,889

$ 2,405,830

425,698 

224,482 

264,748 

$ 2,325,246 

1.75 %

0.15

1.90 %

2.03 %

0.40

2.43 %

$  49,486

2.08 % 

0.37 

2.45 % 

$  48,772

Total interest-bearing deposits

1,077,515

1,943

Federal funds purchased, securities loaned or sold under 
agreements to repurchase, short-term borrowings and 
other interest-bearing liabilities

Trading account liabilities

Long-term debt

Total interest-bearing liabilities

Noninterest-bearing sources 

Noninterest-bearing deposits
Other liabilities (6) 

Shareholders’ equity

987

974

4,321

8,225

293,466

41,386

220,440

1,632,807

555,483

227,523

267,309

Total liabilities and shareholders’ equity

$  2,683,122

Net interest spread

Impact of noninterest-bearing sources

Net interest income/yield on earning assets (7) 

$  43,859

(1) 
Includes the impact of interest rate risk management contracts. For more information, see Interest Rate Risk Management for the Banking Book on page 105. 
(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) 
(4)  Certain prior-period amounts for 2019 have been reclassified to conform to current-period presentation. 
(5) 

Includes non-U.S. consumer loans of $2.9 billion, $2.9 billion and $2.8 billion for 2020, 2019 and 2018, respectively. 

Includes U.S. commercial real estate loans of $59.8 billion, $57.3 billion and $56.4 billion, and non-U.S. commercial real estate loans of $3.6 billion, $4.7 billion and $4.0 billion for 2020, 2019 
and 2018, respectively. 
(6) 
Includes $34.3 billion, $35.5 billion and $30.4 billion of structured notes and liabilities for 2020, 2019 and 2018, respectively. 
(7)  Net interest income includes FTE adjustments of $499 million, $595 million and $610 million for 2020, 2019 and 2018, respectively.

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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 

Due to Change in (1) 
Rate
Volume
From 2019 to 2020

Net Change

Due to Change in (1) 
Volume

Rate

Net Change 

From 2018 to 2019 

5
8

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2
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3
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$  1,849  $ 

(1,464)  $ 

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
Direct/Indirect and other consumer

Total consumer
U.S. commercial (2) 
Non-U.S. commercial (2) 
Commercial real estate
Commercial lease financing

Total commercial
Total loans and leases

Other earning assets

Net increase (decrease) in interest income

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

Savings
Demand 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
Time, savings and other

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

(13)
519
3
2,188

563
(312)
(1,018)
(22)

912
80
63
(76)

(3,313)  $
(165)
(4,459)
(1,087)
(4,237)

(876)
(592)
(389)
(694)

(4,361)
(1,274)
(1,014)
(83)

905

(2,844)

$ 

$

1
507
2
(39)

(5)
68

$

 — $

(4,001)
(68)
(1,045)

(11)
(654)

(178)
(3,940)
(1,084)
(2,049)

(313)
(904)
(1,407)
(716)
(3,340)
(3,449)
(1,194)
(951)
(159)
(5,753)
(9,093)
(1,939)
(19,747)

  1
(3,494)
(66)
(1,084)
(4,643)

(16)
(586)
(602)
(5,245)

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

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

451
(111)
619

(6,672)
(164)
(2,998)

(6,221)
(275)
(2,379)
(14,120)

$

(5,627)

(193)  $
—
347
563
135

90  $
(9)
1,320
(195)
(55)

447
(446)
(17)
(76)

665
209
75
(28)

(90)
67
604
233

559
(27)
48
48

(417)

595

$

$

(1)  $

—  $

254
29
320

1,581
285
96

(6)
41

(13)
107

160
(145)
41

1,209
36
(256)

(103) 
(9) 
1,667 
368 
80 

357 
(379) 
587 
157 
722 
1,224 
182 
123 
20 
1,549 
2,271 
178 
4,452 

(1) 
1,835 
314 
416 
2,564 

(19) 
148 
129 
2,693 

1,369 
(109) 
(215) 
3,738 

$

714 

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

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

(2)  Certain prior-period amounts have been reclassified to conform to current-period presentation. 
(3) 

Includes changes in FTE basis adjustments of a $96 million decrease from 2019 to 2020 and a $15 million decrease from 2018 to 2019.

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Business Segment Operations 

Segment Description and Basis of Presentation 
We report our results of operations through 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, 
rate,  business  and 
operational  risk  components.  For  more  information  on  the 
nature  of  these  risks,  see  Managing  Risk  on  page  70.  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  7  –  Goodwill  and  Intangible  Assets  to  the 
Consolidated Financial Statements. 

interest 

For  more  information  on  our  presentation  of  financial 
information  on  an  FTE  basis,  see  Supplemental  Financial  Data 
on  page  54,  and  for  reconciliations  to  consolidated  total 
revenue, net income and period-end total assets, see Note 23 – 
Business  Segment  Information  to  the  Consolidated  Financial 
Statements. 

Key Performance Indicators 
We  present  certain  key  financial  and  nonfinancial  performance 
indicators  that  management  uses  when  evaluating  segment 
results.  We  believe  they  are  useful  to  investors  because  they 
provide  additional  information  about  our  segments’  operational 
performance, customer trends and business growth.

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Consumer Banking 

(Dollars in millions)
Net interest income
Noninterest income: 

Card income
Service charges
All other income

Total noninterest income
Total revenue, net of interest expense

Provision for credit losses
Noninterest expense

Income before income taxes

Income tax expense
Net income

Effective tax rate (1) 

Net interest yield
Return on average allocated capital
Efficiency ratio

Balance Sheet 

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

Year end 
Total loans and leases
Total earning assets (2) 
Total assets (2) 
Total deposits

Deposits

Consumer Lending

Total Consumer Banking 

2020
13,739 

2019
16,904 

$ 

$

2020
10,959

2019
11,254 

 $ 

2020
24,698

2019
28,158

 $ 

$

$

% Change 
(12)% 

(20)
3,416
310
3,706
17,445

379
11,508
5,558
1,362
4,196 

1.69 %
35
65.97

5,144 
813,779
849,924
816,968
12,000

4,673 
899,951
939,629
906,092

$

$

$

$

$

$

(33)
4,216
833
5,016
21,920

269
10,718
10,933
2,679
8,254

$

4,693
1
164
4,858
15,817

5,386
7,370
3,061
750
2,311 

$

5,117
2
294
5,413
16,667

3,503
6,928
6,236
1,528
4,708

4,673
3,417
474
8,564
33,262

5,765
18,878
8,619
2,112
6,507 

$ 

5,084
4,218
1,127
10,429
38,587

3,772
17,646
17,169
4,207
12,962

$

24.5 %

24.5 % 

2.40 %
69
48.90

3.53 %
 9
46.60

3.80 %
19
41.56

2.88
17
56.76

3.81 
35 
45.73 

5,371
703,481
735,298
702,972
12,000

$  310,436 
310,862
314,599
6,698
26,500

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

$  315,580 
858,724
898,606
823,666
38,500

$  300,933
738,807
780,742
708,340
37,000

5,467
724,573
758,459
725,665

$  295,261 
295,627
299,186
6,560

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

$  299,934 
945,343
988,580
912,652

$  317,409
760,174
804,093
730,745

(8) 
(19) 
(58) 
(18) 
(14) 

53 
7 
(50) 
(50) 
(50) 

5 % 

16 
15 
16 
4 

(6)% 
24 
23 
25 

(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’ 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  17,000  ATMS,  nationwide  call 
centers  and  leading  digital  banking  platforms  with  more  than 
39  million  active  users,  including  approximately  31  million 
active mobile users. 

Consumer Banking Results. 
Net  income  for  Consumer  Banking  decreased  $6.5  billion  to 
$6.5 billion  in 2020  compared  to 2019 primarily due  to lower 
revenue, higher provision for credit losses and higher expenses. 
Net  interest  income  decreased  $3.5 billion  to  $24.7 billion 

loan  balances.  Noninterest 

primarily  due  to  lower  rates,  partially  offset  by  the  benefit  of 
higher  deposit  and 
income 
decreased  $1.9  billion  to  $8.6  billion  driven  by  a  decline  in 
service  charges  primarily  due  to  higher  deposit  balances  and 
lower  card  income  due  to  decreased  client  activity,  as  well  as 
lower  other  income  due  to  the  allocation  of  asset  and  liability 
management (ALM) results. 

The provision for credit losses increased $2.0 billion to $5.8 
billion  primarily  due  to  the  weaker  economic  outlook  related  to 
COVID-19. Noninterest expense increased $1.2 billion to $18.9 
billion  primarily  driven  by  incremental  expense  to  support 
customers and employees during the pandemic, as well as the 
cost  of  increased  client  activity  and  continued  investments  for 
business growth, including the merchant services platform. 

The  return  on  average  allocated  capital  was  17  percent, 
down  from  35  percent,  driven  by  lower  net  income  and,  to  a 
lesser  extent,  an  increase  in  allocated  capital.  For  information 
on  capital  allocated  to  the  business  segments,  see  Business 
Segment Operations on page 59.

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

Net  income  for  Deposits  decreased  $4.1  billion  to  $4.2 
billion  primarily  driven  by  lower  revenue.  Net  interest  income 
declined  $3.2  billion  to  $13.7  billion  primarily  due  to  lower 
interest  rates,  partially  offset  by  the  benefit  of  growth  in 
deposits.  Noninterest  income  decreased  $1.3  billion  to  $3.7 
billion  primarily  driven  by  lower  service  charges  due  to  higher 
deposit balances and lower client activity related to the impact 
of COVID-19, as well as lower other income due to the allocation 
of ALM results. 

The  provision  for  credit  losses  increased  $110  million  to 
$379  million  in  2020  due  to  the  weaker  economic  outlook 
related  to  COVID-19.  Noninterest  expense  increased  $790 
million  to  $11.5  billion  driven  by  continued  investments  in  the 
business  and  incremental  expense  to  support  customers  and 
employees during the pandemic. 

Average deposits increased $114.0 billion to $817.0 billion 
in  2020  driven  by  strong  organic  growth  of  $79.3  billion  in 
checking  and  time  deposits  and  $34.4  billion  in  traditional 
savings and money market savings. 

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The  following  table  provides  key  performance  indicators  for 
Deposits. Management uses these metrics, and we believe they 
are  useful  to 
investors  because  they  provide  additional 
information  to  evaluate  our  deposit  profitability  and  digital/ 
mobile trends. 

Key Statistics – Deposits 

Total deposit spreads (excludes noninterest costs) (1) 

Year End 
Consumer investment assets (in millions) (2) 
Active digital banking users (units in thousands) (3) 
Active mobile banking users (units in thousands) (4) 
Financial centers
ATMs

2020
1.94%

2019 
2.34% 

$306,104  $240,132 

39,315
30,783
4,312
16,904

38,266 
29,174 
4,300 
16,788 

(1) 

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 at period end. 
(4)  Active mobile banking users represents mobile users at period end. 

Consumer  investment  assets  increased  $66.0  billion  in 
2020  driven  by  market  performance  and  client  flows.  Active 
mobile  banking  users  increased  approximately  two  million 
reflecting  continuing  changes 
in  our  customers’  banking 
preferences.  We  had  a  net  increase  of  12  financial  centers  as 
we continued to optimize our consumer banking network. 

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 
income  and  other 
card 
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.

fees,  mortgage  banking 

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Net  income  for  Consumer  Lending  was  $2.3  billion,  a 
decrease  of  $2.4  billion,  primarily  due  to  higher  provision  for 
credit  losses.  Net  interest  income  declined  $295  million  to 
$11.0 billion primarily due to lower interest rates, partially offset 
by  loan  growth.  Noninterest  income  decreased  $555  million  to 
$4.9  billion  primarily  driven  by  lower  card  income  due  to  lower 
client  activity,  as  well  as  lower  other  income  due  to  the 
allocation of ALM results. 

The provision for credit losses increased $1.9 billion to $5.4 
billion  primarily  due  to  the  weaker  economic  outlook  related  to 
COVID-19. Noninterest expense increased $442 million to $7.4 
billion  primarily  driven  by  investments  in  the  business  and 
incremental  expense  to  support  customers  and  employees 
during the pandemic. 

Average  loans  increased  $14.9  billion  to  $310.4  billion 
primarily driven by an increase in residential mortgages and PPP 
loans, partially offset by a decline in credit cards. 

The  following  table  provides  key  performance  indicators  for 
Consumer  Lending.  Management  uses  these  metrics,  and  we 
believe  they  are  useful  to  investors  because  they  provide 
additional information about loan growth and profitability. 

the 

lower 

interest 

During  2020,  the  total  risk-adjusted  margin  increased  88 
bps  compared  to  2019  driven  by  a  lower  mix  of  customer 
balances  at  promotional 
rate 
rates, 
environment  and  lower  net  credit  losses.  Total  credit  card 
purchase volumes declined $26.3 billion to $251.6 billion. The 
decline  in  credit  card  purchase  volumes  was  driven  by  the 
impact of COVID-19. While overall spending improved during the 
second  half  of  2020,  spending  for  travel  and  entertainment 
remained  lower  compared  to  2019.  During  2020,  debit  card 
purchase  volumes  increased  $23.8  billion  to  $384.5  billion, 
despite  COVID-19  impacts.  Debit  card  purchase  volumes 
improved  in  the  second  half  of  2020  as  businesses  reopened 
and spending improved. 

Key Statistics – Residential Mortgage Loan Production (1) 

(Dollars in millions)
Consumer Banking: 
First mortgage
Home equity

Total (2) : 

First mortgage
Home equity

2020

2019 

$

$

43,197  $

6,930

69,086  $

8,160

49,179 
9,755 

72,467 
11,131 

Key Statistics – Consumer Lending 

(Dollars in millions)
Total credit card (1) 

Gross interest yield (2) 
Risk-adjusted margin (3) 
New accounts (in thousands)
Purchase volumes

Debit card purchase volumes

2020

2019 

10.27 %
9.16
2,505
251,599
384,503

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

$ 
$ 

Includes GWIM's credit card portfolio. 

(1) 
(2)  Calculated as the effective annual percentage rate divided by average loans. 
(3)  Calculated as the difference between total revenue, net of interest expense, and net credit 

losses divided by average loans. 

(1)  The  loan  production  amounts  represent  the  unpaid  principal  balance  of  loans  and,  in  the 

(2) 

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

First mortgage loan originations in Consumer Banking and for 
the total Corporation decreased $6.0 billion and $3.4 billion in 
2020  primarily  driven  by  a  decline 
in  nonconforming 
applications. 

Home  equity  production  in  Consumer  Banking  and  for  the 
total  Corporation  decreased  $2.8  billion  and  $3.0  billion  in 
2020 primarily driven by a decline in applications.

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(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

n/m = not meaningful 

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2020

2019

% Change 

$

5,468

$

6,504

(16)% 

12,270
846
13,116
18,584

357
14,154
4,073
998
3,075

$

11,870
1,164
13,034
19,538

82
13,825
5,631
1,380
4,251

24.5 %

24.5 % 

1.73
21
76.16

2.33 
29 
70.76 

$

$

183,402
316,008
328,384
287,123
15,000

188,562
356,873
369,736
322,157

168,910
279,681
292,016
256,516
14,500

176,600
287,201
299,770
263,113

$

$

$

3 
(27) 
1 
(5) 

n/m 
2 
(28) 
(28) 
(28) 

9 % 

13 
12 
12 
3 

7 % 

24 
23 
22 

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  decreased  $1.2  billion  to  $3.1  billion 
primarily  due  to  lower  net  interest  income,  higher  noninterest 
expense and higher provision for credit losses. 

Net  interest  income  decreased  $1.0  billion  to  $5.5  billion 
due to the impact of lower interest rates, partially offset by the 
benefit of strong deposit and loan growth. 

Noninterest income, which primarily includes investment and 
brokerage  services  income,  increased  $82  million  to  $13.1 
billion  primarily  due  to  higher  market  valuations  and  positive 
AUM flows, largely offset by declines in AUM pricing as well as 
lower other income due to the allocation of ALM results. 

The  provision  for  credit  losses  increased  $275  million  to 
$357  million  primarily  due  to  the  weaker  economic  outlook 
related  to  COVID-19.  Noninterest  expense  increased  $329 
million to $14.2 billion primarily driven by higher investments in 
primary sales professionals and revenue-related incentives. 

The  return  on  average  allocated  capital  was  21  percent, 
down from 29 percent, due to lower net income and, to a lesser 
extent, a small increase in allocated capital. 

Average  loans  increased  $14.5  billion  to  $183.4  billion 
primarily  driven  by  residential  mortgage  and  custom  lending. 
Average  deposits  increased  $30.6  billion  to  $287.1  billion 
primarily  driven  by  inflows  resulting  from  client  responses  to 
market volatility and lower spending. 

MLGWM  revenue  of  $15.3  billion  decreased  five  percent 
primarily  driven  by  the  impact  of  lower  interest  rates,  partially 
offset  by  the  benefits  of  higher  market  valuations  and  positive 
AUM flows. 

Bank  of  America  Private  Bank  revenue  of  $3.3  billion 
decreased  four  percent  primarily  driven  by  the  impact  of  lower 
interest rates.

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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 (2)  (in thousands)

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

62539financials

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$

$

$

$

$

$

$

$

2020

2019 

15,292  $

3,292

18,584  $

16,112 
3,426 
19,538 

2,808,340  $

541,464

3,349,804  $

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

1,408,465  $
1,479,614
322,157
191,124
(51,556)
3,349,804  $

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

1,275,555  $
19,596
113,314

1,408,465  $

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

17,331
19,373
21,213

17,458 
19,440 
20,586 

$

1,126  $

1,082 

1,759

1,766 

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

(1) 
(2)  For a definition, see Key Metrics on page 196. 

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  $302.0  billion,  or  10  percent,  to 
$3.3 trillion at December 31, 2020 compared to December 31, 
2019.  The  increase  in  client  balances  was  primarily  due  to 
higher market valuations and positive client flows.

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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 

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2020

2019

% Change 

$

9,013

$

10,675

(16)% 

3,238
4,010
2,726
9,974
18,987

4,897
9,337
4,753
1,283
3,470

$

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

414
9,011
11,058
2,985
8,073

27.0 %

27.0 % 

1.86
 8
49.17

2.75 
20 
43.99 

$

$

382,264
485,688
542,302
456,562
42,500

339,649
522,650
580,561
493,748

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

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

$

$

$

7 
28 
(25) 
2 
(7) 

n/m 
4 
(57) 
(57) 
(57) 

2 % 

25 
22 
26 
4 

(10)% 
28 
25 
29 

lending.  Our 

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 
treasury  solutions 
business  includes  treasury  management,  foreign  exchange, 
short-term  investing  options  and  merchant  services.  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  Corporate  Banking  clients 
generally include large global corporations, financial institutions 
and  leasing  clients. 
Global  Commercial  Banking  clients 
generally  include  middle-market  companies,  commercial  real 
estate  firms  and  not-for-profit  companies.  Business  Banking 
clients 
include  mid-sized  U.S.-based  businesses  requiring 
customized and integrated financial advice and solutions. 

Net  income  for  Global  Banking  decreased  $4.6  billion  to 
$3.5 billion primarily driven by higher provision for credit losses 
as well as lower revenue. 

Revenue  decreased  $1.5  billion  to  $19.0  billion  driven  by 
lower net interest income. Net interest income decreased $1.7 

billion  to  $9.0  billion  primarily  driven  by  lower  interest  rates, 
partially offset by higher loan and deposit balances. 

Noninterest  income  of  $10.0  billion  increased  $166  million 
driven  by  higher  investment  banking  fees,  partially  offset  by 
lower  valuation  driven  adjustments  on  the  fair  value  loan 
portfolio,  debt  securities  and  leveraged  loans,  as  well  as  the 
allocation of ALM results. 

The provision for credit losses increased $4.5 billion to $4.9 
billion  primarily  due  to  the  weaker  economic  outlook  related  to 
COVID-19. Noninterest expense increased $326 million primarily 
due to continued investments in the business, partially offset by 
lower revenue-related incentives. 

The return on average allocated capital was eight percent in 
2020 compared to 20 percent in 2019 due to lower net income 
and,  to  a  lesser  extent,  an  increase  in  allocated  capital.  For 
information on capital allocated to the business segments, see 
Business Segment Operations on page 59. 

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.

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

services and PPP activities in Global Banking. 

Global Corporate, Global Commercial and Business Banking 

(Dollars in millions)
Revenue 

Global Corporate Banking

Global Commercial Banking

Business Banking

Total 

2020

2019

2020

2019

2020

2019

2020

2019 

Business Lending
Global Transaction Services 

Total revenue, net of interest expense 

$

$

3,552  $
2,986 
6,538  $

3,994
3,994 
7,988

 $

 $

3,743  $
3,169 
6,912  $

4,132
3,499 
7,631

$

 $

$

261
893 
1,154  $

363
1,064 
1,427

$

 $

7,556  $
7,048 
14,604

 $ 

8,489
8,557 
17,046 

Balance Sheet 

Average 
Total loans and leases
Total deposits

Year  end 
Total loans and leases
Total deposits

$  179,393  $  177,713  $  182,212  $  181,485  $

216,371

177,924

191,813

144,620

$  153,126  $  181,409  $  164,641  $  182,727  $

233,484

185,352

207,597

157,322

14,410
48,214

13,242
52,150

 $ 

 $ 

15,058  $  376,015  $  374,256 
362,740 
40,196
456,398

15,152  $  331,009  $  379,288 
383,178 
40,504
493,231

Business  Lending  revenue  decreased  $933  million  in  2020 
compared to 2019. The decrease was primarily driven by lower 
interest rates. 

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

Global  Transaction  Services  revenue  decreased  $1.5  billion 
in  2020  compared  to  2019  driven  by  the  allocation  of  ALM 
results, partially offset by the impact of higher deposit balances. 
Average  loans  and  leases  were  relatively  flat  in  2020 
compared  to  2019.  Average  deposits  increased  26  percent 
primarily 
client  responses  to  market  volatility, 
government stimulus and placement of credit draws. 

due 

to 

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 

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

2020

2019

Total Corporation 
2019 
2020

$

1,458  $  1,336  $  1,621  $  1,460 
3,107 
1,555
1,259 
997

1,348
453

3,443
2,328

4,010
(93)

3,137
(62)

7,392
(212)

5,826 
(184) 

$

3,917  $ 3,075  $  7,180  $  5,642 

Total Corporation investment banking fees, excluding self-led 
deals, of $7.2 billion, which are primarily included within Global 
Banking  and  Global  Markets,  increased  27  percent  primarily 
driven by higher equity issuance fees.

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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 

financing, 

securities 

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, 
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  internal  revenue-sharing 
arrangement.  Global  Banking  originates  certain  deal-related 
transactions with our corporate and commercial clients that are 

62539financials

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2020

2019

% Change 

$

4,646

$

3,915

19 % 

1,973
2,991
8,471
685
14,120
18,766

251
11,422
7,093
1,844
5,249

$

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

(9)
10,728
4,895
1,395
3,500

26.0 %

28.5 % 

15
60.86

10 
68.71 

$

$

243,519
104,697
87,125
47,655
482,996
73,062
482,171
685,047
47,400
36,000

421,698
78,415
447,350
616,609
53,925

246,336
116,883
83,216
43,273
489,708
71,334
476,225
679,300
31,380
35,000

452,499
72,993
471,701
641,809
34,676

$

$

$

14 
31 
20 
13 
21 
20 

n/m 
6 
45 
32 
50 

(1)% 

(10) 
5 
10 
(1) 
2 
1 
1 
51 
3 

(7)% 
7 
(5) 
(4) 
56 

executed  and  distributed  by  Global  Markets.  For  information  on 
investment banking fees on a consolidated basis, see page 66. 
The  following  explanations  for  year-over-year  changes  for 
Global  Markets,  including  those  disclosed  under  Sales  and 
Trading  Revenue,  are  the  same  for  amounts  including  and 
excluding net DVA. Amounts excluding net DVA are a non-GAAP 
financial  measure.  For  more  information  on  net  DVA,  see 
Supplemental Financial Data on page 54. 

Net income for Global Markets increased $1.7 billion to $5.2 
billion.  Net  DVA  losses  were  $133  million  compared  to  losses 
of  $222  million  in  2019.  Excluding  net  DVA,  net  income 
increased  $1.7  billion  to  $5.4  billion.  These  increases  were 
primarily  driven  by  higher  revenue,  partially  offset  by  higher 
noninterest expense and provision for credit losses. 

Revenue  increased  $3.2  billion  to  $18.8  billion  primarily 
driven  by  higher  sales  and  trading  revenue  and  investment 
banking fees. Sales and trading revenue increased $2.3 billion, 
and excluding net DVA, increased $2.2 billion. These increases 
were driven by higher revenue across FICC and Equities. 

The  provision  for  credit  losses  increased  $260  million 
primarily  due  to  the  weaker  economic  outlook  related  to 
COVID-19.  Noninterest  expense  increased  $694  million  to

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$11.4  billion  driven  by  higher  activity-based  expenses  for  both 
card and trading. 

Average total assets increased $5.7 billion to $685.0 billion 
driven  by  higher  client  balances  in  Global  Equities.  Year-end 
total assets decreased $25.2 billion to $616.6 billion driven by 
lower levels of inventory in FICC and increased hedging of client 
activity  in  Equities  with  derivative  transactions  relative  to  stock 
positions. 

The  return  on  average  allocated  capital  was  15  percent,  up 
from 10 percent, reflecting higher net income, partially offset by 
an increase in allocated capital. 

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, 
loan 
residential  mortgage-backed  securities,  collateralized 
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, 

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) 

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excluding  net  DVA,  which  is  a  non-GAAP  financial  measure.  For 
more information on net DVA, see Supplemental Financial Data 
on page 54. 

Sales and Trading Revenue (1, 2, 3) 

(Dollars in millions)
Sales and trading revenue 

Fixed income, currencies and commodities
Equities 

Total sales and trading revenue 

2020

2019 

$  9,595  $  8,189 
4,493 
$  15,017  $  12,682 

5,422 

$  9,725  $ 8,397  

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

4,507 
$  15,150  $  12,904 
(1 ) For  more  information  on  sales  and  trading  revenue,  see  Note  3  –  Derivatives  to  the 

Total sales and trading revenue, excluding net DVA 

5,425 

(2 )

(3 )

Consolidated Financial Statements. 
Includes FTE adjustments of $196 million and $187 million for 2020 and 2019. 
Includes  Global  Banking  sales  and  trading  revenue  of  $478  million  and  $538  million  for 
2020 and 2019. 

(4)  FICC  and  Equities  sales  and  trading  revenue,  excluding  net  DVA,  is  a  non-GAAP  financial 
measure.  FICC  net  DVA  losses  were  $130  million  and  $208  million  for  2020  and  2019. 
Equities net DVA losses were $3 million and $14 million for 2020 and 2019. 

FICC  revenue  increased  $1.3  billion  driven  by  increased 
client  activity  and  improved  market-making  conditions  across 
macro products. Equities revenue increased $918 million driven 
by increased client activity and a strong trading performance in a 
more volatile market environment. 

2020

2019

% Change 

$

$

$

$

$

34
(3,606)
(3,572)

50
1,422
(5,044)
(4,637)

(407)  $

234
(2,617)
(2,383)

(669)
3,690
(5,404)
(4,048)
(1,356)

28,159  $

228,783
18,247

42,935
210,689
21,359

$

21,301
264,141
12,998

37,156
224,375
23,089

(85)% 
38 
50 

(107) 
(61) 
(7) 
15 
(70) 

(34)% 
9 
(15) 

(43)% 
18 
(44) 

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 $763.1 billion and $544.3 billion for 2020 and 2019, and year-end allocated assets were $977.7 billion and $565.4 
billion at December 31, 2020 and 2019. 

loans  and  servicing  activities, 

All  Other  consists  of  ALM  activities,  equity  investments,  non-
core  mortgage 
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 

23  –  Business  Segment  Information  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  2020,  residential  mortgage  loans  held  for  ALM 
activities decreased $12.7 billion to $9.0 billion due primarily to 
loan  sales.  Non-core  residential  mortgage  and  home  equity 
loans, which are principally runoff portfolios, are also held in All

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Other. During 2020, total non-core loans decreased $3.0 billion 
to $12.6 billion due primarily to payoffs and paydowns, as well 
as  Federal  Housing  Administration  (FHA)  loan  conveyances  and 
sales,  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 85. 

The  net  loss  for  All  Other  decreased  $949  million  to  a  net 
loss  of  $407  million,  primarily  due  to  a  $2.1  billion  pretax 
impairment  charge  related  to  the  notice  of  termination  of  the 
merchant services joint venture in 2019, partially offset by lower 
revenue and higher provision for credit losses. 

commit  to  future  purchases  of  products  or  services  from 
unaffiliated  parties.  Purchase  obligations  are  defined  as 
obligations  that  are  legally  binding  agreements  whereby  we 
agree to purchase products or services with a specific minimum 
quantity  at  a  fixed,  minimum  or  variable  price  over  a  specified 
period  of  time.  Included  in  purchase  obligations  are  vendor 
contracts, the most significant of which include communication 
services,  processing  services  and  software  contracts.  Debt, 
lease and other obligations are more fully discussed in Note 11 
–  Long-term  Debt
and  Note  12  –  Commitments  and 
Contingencies to the Consolidated Financial Statements. 

Revenue  decreased  $1.2  billion  primarily  due 
to 
extinguishment  losses  on  certain  structured  liabilities,  higher 
client-driven  ESG 
in  higher 
partnership  losses  on  these  tax-advantaged  investments,  and 
lower net interest income, partially offset by a gain on sales of 
mortgage loans. 

investment  activity, 

resulting 

The  provision  for  credit  losses  increased  $719  million  to 
$50  million  from  a  provision  benefit  of  $669  million  in  2019, 
primarily  due  to  recoveries  from  sales  of  previously  charged-off 
non-core  consumer  real  estate  loans  in  2019,  as  well  as  the 
weaker economic outlook related to COVID-19. 

Noninterest  expense  decreased  $2.3  billion  to  $1.4  billion 
primarily  due  to  the  $2.1  billion  pretax  impairment  charge  in 
2019, partially offset by higher litigation expense. 

The  income  tax  benefit  increased  $589  million  primarily 
driven  by  the  impact  of  the  U.K.  tax  law  change  and  a  higher 
level  of  income  tax  credits  related  to  our  ESG  investment 
activity,  partially  offset  by  the  positive  impact  from  the 
resolution  of  various  tax  controversy  matters  in  2019.  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 

Table 10  Contractual Obligations 

to 

related 

Other  long-term  liabilities  include  our  contractual  funding 
obligations 
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  2020  and 
2019,  we  contributed  $115  million  and  $135  million  to  the 
Plans,  and  we  expect  to  make  $136  million  of  contributions 
during  2021.  The  Plans  are  more  fully  discussed  in  Note  17  – 
the  Consolidated  Financial 
Employee  Benefit  Plans 
Statements. 

to 

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

We also utilize variable interest entities (VIEs) in the ordinary 
course of business to support our financing and investing needs 
as well as those of our customers. For more information on our 
involvement  with  unconsolidated  VIEs,  see  Note  6  – 
Securitizations  and  Other  Variable  Interest  Entities  to  the 
Consolidated Financial Statements. 

Table 10 includes certain contractual obligations at December 

31, 2020 and 2019. 

(Dollars in millions) 
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) 

December 31, 2020 

Due After 
One Year 
Through 
Three Years 

Due After 
Three Years 
Through 
Five Years 

Due After 
Five Years

50,824  $

48,568  $  143,190  $ 

Due in One 
Year or Less  
$

20,352  $

1,927
551
50,661
1,656
4,542

3,169
700
3,206
1,092
8,123

2,395
80
426
953
6,958

4,609
103
1,563
781
30,924

December 31 
2019 

Total
262,934  $ 

12,100
1,434
55,856
4,482
50,547

Total 
240,856 
11,794 
3,530 
74,673 
4,099 
44,385 
379,337 

Total contractual obligations

$

79,689  $

67,114  $

59,380  $  181,170  $ 

387,353  $ 

(1)  Represents forecasted net interest expense on long-term debt and time deposits based on interest rates at December 31, 2020 and 2019. Forecasts are based on the contractual maturity dates 

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

Representations and Warranties Obligations 
For  information  on  representations  and  warranties  obligations  in  connection  with  the  sale  of  mortgage  loans,  see  Note  12  – 
Commitments and Contingencies to the Consolidated Financial Statements.

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Managing Risk 
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 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  to  current  or  projected  financial 
condition  arising  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 
is 
otherwise  negatively 
composed of price risk and interest rate risk. 

impact  earnings.  Market 

risk 

•  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. 

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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 
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 59. 

financial  objectives 

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. 

is 

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 
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. 

tracking  and 

responsible 

for 

For  a  more  detailed  discussion  of  our  risk  management 
activities, see the discussion below and pages 73 through 108. 
For more information about the Corporation's risks related to 
the  pandemic,  see  Item  1A.  Risk  Factors  of  our  2020  Annual 
Report  on  Form  10-K.  These  COVID-19  related  risks  are  being 
managed  within  our  Risk  Framework  and  supporting  risk 
management programs. 

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. 

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.

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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. 

62539financials

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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. 

independence  of  the 

Audit Committee 
The  Audit  Committee  oversees  the  qualifications,  performance 
Independent  Registered  Public 
and 
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 
identification, 
measurement, monitoring and control of key risks we face. The 

responsibilities 

the 

for 

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 
operational 
risk  programs,  balance  sheet  and  capital 
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  further  described  in  this 
section.

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delegate 

responsibilities, 

level  committees,  management 

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 
to 
further 
routines  or 
management 
individuals.  Executive  officers 
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. 

review  our  activities 

appropriate, 

as 

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

responsible 

Three  organizational  units  that  include  FLU  activities  and 
control function activities, but are not part of IRM are 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. 

implement  a  meaningful 

The  CRO  has  the  stature,  authority  and  independence  to 
develop  and 
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 
teams  work 
collaboratively in executing their respective duties. 

line  unit  or  control 

function.  These 

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 

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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. 

to  changes 

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 
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. 

training, 

risk  well 

procedures 

The formal processes used to manage risk represent a part of 
our  overall  risk  management  process.  We  instill  a  strong  and 
through 
comprehensive  culture  of  managing 
communications, 
and 
policies, 
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.

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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. 

risk, 

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  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 
is 
regulatory  capital 
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. 

requirements.  Capital  management 

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 59. 

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

Based  on  the  results  of  our  2020  CCAR  supervisory  stress 
test  that  was  submitted  to  the  Federal  Reserve  in  the  second 
quarter of 2020, we are subject to a 2.5 percent stress capital 
buffer  (SCB)  for  the  period  beginning  October  1,  2020  and 
ending  on  September  30,  2021.  Our  Common  equity  tier  1 
(CET1)  capital  ratio  under  the  Standardized  approach  must 
remain  above  9.5  percent  during  this  period  (the  sum  of  our 
CET1  capital  ratio  minimum  of  4.5  percent,  global  systemically 
important bank (G-SIB) surcharge of 2.5 percent and our SCB of 
2.5 percent) in order to avoid restrictions on capital distributions 
and discretionary bonus payments.

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 

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Due  to  economic  uncertainty  resulting  from  the  pandemic, 
the  Federal  Reserve  required  all  large  banks  to  update  and 
resubmit  their  capital  plans  in  November  2020  based  on  the 
Federal  Reserve’s  updated  supervisory  stress  test  scenarios. 
The  results  of  the  additional  supervisory  stress  tests  were 
published in December 2020. 

The  Federal  Reserve  also  required  large  banks  to  suspend 
share  repurchase  programs  during  the  second  half  of  2020, 
except  for  repurchases  to  offset  shares  awarded  under  equity-
based  compensation  plans,  and  to  limit  common  stock 
dividends  to  existing  rates  that  did  not  exceed  the  average  of 
the  last  four  quarters’  net  income.  The  Federal  Reserve’s 
directives regarding share repurchases aligned with our decision 
to  voluntarily  suspend  our  general  common  stock  repurchase 
program  during  the  first  half  of  2020.  The  suspension  of  our 
repurchases  did  not  include  repurchases  to  offset  shares 
awarded  under  our  equity-based  compensation  plans.  Pursuant 
to  the  Board’s  authorization,  we  repurchased  $7.0  billion  of 
common stock during 2020. 

In  December  2020,  the  Federal  Reserve  announced  that 
beginning  in  the  first  quarter  of  2021,  large  banks  would  be 
permitted to pay common stock dividends at existing rates and 
to  repurchase  shares  in  an  amount  that,  when  combined  with 
dividends paid, does not exceed the average of net income over 
the last four quarters. 

On  January  19,  2021,  we  announced  that  the  Board 
declared a quarterly common stock dividend of $0.18 per share, 
payable  on  March  26,  2021  to  shareholders  of  record  as  of 
March  5,  2021.  We  also  announced  that  the  Board  authorized 
the repurchase of $2.9 billion in common stock through March 
31,  2021,  plus  repurchases  to  offset  shares  awarded  under 
equity-based  compensation  plans  during  the  same  period, 
estimated  to  be  approximately  $300  million.  This  authorization 
equals the maximum amount allowed by the Federal Reserve for 
the period. 

Our stock repurchase program is subject to various factors, 
including  the  Corporation’s  capital  position,  liquidity,  financial 
performance and alternative uses of capital, stock trading price 
and  general  market  conditions,  and  may  be  suspended  at  any 
time.  Such  repurchases  may  be  effected  through  open  market 
purchases  or  privately  negotiated 
including 
repurchase  plans  that  satisfy  the  conditions  of  Rule  10b5-1  of 
the  Securities  Exchange  Act  of  1934,  as  amended  (Exchange 
Act). 

transactions, 

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 
requirements  and  outlined  two  methods  of 
and  buffer 

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risk-weighted  assets 

the  Standardized 
calculating 
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. 

(RWA), 

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  RWA 
under  both  the  Standardized  and  Advanced  approaches.  The 
approach  that  yields  the  lower  ratio  is  used  to  assess  capital 
adequacy 
framework.  As  of 
December 31, 2020, the CET1, Tier 1 capital and Total capital 
ratios  for  the  Corporation  were  lower  under  the  Standardized 
approach. 

including  under 

the  PCA 

ratio 

Minimum Capital Requirements 
In  order  to  avoid  restrictions  on  capital  distributions  and 
discretionary bonus  payments, the  Corporation must meet  risk-
based  capital 
include  a  capital 
than  2.5  percent,  plus  any 
conservation  buffer  greater 
applicable  countercyclical  capital  buffer  and  a  G-SIB  surcharge. 
On  October  1,  2020,  the  capital  conservation  buffer  was 
replaced  by  the  SCB  for  the  Corporation’s  Standardized 
approach  ratio  requirements.  The  buffers  and  surcharge  must 
be comprised solely of CET1 capital. 

requirements 

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  deductions  and  applicable  temporary  exclusions,  as 
well  as  the  simple  average  of  certain  off-balance  sheet 
exposures, as of the end of each month in a quarter. For more 
information, 
–  Regulatory 
Developments  on page 78. 

see  Capital  Management 

related 

Capital Composition and Ratios 
Table 11 presents Bank of America Corporation’s capital ratios 
and 
in  accordance  with  Basel  3 
Standardized  and  Advanced  approaches  as  measured  at 
December  31,  2020  and  2019.  For  the  periods  presented 
herein,  the  Corporation  met  the  definition  of  well  capitalized 
under current regulatory requirements.

information 

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Table 11  Bank of America Corporation Regulatory Capital under Basel 3 

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(Dollars in millions, except as noted)
Risk-based capital metrics: 

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

Leverage-based metrics: 

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

Supplementary leverage exposure (in billions) (6)
Supplementary leverage ratio

Risk-based capital metrics: 

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

Leverage-based metrics: 

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

Supplementary leverage exposure (in billions)
Supplementary leverage ratio

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Standardized 
Approach (1, 2) 

Advanced 
Approaches (1) 
December 31, 2020 

Regulatory 
Minimum (3) 

$

176,660
200,096
237,936
1,480

11.9 %
13.5
16.1

$

2,719

7.4 %

$

$

$

176,660 
200,096 
227,685 
1,371 

12.9 %
14.6
16.6

2,719 

7.4 %

2,786 

7.2 %

December 31, 2019 

$ 

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

$ 

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

11.2 %
12.6
14.8

$

2,374

7.9 %

$

$

11.5 %
13.0
14.7

2,374 

7.9 %

2,946 

6.4 %

9.5 % 

11.0 
13.0 

4.0 

5.0 

9.5 % 

11.0 
13.0 

4.0 

5.0 

(1)  As of December 31, 2020, capital ratios are calculated using the regulatory capital rule that allows a five-year transition period related to the adoption of CECL. 
(2)  Derivative exposure amounts are calculated using the standardized approach for measuring counterparty credit risk at December 31, 2020 and the current exposure method at December 31, 

2019. 

(3)  The capital conservation buffer and G-SIB surcharge were 2.5 percent at both December 31, 2020 and 2019. At December 31, 2020, the Corporation's SCB of 2.5 percent was applied in place of 

the capital conservation buffer under the Standardized approach. The countercyclical capital buffer for both periods was zero. The SLR minimum includes a leverage buffer of 2.0 percent. 

(4)  Total  capital  under  the  Advanced  approaches  differs  from  the  Standardized  approach  due  to  differences  in  the  amount  permitted  in  Tier  2  capital  related  to  the  qualifying  allowance  for  credit 

losses. 

(5)  Reflects total average assets adjusted for certain Tier 1 capital deductions. 
(6)  Supplementary leverage exposure at December 31, 2020 reflects the temporary exclusion of U.S. Treasury securities and deposits at Federal Reserve Banks. 

At December 31, 2020, CET1 capital was $176.7 billion, an 
increase  of  $9.9  billion  from  December  31,  2019,  driven  by 
earnings  and  net  unrealized  gains  on  available-for-sale  (AFS) 
debt  securities  included  in  accumulated  other  comprehensive 
income (OCI), partially offset by common stock repurchases and 
dividends.  Total  capital  under  the  Standardized  approach 
increased $16.7 billion primarily driven by the same factors as 
CET1  capital,  an  increase  in  the  adjusted  allowance  for  credit 

losses  included  in  Tier  2  capital  and  the  issuance  of  preferred 
stock. RWA under the Standardized approach, which yielded the 
lower  CET1  capital  ratio  at  December  31,  2020,  decreased 
$13.7  billion  during  2020  to  $1,480  billion  primarily  due  to 
lower  commercial  and  consumer  lending  exposures,  partially 
offset by investments of excess deposits in securities. Table 12 
shows  the  capital  composition  at  December  31,  2020  and 
2019.

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Table 12  Capital Composition under Basel 3 

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(Dollars in millions)
Total common shareholders’ equity
CECL transitional amount (1) 
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, net of related deferred tax liabilities
Defined benefit pension plan net assets
Cumulative unrealized net (gain) loss related to changes in fair value of financial liabilities attributable to own creditworthiness, 
net-of-tax
Other

Common equity tier 1 capital

Qualifying preferred stock, net of issuance cost
Other

Tier 1 capital

Tier 2 capital instruments
Qualifying allowance for credit losses (2) 
Other

Total capital under the Standardized approach

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December 31 

2020

2019 

$

248,414  $
4,213
(68,565)
(5,773)
(1,617)
(1,164)

1,753
(601)
176,660
23,437
(1)
200,096
22,213
15,649
(22)
237,936

241,409 
— 
(68,570) 
(5,193) 
(1,328) 
(1,003) 

1,278 
167 
166,760 
22,329 
(597) 
188,492 
22,538 
10,229 
(29) 
221,230 

(8,132) 
213,098 

Adjustment in qualifying allowance for credit losses under the Advanced approaches (2) 

Total capital under the Advanced approaches

(10,251)
227,685  $

$

(1)  The  CECL  transitional  amount  includes  the  impact  of  the  Corporation's  adoption  of  the  new  CECL  accounting  standard  on  January  1,  2020  plus  25  percent  of  the  increase  in  the  adjusted 

allowance for credit losses from January 1, 2020 through December 31, 2020. 

(2)  The balance at December 31, 2020 includes the impact of transition provisions related to the new CECL accounting standard. 

Table 13 shows the components of RWA as measured under Basel 3 at December 31, 2020 and 2019. 

Table 13  Risk-weighted Assets under Basel 3 

Standardized 
Approach (1) 

Advanced 
Approaches 

Standardized 
Approach (1) 

Advanced 
Approaches 

December 31 

(Dollars in billions)
Credit risk
Market risk
Operational risk (2) 
Risks related to credit valuation adjustments

858 
55 
500 
34 
1,447 
(1)  Derivative  exposure  amounts  are  calculated  using  the  standardized  approach  for measuring  counterparty credit risk  at December 31,  2020 and the  current exposure  method at December 31, 

2019 
1,437  $
56
n/a
n/a
1,493  $

2020
1,420  $
60
n/a
n/a
1,480  $

60
372
43
1,371  $

Total risk-weighted assets

896  $

$

$

2019. 

(2) December 31, 2020 includes the effects of an update made to our operational risk RWA model during the third quarter of 2020. 
n/a = not applicable

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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, 2020 and 2019. BANA met the definition of well capitalized under the PCA framework for both periods. 

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

Leverage-based metrics: 

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

Supplementary leverage exposure (in billions)
Supplementary leverage ratio

Risk-based capital metrics: 

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

Leverage-based metrics: 

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

Supplementary leverage exposure (in billions)
Supplementary leverage ratio

Standardized 
Approach (1, 2) 

Advanced 
Approaches (1) 
December 31, 2020 

Regulatory 
Minimum (3) 

$

164,593
164,593
181,370
1,221

13.5 %
13.5
14.9

$

2,143

7.7 %

$

$

$

164,593 
164,593 
170,922 
1,014 

16.2 %
16.2
16.9

2,143

7.7 %

2,525 

6.5 %

December 31, 2019 

$ 

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

12.5 %
12.5
13.4

$

1,780

8.7 %

$ 

$

$

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

1,780 

8.7 %

2,177 

7.1 %

7.0 % 
8.5 
10.5 

5.0 

6.0 

7.0 % 
8.5 
10.5 

5.0 

6.0 

(1)  As of December 31, 2020, capital ratios are calculated using the regulatory capital rule that allows a five-year transition period related to the adoption of CECL. 
(2)  Derivative exposure amounts are calculated using the standardized approach for measuring counterparty credit risk at December 31, 2020 and the current exposure method at December 31, 

2019. 

(3)  Risk-based  capital  regulatory  minimums  at  both  December  31,  2020  and  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 are the percent required to be considered well capitalized under the PCA framework. 

(4)  Total  capital  under  the  Advanced  approaches  differs  from  the  Standardized  approach  due  to  differences  in  the  amount  permitted  in  Tier  2  capital  related  to  the  qualifying  allowance  for  credit 

losses. 

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

loss-absorbing  capacity 

Total Loss-Absorbing Capacity Requirements 
Total 
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 

(TLAC)  consists  of 

risk-based capital  ratios and SLR,  the Corporation  is required 
to  maintain  TLAC  ratios  in  excess  of  minimum  requirements 
restrictions  on  capital 
to  avoid 
plus  applicable  buffers 
distributions  and  discretionary  bonus  payments.  Table  15 
presents  the  Corporation's  TLAC  and  long-term  debt  ratios  and 
related information as of December 31, 2020 and 2019.

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

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(Dollars in millions)
Total eligible balance
Percentage of risk-weighted assets (4) 
Percentage of supplementary leverage exposure (5, 6) 

Total eligible balance
Percentage of risk-weighted assets (4) 
Percentage of supplementary leverage exposure (6) 

TLAC (1) 

Regulatory 
Minimum (2) 

Long-term 
Debt 

Regulatory 
Minimum (3) 

$ 

405,153

$ 

196,997 

December 31, 2020 

27.4 %
14.5

22.0 %
9.5

13.3 %
7.1

8.5 % 
4.5 

$  367,449

$  171,349 

December 31, 2019 

24.6 %
12.5

22.0 %
9.5

11.5 %
5.8

8.5 % 
4.5 

(1)  As of December 31, 2020, TLAC ratios are calculated using the regulatory capital rule that allows a five-year transition period related to the adoption of CECL. 
(2)  The TLAC RWA regulatory minimum consists of 18.0 percent plus a TLAC RWA buffer comprised of 2.5 percent plus the Method 1 G-SIB surcharge of 1.5 percent. The countercyclical buffer is zero 
for both periods. The TLAC supplementary leverage exposure regulatory minimum consists of 7.5 percent plus a 2.0 percent TLAC leverage buffer. The TLAC RWA and leverage buffers must be 
comprised solely of CET1 capital and Tier 1 capital, respectively. 

(3)  The long-term debt RWA 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. 

(4)  The approach that yields the higher RWA is used to calculate TLAC and long-term debt ratios, which was the Standardized approach as of both December 31, 2020 and 2019. 
(5)  Supplementary leverage exposure at December 31, 2020 reflects the temporary exclusion of U.S. Treasury Securities and deposits at Federal Reserve Banks. 
(6)  Derivative exposure amounts are calculated using the standardized approach for measuring counterparty credit risk at December 31, 2020 and the current exposure method at December 31, 

2019. 

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  ECL  inherent  in  the  Corporation's  relevant 
financial assets. For more information, see Note 1 – Summary of 
Significant  Accounting  Principles  to  the  Consolidated  Financial 
Statements. During the first quarter of 2020, in accordance with 
an interim final rule issued by U.S. banking regulators that was 
finalized  on  August  26,  2020,  the  Corporation  delayed  for  two 
years  the  initial  adoption  impact  of  CECL  on  regulatory  capital, 
followed  by  a  three-year  transition  period  to  phase  out  the 
aggregate  amount  of  the  capital  benefit  provided  during  2020 
and 2021 (i.e., a five-year transition period). During the two-year 
delay, the Corporation will add back to CET1 capital 100 percent 
of  the  initial  adoption  impact  of  CECL  plus  25  percent  of  the 
cumulative quarterly changes in the allowance for credit losses 
(i.e., quarterly transitional amounts). After two years, starting on 
January  1,  2022,  the  quarterly  transitional  amounts  along  with 
the  initial  adoption impact of CECL will  be phased  out of CET1 
capital over the three-year period. 

Stress Capital Buffer 
On March 4, 2020, the Federal Reserve issued a final rule that 
integrates  the  annual  quantitative  assessment  of  the  CCAR 
program  with  the  buffer  requirements  in  the  U.S.  Basel  3  Final 
Rule. The new approach replaced the static 2.5 percent capital 
conservation  buffer 
for  Basel  3  Standardized  approach 
requirements with a SCB, calculated as the decline in the CET1 
capital  ratio  under  the  supervisory  severely  adverse  scenario 
plus four quarters of planned common stock dividends, floored 
at  2.5  percent.  Based  on  the  CCAR  2020  supervisory  stress 
test results, the Corporation is subject to a 2.5 percent SCB for 
the period beginning October 1, 2020 and ending on September 
30, 2021. 

In  conjunction  with  this  new  requirement,  the  Federal 
Reserve  has  removed  the  annual  CCAR  quantitative  objection 
process  beginning  with  CCAR  2020.  While  the  final  rule 
continues  to  require  that  the  Corporation  describe  its  planned 
capital distributions in its CCAR capital plan, the Corporation is 
no  longer  required  to  seek  prior  approval  if  it  makes  capital 
distributions  in  excess  of  those  included  in  its  CCAR  capital 

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plan.  The  Corporation 
to  automatic 
distribution  limitations  if  its  capital  ratios  fall  below  its  buffer 
requirements, which include the SCB. 

instead  subject 

is 

Eligible Retained Income 
On March 17, 2020, in response to the economic impact of the 
pandemic,  the  U.S.  banking  regulators  issued  an  interim  final 
rule that revises the definition of eligible retained income to be 
based on average net income over the prior four quarters. This 
change,  which  was  finalized  on  August  26,  2020,  more 
gradually  phases  in  automatic  distribution  restrictions  to  the 
extent capital buffers are breached. 

Supplementary Leverage Ratio 
On  April  1,  2020,  in  response  to  the  economic  impact  of  the 
pandemic,  the  Federal  Reserve  issued  an  interim  final  rule  to 
temporarily  exclude  the  on-balance  sheet  amounts  of  U.S. 
Treasury securities and deposits at Federal Reserve Banks from 
the  calculation  of  supplementary  leverage  exposure  for  bank 
holding  companies.  The  rule  is  effective  for  June  30,  2020 
through  March  31,  2021  reports.  As  of  December  31,  2020, 
temporary  exclusions  improved  the  SLR  by  1.0  percent  to  7.2 
percent. 

On  May  15,  2020,  the  U.S.  banking  regulators  issued  an 
interim final rule that provides a similar temporary exclusion to 
depository  institutions,  effective  from  the  beginning  of  the 
second  quarter  of  2020  through  March  31,  2021;  however, 
institutions  must  elect  the  relief.  Beginning  in  the  third  quarter 
of 2020, a depository institution electing to apply the exclusion 
must receive approval from its primary regulator prior to making 
any capital distributions as long as the exclusion is in effect. As 
of  December  31,  2020,  the  Corporation’s  insured  depository 
institution subsidiaries have not elected the exclusion. 

Paycheck Protection Program Loans 
On  April  9,  2020,  in  response  to  the  economic  impact  of  the 
pandemic,  the  U.S.  banking  regulators  issued  an  interim  final 
rule  that,  among  other  things,  stipulates  PPP  loans,  which  are 
guaranteed  by  the  SBA,  will  receive  a  zero  percent  risk  weight 
under the Basel 3 Advanced and Standardized approaches. The 
rule  was  later  finalized  by  the  U.S.  banking  regulators  on 
October  28,  2020.  For  more  information  on  the  PPP,  see 
Executive  Summary  –  Recent  Developments  –  COVID-19 
Pandemic  on  page  48  and  Note  1  –  Summary  of  Significant 
Accounting Principles to the Consolidated Financial Statements.

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the  Corporation  adopted 

Standardized  Approach  for Measuring  Counterparty Credit 
Risk 
On  June  30,  2020 
the  new 
standardized  approach  for  measuring  counterparty  credit  risk 
(SA-CCR),  which  replaces  the  current  exposure  method  for 
calculating the exposure amount of derivative contracts for risk-
weighted  assets  and  supplementary 
leverage  exposure. 
Adoption of SA-CCR resulted in a decrease of approximately $15 
billion in the Corporation’s Standardized RWA, and a $66 billion 
decrease in supplementary leverage exposure. 

Swap Dealer Capital Requirements 
On  July  22,  2020,  the  U.S.  Commodity  Futures  Trading 
Commission  (CFTC)  issued  a  final  rule  to  establish  capital 
requirements for swap dealers and major swap participants that 
are not subject to existing U.S. prudential regulation. Under the 
rule,  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  6.5  percent  of  the  entity’s  RWA  as 
calculated under Basel 3, Total capital greater than or equal to 
8.0 percent of the entity’s RWA as calculated under Basel 3 and 
Total capital greater than or equal to 8.0 percent of the entity’s 
uncleared  swap  margin.  The  second  approach  is  based  on  net 
liquid  assets  and  requires  that  a  firm  maintain  net  capital 
greater  than  or  equal  to  2.0  percent  of  its  uncleared  swap 
margin. The final rule also includes reporting requirements. The 
impact on the Corporation is not expected to be significant. 

Deduction of Unsecured Debt of G-SIBs 
On  October  20,  2020,  the  Federal  Reserve,  Federal  Deposit 
Insurance  Corporation  (FDIC)  and  the  Office  of  the  Comptroller 
of  the  Currency  (U.S.  Agencies)  finalized  a  rule  requiring 
Advanced  approaches  institutions  to  deduct  from  regulatory 
capital  certain  investments  in  TLAC-eligible  long-term  debt  and 
other pari passu or subordinated debt instruments issued by G-
SIBs  above  a  specified  threshold.  The  final  rule  is  intended  to 
limit 
is 
complementary  to  existing  regulatory  capital  requirements  that 
generally require banks to deduct investments in the regulatory 
capital of financial institutions. The final rule is effective April 1, 
2021.  The  impact  to  the  Corporation  is  not  expected  to  be 
significant. 

interconnectedness  between  G-SIBs  and 

the 

Volcker Rule 
Effective  January  1,  2020,  we  became  subject  to  certain 
changes to the Volcker Rule, including removing the requirement 
for  banking  organizations  to  deduct  from  Tier  1  capital 
ownership interests of covered funds acquired or retained under 
the  underwriting  or  market-making  exemptions  of  the  Volcker 
Rule, which the banking entity did not organize or offer. 

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 

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and  nonbank  financial  institutions  regulated  by  the  Federal 
Reserve  do  not  breach  15  percent  of  Tier  1  capital  and 
exposures  to  most  other  counterparties  do  not  breach  25 
percent of Tier 1 capital. Certain exposures, including exposures 
to  the  U.S.  government,  U.S.  government-sponsored  entities 
and qualifying central counterparties, are exempt from the credit 
limits. 

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).  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  15c3-1e,  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  CFTC  Regulation 
1.17.  The  U.S.  broker-dealer  subsidiaries  are  also  registered 
with  the  Financial  Industry  Regulatory  Authority,  Inc.  (FINRA). 
Pursuant  to  FINRA  Rule  4110,  FINRA  may  impose  higher  net 
capital  requirements  than  Rule  15c3-1  under  the  Exchange  Act 
with respect to each of the broker-dealers. 

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  customers'  and  affiliates'  risk-based 
margin  in  order  to  meet  its  CFTC  minimum  net  capital 
requirement.  At  December  31,  2020,  BofAS  had  tentative  net 
capital of $16.8 billion. BofAS also had regulatory net capital of 
$14.1 billion, which exceeded the minimum requirement of $2.9 
billion. 

MLPCC  is  a  fully-guaranteed  subsidiary  of  BofAS  and 
provides  clearing  and  settlement  services  as  well  as  prime 
brokerage  and  arranged  financing  services  for  institutional 
clients. At December 31, 2020, MLPCC’s regulatory net capital 
of  $8.6  billion  exceeded  the  minimum  requirement  of  $1.4 
billion. 

MLPF&S  provides  retail  services.  At  December  31,  2020, 
MLPF&S' regulatory net capital was $3.6 billion, which exceeded 
the minimum requirement of $180 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, 2020, 
MLI’s capital resources were $34.1 billion, which exceeded the 
minimum Pillar 1 requirement of $14.7 billion. BofASE, a French 
investment  firm,  is  regulated  by  the  Autorité  de  Contrôle 
Prudentiel  et  de  Résolution  and  the  Autorité  des  Marchés 
Financiers,  and 
regulatory  capital 
requirements.  At  December  31,  2020,  BofASE's  capital 
resources were $6.2 billion, which exceeded the minimum Pillar 
1 requirement of $1.9 billion.

is  subject 

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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.  These  liquidity  risk 
management  practices  have  allowed  us  to  effectively  manage 
the  market  stress  from  the  pandemic  that  began  in  the  first 
quarter  of  2020.  For  more  information  on  the  effects  of  the 
pandemic, see Item 1A. Risk Factors of our 2020 Annual Report 
on Form 10-K and Executive Summary – Recent Developments – 
COVID-19 Pandemic on page 48. 

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  to 
monitor  liquidity  requirements,  maximizes  access  to  funding 
sources,  minimizes  borrowing  costs  and  facilitates  timely 
responses to liquidity events. 

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  70.  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 
funding  sources, 
stressed  market  conditions;  diversifying 
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  bank  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 
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. 

in  stressed  conditions, 

Table 16 presents average GLS for the three months ended 

December 31, 2020 and 2019. 

Table 16  Average Global Liquidity Sources 

(Dollars in billions)
Bank entities 
Nonbank and other entities (1 )

Total Average Global Liquidity Sources 

Three Months Ended 
December 31 

2020

2019 

$

$

 773
170
 943

$

$

454 
122 
576 

(1 ) Nonbank includes Parent, NB Holdings and other regulated entities. 

Our bank subsidiaries’ liquidity is primarily driven by deposit 
and lending activity, as well as securities valuation and net debt 
activity.  Bank  subsidiaries  can  also  generate  incremental 
liquidity  by  pledging  a  range  of  unencumbered  loans  and 
securities  to  certain  FHLBs  and  the  Federal  Reserve  Discount 
Window. The cash we could have obtained by borrowing against 
this  pool  of  specifically-identified  eligible  assets  was  $306 
billion  and  $372  billion  at  December  31,  2020  and  2019.  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.

80 Bank of America 2020
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Liquidity  is  also  held  in  nonbank  entities,  including  the 
Parent,  NB  Holdings  and  other  regulated  entities.  Parent 
company  and  NB  Holdings  liquidity  is  typically  in  the  form  of 
cash  deposited  at  BANA  and  is  excluded  from  the  liquidity  at 
bank  subsidiaries.  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, 2020 and 2019. 

Table 17  Average Global Liquidity Sources Composition 

(Dollars in billions)
Cash on deposit 
U.S. Treasury securities
U.S. agency securities, mortgage-backed 
securities, and other investment-grade 
securities

Non-U.S. government securities

$

Total Average Global Liquidity Sources

$

Three Months Ended 
December 31 

2020

2019 

322 $
141

462
18
943  $

 103
98 

358 
17 
 576

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  $584  billion 
and  $464  billion  for  the  three  months  ended  December  31, 
2020  and  2019.  For 
the  average 
consolidated  LCR  was  122  percent  and  116  percent.  Our  LCR 
fluctuates due to normal business flows from customer activity. 

the  same  periods, 

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  issuances;  diminished  access  to 
secured  financing  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 Final Rule 
On  October  20,  2020,  the  U.S.  Agencies  finalized  the  Net 
Stable  Funding  Ratio  (NSFR),  a  rule  requiring  large  banks  to 
maintain  a  minimum  level  of  stable  funding  over  a  one-year 
period. The final rule is intended to support the ability of banks 
to  lend  to  households  and  businesses  in  both  normal  and 
adverse economic conditions and is complementary to the LCR 
rule, which focuses on short-term liquidity risks. The final rule is 
effective  July  1,  2021.  The  U.S.  NSFR  would  apply  to  the 
Corporation  on  a  consolidated  basis  and  to  our  insured 
depository  institutions.  The  Corporation  expects  to  be  in 
compliance within the final NSFR rule in the regulatory timeline 
provided  and  does  not  expect  any  significant  impacts  to  the 
Corporation. 

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

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 
requirements  of  subsidiaries.  Where 
variable 
regulations, 
zone  differences  or  other  business 
considerations  make  parent  company  funding  impractical, 
certain other subsidiaries may issue their own debt. 

funding 
time 

We  fund  a  substantial  portion  of  our  lending  activities 
through  our  deposits,  which  were  $1.80  trillion  and  $1.43 
trillion at December 31, 2020 and 2019. 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

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reductions in the availability of such financing. We manage the 
liquidity  risks  arising  from  secured  funding  by  sourcing  funding 
globally  from  a  diverse  group  of  counterparties,  providing  a 
range  of  securities  collateral  and  pursuing  longer  durations, 
when  appropriate.  For  more  information  on  secured  financing 
agreements,  see  Note  10  –  Federal  Funds  Sold  or  Purchased, 
Securities  Financing  Agreements,  Short-term  Borrowings  and 
Restricted Cash to the Consolidated Financial Statements. 

Total  long-term  debt  increased  $22.1  billion  to  $262.9 
billion  during  2020,  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  2020,  we  issued  $56.9  billion  of  long-term  debt 
consisting of $43.8 billion of notes issued by Bank of America 
Corporation, substantially all of which was TLAC compliant, $4.8 
billion of notes issued by Bank of America, N.A. and $8.3 billion 
of other debt. During 2019, we 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. 

During  2020,  we  had  total  long-term  debt  maturities  and 
redemptions  in  the  aggregate  of  $47.1  billion  consisting  of 
$22.6 billion for Bank of America Corporation, $11.5 billion for 
Bank  of  America,  N.A.  and  $13.0  billion  of  other  debt.  During 
2019,  we  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. 

At  December  31,  2020,  Bank  of  America  Corporation's 
senior  notes  of  $191.2  billion  included  $146.6  billion  of 
outstanding  notes  that  are  both  TLAC  eligible  and  callable  at 
least  one  year  before  their  stated  maturities.  Of  these  senior 
notes, $12.0 billion will be callable and become TLAC ineligible 
during 2021, and $15.3 billion, $14.6 billion, $11.7 billion and 
$13.2  billion  will  do  so  during  each  of  2022  through  2025, 
respectively, and $79.8 billion thereafter. 

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. We may issue unsecured debt in the form of structured 
notes  for  client  purposes,  certain  of  which  qualify  as  TLAC-
eligible debt. During 2020, we issued $7.3 billion of structured 
notes, which are unsecured 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. 

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that  could 

Substantially  all  of  our  senior  and  subordinated  debt 
obligations  contain  no  provisions 
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 
11 – Long-term Debt to the Consolidated Financial Statements. 

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 105. 

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 
ratings,  and 
management maintains an active dialogue with the major rating 
agencies. 

to  maintain  high-quality  credit 

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

for 

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 
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. 
legislative
future 
government;  current  or 

regulatory  and 

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initiatives;  and  the  agencies’  views  on  whether  the  U.S. 
government  would  provide  meaningful  support 
the 
Corporation or its subsidiaries in a crisis. 

to 

On April 22, 2020, Fitch Ratings (Fitch) completed its review 
of  large,  complex  securities  trading  and  universal  banks  in  the 
U.S.,  including  Bank  of  America,  in  response  to  declining 
economic  activity  from  the  pandemic.  The  agency  affirmed  its 
long-term and short-term senior debt ratings for the Corporation 
and  all  of  its  rated  subsidiaries,  except  for  select  issuer  and 
instrument-level  ratings  that  had  previously  been  placed  under 
criteria observation on March 4, 2020, following changes in the 
agency’s bank rating criteria on February 28, 2020. 

Concurrently,  Fitch  reached  a  conclusion  on  select  under-
criteria-observation  designations 
the  Corporation  and 
upgraded its long-term and short-term senior debt ratings of MLI 
and BofASE by one notch to AA-/F1+. The agency also upgraded 
its  preferred  stock  rating  for  the  Corporation  by  one  notch  to 
BBB  and  downgraded  its  subordinated  debt  rating  for  the 
Corporation  by  one  notch  to  A-.  According  to  Fitch,  rating 

for 

Table 18  Senior Debt Ratings 

changes  under  criteria  observation  are  the  sole  result  of  bank 
rating  criteria  changes  and  do  not  reflect  a  change  in  the 
underlying fundamentals of the institution. Fitch’s outlook for all 
of our long-term ratings is currently Stable. 
On  June  9,  2020,  Fitch  affirmed 

for  the 
subordinated debt of BANA at A. This rating had remained under 
criteria observation following Fitch’s broader rating actions. 

its  rating 

On  November  18,  2020,  Moody’s 

Investors  Service 
(Moody's) affirmed its long-term and short-term debt ratings for 
the  Corporation  and  all  of  its  rated  subsidiaries,  which  did  not 
change  during  2020.  Moody’s  outlook  for  all  of  our  long-term 
ratings is currently Stable. 

The  current  ratings  and  Stable  outlooks  for  the  Corporation 
and its subsidiaries from Standard & Poor’s Global Ratings also 
did not change during 2020. 

Table 18 presents the Corporation’s current long-term/short-
term  senior  debt  ratings  and  outlooks  expressed  by  the  rating 
agencies. 

Bank of America Corporation
Bank of America, N.A.
Bank of America Europe 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

Outlook
Stable
Stable

Long-term 
A-
A+

NR

NR
NR
NR
NR

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 

A+
AA-

AA-

AA-
AA-
AA-
AA-

Fitch Ratings 
Short-term
F1
F1+

Outlook 
Stable 
Stable 

F1+

F1+
F1+
F1+
F1+

Stable 

Stable 
Stable 
Stable 
Stable 

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  in  those  businesses  where 
counterparty  creditworthiness  is  critical.  In  addition,  under  the 
terms  of  certain  OTC  derivative  contracts  and  other  trading 
agreements,  in  the  event  of  downgrades  of  our  or  our  rated 
subsidiaries’  credit 
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. 

the  counterparties 

ratings, 

to 

to  a 

institution 

While  certain  potential 

impacts  are  contractual  and 
quantifiable,  the  full  scope  of  the  consequences  of  a  credit 
inherently 
financial 
rating  downgrade 
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 81. 

is 

For more information on additional collateral and termination 
payments that could be required in connection with certain over-
the-counter derivative contracts and other trading agreements in 
the event of a credit rating downgrade, see Note 3 – Derivatives 
to  the  Consolidated  Financial  Statements  and  Item  1A.  Risk 
Factors of our 2020 Annual Report on Form 10-K.

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Common Stock Dividends 
For  a  summary  of  our  declared  quarterly  cash  dividends  on 
common  stock  during  2020  and  through  February  24,  2021, 
see  Note  13  –  Shareholders’  Equity  to  the  Consolidated 
Financial Statements. 

Finance Subsidiary Issuers and Parent Guarantor 
BofA  Finance  LLC,  a  Delaware  limited  liability  company  (BofA 
Finance), is a consolidated finance subsidiary of the Corporation 
that has issued and sold, and is expected to continue to issue 
and  sell,  its  senior  unsecured  debt  securities  (Guaranteed 
Notes),  that  are  fully  and  unconditionally  guaranteed  by  the 
Corporation.  The  Corporation  guarantees  the  due  and  punctual 
payment,  on  demand,  of  amounts  payable  on  the  Guaranteed 
Notes  if  not  paid  by  BofA  Finance.  In  addition,  each  of  BAC 
Capital Trust XIII and BAC Capital Trust XIV, Delaware statutory 
trusts (collectively, the Trusts), is a 100 percent owned finance 
subsidiary  of  the  Corporation  that  has  issued  and  sold  trust 
preferred securities (the Trust Preferred Securities and, together 
with  the  Guaranteed  Notes,  the  Guaranteed  Securities)  that 
remained  outstanding  at  December  31,  2020.  The  Corporation 
guarantees  the  payment  of  amounts  and  distributions  with 
respect  to  the  Trust  Preferred  Securities  if  not  paid  by  the 
Trusts,  to  the  extent  of  funds  held  by  the  Trusts,  and  this 
guarantee, together with the Corporation’s other obligations with 
respect to the Trust Preferred Securities, effectively constitutes 
a  full  and  unconditional  guarantee  of  the  Trusts’  payment 
obligations  on 
the  Trust  Preferred  Securities.  No  other 
subsidiary  of  the  Corporation  guarantees  the  Guaranteed 
Securities. 

the  Trusts  are 

independent  assets, 

BofA  Finance  and  each  of 

finance 
revenues  or 
subsidiaries,  have  no 
operations and are dependent upon the Corporation and/or the 
Corporation’s  other  subsidiaries  to  meet  their  respective 
obligations  under  the  Guaranteed  Securities  in  the  ordinary 
course. If holders of the Guaranteed Securities make claims on 
their  Guaranteed  Securities  in  a  bankruptcy,  resolution  or 
similar  proceeding,  any  recoveries  on  those  claims  will  be 
limited to those available under the applicable guarantee by the 
Corporation, as described above. 

The Corporation is a holding company and depends upon its 
subsidiaries  for  liquidity.  Applicable  laws  and  regulations  and 
intercompany arrangements entered into in connection with the 
Corporation’s  resolution  plan  could  restrict  the  availability  of 
funds  from  subsidiaries  to  the  Corporation,  which  could 
adversely  affect  the  Corporation’s  ability  to  make  payments 
under  its  guarantees.  In  addition,  the  obligations  of  the 
Corporation under the guarantees of the Guaranteed Securities 
will  be  structurally  subordinated  to  all  existing  and  future 
liabilities of its subsidiaries, and claimants should look only to 
assets  of  the  Corporation  for  payments.  If  the  Corporation,  as 
guarantor of the Guaranteed Notes, transfers all or substantially 
all of its assets to one or more direct or indirect majority-owned 
subsidiaries,  under  the  indenture  governing  the  Guaranteed 
Notes,  the  subsidiary  or  subsidiaries  will  not  be  required  to 
assume the Corporation’s obligations under its guarantee of the 
Guaranteed Notes. 

For more information on factors that may affect payments to 
holders  of  the  Guaranteed  Securities,  see  Liquidity  Risk  –  NB 
Holdings  Corporation  in  this  section,  see  Item  1.  Business  of 
our  2020  Annual  Report  on  Form  10-K  and  Item  1A.  Risk 
Factors of our 2020 Annual Report on Form 10-K. 

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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 
in  earnings.  For  derivative 
positions,  our  credit  risk  is  measured  as  the  net  cost  in  the 
event the counterparties with contracts in which we are in a gain 
position fail to perform under the terms of those contracts. We 
use  the  current  fair  value  to  represent  credit  exposure  without 
giving  consideration  to  future  mark-to-market  changes.  The 
credit risk amounts take into consideration the effects of legally 
enforceable master netting agreements and cash collateral. Our 
consumer  and  commercial  credit  extension  and 
review 
procedures encompass funded and unfunded credit exposures. 
For  more  information  on  derivatives  and  credit  extension 
commitments,  see  Note  3  –  Derivatives  and  Note  12  – 
Commitments  and  Contingencies  to  the  Consolidated  Financial 
Statements. 

recorded 

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 
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. 

the  commercial  businesses 

losses 

in 

For information on our credit risk management activities, see 
Consumer Portfolio Credit Risk Management below, Commercial 
Portfolio  Credit  Risk  Management  on  page  91,  Non-U.S. 
Portfolio on page  97, Allowance for Credit Losses on page  99, 
and  Note  5  –  Outstanding  Loans  and  Leases  and  Allowance  for 
Credit Losses to the Consolidated Financial Statements. 

During  2020,  the  pandemic  negatively  impacted  economic 
activity in the U.S. and around the world. In particular, beginning 
in  the  latter  portion  of  the  first  quarter  of  2020,  the  pandemic 
resulted  in  changes  to  consumer  and  business  behaviors  and 
restrictions on economic activity. These restrictions gave rise to 
increased unemployment and underemployment, lower business 
profits, 
increased  business  closures  and  bankruptcies, 
fluctuations  and  disruptions  to  commercial  and  consumer 
spending  and  markets,  and  lower  global  GDP,  all  of  which 
negatively  impacted  our  consumer  and  commercial  credit 
portfolio.

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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, 
line 
management,  collection  practices  and  strategies,  and 
determination  of  the  allowance  for  loan  and  lease  losses  and 
allocated capital for credit risk. 

including  authorizations  and 

Consumer Credit Portfolio 
While  COVID-19  is  severely  impacting  economic  activity,  and  is 
contributing  to  increasing  nonperforming  loans  within  certain 
consumer  portfolios,  it  did  not  have  a  significant  impact  on 
consumer  portfolio  charge-offs  during  2020  due  to  payment 
deferrals and government stimulus benefits. However, COVID-19 
could lead to adverse impacts to credit quality metrics in future 
periods  if  negative  economic  conditions  continue  or  worsen. 
During  2020,  net  charge-offs  decreased  $334  million  to  $2.7 
billion primarily due to lower credit card losses. 
loan  and 

losses 
increased  $5.5  billion  in  2020  to  $10.1  billion  due  to  the 
adoption of the new CECL accounting standard and deterioration 
in the economic outlook resulting from the impact of COVID-19. 
For more information, see Allowance for Credit Losses on page 
99. 

The  consumer  allowance 

lease 

for 

For  more  information  on  our  accounting  policies  regarding 
delinquencies,  nonperforming  status,  charge-offs,  TDRs  for  the 
consumer  portfolio,  as  well  as  interest  accrual  policies  and 
delinquency  status  for  loan  modifications  related  to  the 
pandemic,  see  Note  1  –  Summary  of  Significant  Accounting 
Principles  and  Note  5  –  Outstanding  Loans  and  Leases  and 
Allowance  for  Credit  Losses  to  the  Consolidated  Financial 
Statements. 

Table  19  presents  our  outstanding  consumer  loans  and 
leases,  consumer  nonperforming  loans  and  accruing  consumer 
loans past due 90 days or more.

To  provide  relief  to  individuals  and  businesses  in  the  U.S., 
economic  stimulus  packages  were  enacted  throughout  2020, 
including  the  CARES  Act,  an  executive  order  signed  in  August 
2020 to establish the Lost Wage Assistance Program, and most 
recently,  the  Consolidated  Appropriations  Act  enacted 
in 
December  2020.  In  addition,  U.S.  bank  regulatory  agencies 
issued  interagency  guidance  to  financial  institutions  that  have 
worked  with  and  continue  to  work  with  borrowers  affected  by 
COVID-19. 

including  offering 

To  support  our  customers,  we  implemented  various  loan 
modification  programs  and  other  forms  of  support  beginning  in 
March  2020, 
loan  payment  deferrals, 
refunding certain fees, and pausing foreclosure sales, evictions 
and  repossessions.  Since  June  2020,  we  have  experienced  a 
decline  in  the  need  for  customer  assistance  as  the  number  of 
customer  accounts  and  balances  on  deferral  decreased 
significantly.  For  information  on  the  accounting  for  loan 
modifications related to the pandemic, see Note 1 – Summary of 
Significant  Accounting  Principles  to  the  Consolidated  Financial 
Statements. 

Furthermore,  as  COVID-19  cases  eased  and 

initial 
restrictions  lifted,  the  global  economy  began  to  improve.  This 
improvement, coupled with the aforementioned relief, facilitated 
economic  recovery,  with  unemployment  dropping  from  double-
digit highs in the second quarter of 2020 and GDP significantly 
rebounding in the third quarter of 2020. 

increases 

However,  economic  recovery  remains  uneven,  with  certain 
sectors  of  the  economy  more  significantly  impacted  from  the 
pandemic (e.g., travel and entertainment). As a result, we have 
experienced 
in  commercial  reservable  criticized 
utilized exposures driven by industries most heavily impacted by 
COVID-19.  Also,  we  have  seen  modest 
in 
nonperforming loans driven by commercial loans and consumer 
real  estate  customer  deferral  activities,  though  consumer 
charge-offs remained low during 2020 due to payment deferrals 
and government stimulus benefits. 

increases 

The  pandemic  and  its  full  impact  on  the  global  economy 
continue  to  be  highly  uncertain.  While  COVID-19  cases  have 
begun  to  ease  from  their  January  2021  peak,  the  spread  of 
new, more contagious variants could impact the magnitude and 
duration  of 
this  health  crisis.  However,  ongoing  virus 
containment  efforts  and  vaccination  progress,  as  well  as  the 
possibility of further government stimulus, could accelerate the 
macroeconomic  recovery.  For  more  information  on  how  the 
pandemic may affect our operations, see Executive Summary – 
Recent  Developments  –  COVID-19  Pandemic  on  page  48  and 
Item 1A. Risk Factors of our 2020 Annual Report on Form 10-K. 

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Table 19  Consumer Credit Quality 

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

Outstandings

Nonperforming 
December 31 

Accruing Past Due 
90 Days or More 

2020

$

223,555  $

2019
236,169  $

34,311
78,708
91,363
124

40,208
97,608
90,998
192

2020

2,005
649

$

n/a

71
—

2019

2020

2019 

$

1,470 
536
n/a
47
—

762
—
903
33
—

 $

1,088 
— 
1,042 
33 
— 

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 )

$

$

428,061  $
735
428,796  $
n/a

465,175  $
594 
465,769 
n/a

2,725

$

2,053

$

1,698

$

2,163 

0.64 %

0.44 %

0.40 %

0.47 % 

n/a

n/a

0.65

0.46

0.22

0.24 

(1 ) Residential mortgage loans accruing past due 90 days or more are fully-insured loans. At December 31, 2020 and 2019, residential mortgage includes $537 million and $740 million of loans on 
which interest had been curtailed by the FHA, and therefore were no longer accruing interest, although principal was still insured, and $225 million and $348 million of loans on which interest was 
still accruing. 

(2 ) Outstandings primarily include auto and specialty lending loans and leases of $46.4 billion and $50.4 billion, U.S. securities-based lending loans of $41.1 billion and $36.7 billion and non-U.S. 

consumer loans of $3.0 billion and $2.8 billion at December 31, 2020 and 2019. 

(3 ) Consumer  loans  accounted  for  under  the  fair  value  option  include  residential  mortgage  loans  of  $298  million  and  $257  million  and  home  equity  loans  of  $437  million  and  $337  million  at 

December 31, 2020 and 2019. For more information on the fair value option, see Note 21 – Fair Value Option to the Consolidated Financial Statements. 

(4 ) Excludes consumer loans accounted for under the fair value option. At December 31, 2020 and 2019, $11 million and $6 million of loans accounted for under the fair value option were past due 

90 days or more and not accruing interest. 

n/a = not applicable 

Table 20 presents net charge-offs and related ratios for consumer loans and leases. 

Table 20  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
2020

2019

Net Charge-off Ratios (1 )
2019 

2020

$

$

(30)
(73)
2,349
122
284

$ 

2,652  $ 

(47)
(358)
2,948
209
234
2,986

(0.01)%
(0.19)
2.76
0.14

n/m

0.59

(0.02)% 
(0.81) 
3.12 
0.23 
n/m 
0.66 

(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  21  presents  outstandings,  nonperforming  balances, 
net  charge-offs,  allowance  for  credit  losses  and  provision  for 
credit  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  21  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  21,  outstanding  core  consumer  real 
estate  loans  decreased  $15.4  billion  during  2020  driven  by  a 
decrease  of  $10.5  billion  in  residential  mortgage  and  a  $4.9 
billion decrease in home equity.

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Table 21  Consumer Real Estate Portfolio (1 )

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(Dollars in millions)
Core portfolio 

Residential mortgage
Home equity

Total core portfolio

Non-core portfolio 

Residential mortgage
Home equity

Total non-core portfolio
Consumer real estate portfolio 

Residential mortgage
Home equity
Total consumer real estate portfolio

Core portfolio 

Residential mortgage
Home equity

Total core portfolio

Non-core portfolio 

Residential mortgage
Home equity (2 )
Total non-core portfolio
Consumer real estate portfolio 

Residential mortgage
Home equity (3 )
Total consumer real estate portfolio

Outstandings

Nonperforming 

2020

2019

2020

2019

2020

2019 

December 31 

Net Charge-offs

$

215,273  $ 

225,770  $

1,390  $

30,328
245,601

8,282
3,983
12,265

223,555
34,311

35,226
260,996

10,399
4,982
15,381

236,169
40,208

462
1,852

615
187
802

2,005
649

$

257,866  $ 

276,377  $

2,654  $

883  $
363
1,246

587
173
760

1,470
536
2,006  $

(25) $

(6)
(31)

(5)
(67)
(72)

(30)
(73)

(103)  $

7
51 
58 

(54) 
(409) 
(463) 

(47) 
(358) 
(405) 

Allowance for Loan 
and Lease Losses
December 31 

Provision for Loan 
and Lease Losses

2020

2019

2020

2019 

$

$

$

374
599
973

85
(63)
22

459
536
995  $

229  $
120
349

96
101
197

325
221
546  $

136
135
271

75
(21)
54

211
114
325

$

$

 22
(58) 
(36) 

(134) 
(510) 
(644) 

(112) 
(568) 
(680) 

(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 
$298  million  and  $257  million  and  home  equity  loans  of  $437  million  and  $337  million  at  December  31,  2020  and  2019.  For  more  information,  see  Note  21  –  Fair  Value  Option  to  the 
Consolidated Financial Statements. 

(2 ) The home equity non-core allowance is in a negative position at December 31, 2020 as it includes expected recoveries of amounts previously charged off. 
(3 ) Home equity allowance includes a reserve for unfunded lending commitments of $137 million at December 31, 2020. 

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  52  percent  of 
consumer 
leases  at  December  31,  2020. 
Approximately  52  percent  of  the  residential  mortgage  portfolio 
was  in  Consumer  Banking  and  40  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 

loans  and 

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 
decreased  $12.6  billion  in  2020  as  both  loan  sales  and 
paydowns were partially offset by originations. 

At December 31, 2020 and 2019, the residential mortgage 
portfolio included $11.8 billion and $18.7 billion of outstanding 
fully-insured  loans,  of  which  $2.8  billion  and  $11.2  billion  had 
FHA  insurance,  with  the  remainder  protected  by  Fannie  Mae 
long-term standby agreements. The decline was primarily driven 
by sales of loans with FHA insurance during 2020. 

Table  22  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.

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Table 22  Residential Mortgage – Key Credit Statistics 

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(Dollars in millions)
Outstandings
Accruing past due 30 days or more
Accruing past due 90 days or more
Nonperforming loans (2 )
Percent of portfolio 

Reported Basis (1 )

Excluding Fully-insured Loans (1 )

December 31 

2020

2019

2020

2019 

$

$

223,555
2,314
762
2,005

$

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

$

211,737
1,224
—
2,005

217,479 
1,296 
— 
1,470 

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 (3 )

2%
1
2

3

2 %
1
3

4

1%
1
1

3

2 % 
1 
2 

4 

(1 ) Outstandings, accruing past due, nonperforming loans and percentages of portfolio exclude loans accounted for under the fair value option. For information on our interest accrual policies and 

(2 )

delinquency status for loan modifications related to the pandemic, see Note 1 – Summary of Significant Accounting Principles to the Consolidated Financial Statements. 
Includes loans that are contractually current which primarily consist of collateral-dependent TDRs, including those that have been discharged in Chapter 7 bankruptcy and loans that have not yet 
demonstrated a sustained period of payment performance following a TDR. 

(3 ) These vintages of loans accounted for $503 million and $365 million, or 25 percent, of nonperforming residential mortgage loans at both December 31, 2020 and 2019. 

Nonperforming  outstanding  balances  in  the  residential 
mortgage  portfolio  increased  $535  million  in  2020  primarily 
driven by COVID-19 deferral activity, as well as the inclusion of 
certain  loans  that,  upon  adoption  of  the  new  credit  loss 
standard,  became  accounted  for  on  an  individual  basis,  which 
previously  had  been  accounted  for  under  a  pool  basis.  Of  the 
nonperforming  residential  mortgage  loans  at  December  31, 
2020, $892 million, or 45 percent, were current on contractual 
payments. Loans accruing past due 30 days or more decreased 
$72 million. 

Net  charge-offs  increased  $17  million  to  a  net  recovery  of 
$30 million in 2020 compared to a net recovery of $47 million 
in  2019.  This  increase  is  due  largely  to  lower  recoveries  from 
the sales of previously charged-off loans. 

Of  the  $211.7  billion  in  total  residential  mortgage  loans 
outstanding at December 31, 2020, as shown in Table 22, 27 
percent were originated as interest-only loans. The outstanding 
balance  of  interest-only  residential  mortgage  loans  that  have 
entered the amortization period was $5.9 billion, or 10 percent, 
at  December  31,  2020.  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, 2020, $113 million, or two percent of 
outstanding interest-only residential mortgages that had entered 

Table 23  Residential Mortgage State Concentrations 

residential  mortgage  portfolio. 

the amortization period were accruing past due 30 days or more 
compared  to  $1.2  billion,  or  less  than  one  percent,  for  the 
In  addition,  at 
entire 
December  31,  2020,  $356  million,  or  six  percent,  of 
outstanding  interest-only  residential  mortgage  loans  that  had 
entered  the  amortization  period  were  nonperforming,  of  which 
$96 million were contractually current, compared to $2.0 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  98 
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  23  presents  outstandings,  nonperforming  loans  and 
net  charge-offs  by  certain  state  concentrations 
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, 
2020  and  2019.  In  the  New  York  area,  the  New  York-Northern 
New  Jersey-Long  Island  MSA  made  up  14  percent  and  13 
percent of outstandings at December 31, 2020 and 2019. 

for 

(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 )

2020

2019

2020

2019

2020

2019 

December 31 

Net Charge-offs

$

$

$

83,185  $
23,832
13,017
8,868
8,806
74,029

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

211,737  $ 

11,818

223,555  $ 

217,479  $
18,690 
236,169 

$

 570
272
175
78
98
812

2,005  $

274  $
196
143
65
77
715
1,470  $

(18)
3
(5)
—
(1)
(9)
(30)

$

$

(22) 
5 
(12) 
1 
(4) 
(15) 
(47) 

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

Home Equity 
At December 31, 2020, the home equity portfolio made up eight 
percent  of  the  consumer  portfolio  and  was  comprised  of  home 
equity  lines  of  credit  (HELOCs),  home  equity  loans  and  reverse 
mortgages.  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.  We  no  longer 
originate home equity loans or reverse mortgages. 

At  December  31,  2020,  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

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$5.9  billion  in  2020  primarily  due  to  paydowns  outpacing  new 
originations  and  draws  on  existing  lines.  Of  the  total  home 
equity portfolio at December 31, 2020 and 2019, $13.8 billion, 
or 40 percent, and $15.0 billion, or 37 percent, were in first-lien 
positions. At December 31, 2020, 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 

$5.9 billion, or 17 percent, of our total home equity portfolio. 

Unused  HELOCs  totaled  $42.3  billion  and  $43.6  billion  at 
December 31, 2020 and 2019. The HELOC utilization rate was 
43 percent and 46 percent at December 31, 2020 and 2019. 

Table  24  presents  certain  home  equity  portfolio  key  credit 

statistics. 

Table 24  Home Equity – Key Credit Statistics (1 )

(Dollars in millions)
Outstandings
Accruing past due 30 days or more (2 )
Nonperforming loans (2 , 3 )
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 (4 )

December 31 

$

2020
34,311
186
649

 $ 

2019 
40,208 
218 
536 

1%
1
3
16

1 % 
2 
3 
18 

(1 ) Outstandings, accruing past due, nonperforming loans and percentages of the portfolio exclude loans accounted for under the fair value option. For information on our interest accrual policies and 

delinquency status for loan modifications related to the pandemic, see Note 1 – Summary of Significant Accounting Principles to the Consolidated Financial Statements. 

(2 ) Accruing  past  due  30  days  or  more  include  $25  million  and  $30  million  and  nonperforming  loans  include  $88  million  and  $57  million  of  loans  where  we  serviced  the  underlying  first  lien  at 

(3 )

December 31, 2020 and 2019. 
Includes loans that are contractually current which 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. 

(4 ) These vintages of loans accounted for 36 percent and 34 percent of nonperforming home equity loans at December 31, 2020 and 2019. 

Nonperforming  outstanding  balances  in  the  home  equity 
portfolio increased $113 million during 2020 primarily driven by 
COVID-19  deferral  activity.  Of  the  nonperforming  home  equity 
loans at December 31, 2020, $259 million, or 40 percent, were 
current  on  contractual  payments.  In  addition,  $237  million,  or 
36 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 $32 million in 2020. 
Net  charge-offs  increased  $285  million  to  a  net  recovery  of 
$73 million in 2020 compared to a net recovery of $358 million 
in  2019  as  the  prior-year  period  included  recoveries  from  non-
core home equity loan sales. 

in 

Of 

the  $34.3  billion 

total  home  equity  portfolio 
outstandings at December 31, 2020, as shown in Table 24, 15 
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  $9.2  billion  at 
December  31,  2020.  The  HELOCs  that  have  entered  the 
amortization  period  have  experienced  a  higher  percentage  of 
early  stage  delinquencies  and  nonperforming  status  when 
compared to the HELOC portfolio as a whole. At December 31, 
2020, $121 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, 2020, $477 million, 
or  five  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  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 2020, nine 
percent of these customers with an outstanding balance did not 
pay any principal on their HELOCs. 

Table 25 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,  2020 
and  2019.  The  Los  Angeles-Long  Beach-Santa  Ana  MSA  within 
California  made  up  11  percent  of  the  outstanding  home  equity 
portfolio at both December 31, 2020 and 2019. 

Table 25  Home Equity State Concentrations 

(Dollars in millions)
California
Florida
New Jersey
New York
Massachusetts
Other

Total home equity loan portfolio

Outstandings (1 )

Nonperforming (1 )

2020

2019

2020

2019

2020

2019 

December 31 

Net Charge-offs

$

$

9,488  $
3,715
2,749
2,495
1,719
14,145
34,311  $

11,232  $

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

143
80
67
103
32
224
649

$

$

101  $

71
56
85
29
194
536  $

(26)
(11)
(3)
(1)
(1)
(31)
(73)

$

$

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

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Credit Card 
At  December  31,  2020,  97  percent  of  the  credit  card  portfolio 
was managed in Consumer Banking with the remainder in GWIM. 
Outstandings in the credit card portfolio decreased $18.9 billion 
in 2020 to $78.7 billion due to lower retail spending and higher 
payments.  Net  charge-offs  decreased  $599  million  to  $2.3 
billion  during  2020  compared  to  net  charge-offs  of  $2.9  billion 
in  2019  due  to  government  stimulus  benefits  and  payment 
deferrals  associated  with  COVID-19.  Credit  card  loans  30  days 

or  more  past  due  and  still  accruing  interest  decreased  $346 
million,  and  loans  90  days  or  more  past  due  and  still  accruing 
interest  decreased  $139  million  primarily  due  to  government 
stimulus benefits and declines in loan balances. 

Unused  lines  of  credit  for  credit  card  increased  to  $342.4 

billion at December 31, 2020 from $336.9 billion in 2019. 

Table 26 presents certain state concentrations for the credit 

card portfolio. 

Table 26  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 (1 )

2020

2019

2020

2019

2020

December 31 

Net Charge-offs

$

$

12,543  $

7,666
6,499
4,654
3,685
43,661
78,708  $

16,135  $

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

166
135
87
76
21
418
903

$

$

178  $
135
93
80
26
530
1,042  $

$

419
306
202
188
56
1,178
2,349  $

2019 
526 
363 
241 
243 
71 
1,504 
2,948 

(1 ) For  information  on  our  interest  accrual  policies  and  delinquency  status  for  loan  modifications  related  to  the  pandemic,  see  Note  1  –  Summary  of  Significant  Accounting  Principles  to  the 

Consolidated Financial Statements. 

Direct/Indirect Consumer 
At  December  31,  2020,  51  percent  of  the  direct/indirect 
portfolio was included in Consumer Banking (consumer auto and 
recreational  vehicle  lending)  and  49  percent  was  included  in 
GWIM  (principally  securities-based  lending  loans).  Outstandings 

in the direct/indirect portfolio increased $365 million in 2020 to 
$91.4  billion  primarily  due  to  increases  in  securities-based 
lending offset by lower originations in Auto. 

Table  27  presents  certain  state  concentrations  for  the 

direct/indirect consumer loan portfolio. 

Table 27  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 (1 )

2020

2019

2020

2019

2020

2019 

December 31 

Net Charge-offs

$

$

12,248
10,891
8,981
6,609
3,572
49,062
91,363

 $

 $

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

6
4
6
2
—
15
 33

$

$

4
4
5
1
1
18
 33

$

$

20
20
20
9
2
51
122

$

$

49
27 
29 
12 
4 
88 
209 

(1 ) For  information  on  our  interest  accrual  policies  and  delinquency  status  for  loan  modifications  related  to  the  pandemic,  see  Note  1  –  Summary  of  Significant  Accounting  Principles  to  the 

Consolidated Financial Statements. 

Nonperforming Consumer Loans, Leases and Foreclosed 
Properties Activity 
Table  28  presents  nonperforming  consumer  loans,  leases  and 
foreclosed  properties  activity  during  2020  and  2019.  During 
2020, nonperforming consumer loans increased $672 million to 
$2.7 billion primarily driven by COVID-19 deferral activity, as well 
as  the  inclusion  of  $144  million  of  certain  loans  that  were 
previously  classified  as  purchased  credit-impaired  loans  and 
accounted for under a pool basis. 

At  December  31,  2020,  $892  million,  or  33  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,  2020,  $1.2  billion,  or  45 
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  $106  million  in  2020  to 
$123  million  as  the  Corporation  has  paused  formal  loan 
foreclosure  proceedings  and  foreclosure  sales  for  occupied 
properties during 2020. 

to  borrowers  experiencing 

Nonperforming  loans  also  include  certain  loans  that  have 
been modified in TDRs where economic concessions have been 
granted 
financial  difficulties. 
Nonperforming  TDRs  are  included  in  Table  28.  For  more 
information  on  our  loan  modification  programs  offered  in 
response  to  the  pandemic,  most  of  which  are  not  TDRs,  see 
Executive  Summary  –  Recent  Developments  –  COVID-19 
Pandemic  on  page  48  and  Note  1  –  Summary  of  Significant 
Accounting Principles to the Consolidated Financial Statements.

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Table 28  Nonperforming Consumer Loans, Leases and Foreclosed Properties Activity 

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Nonperforming loans and leases, January 1
Additions
Reductions: 

Paydowns and payoffs
Sales
Returns to performing status (1 )
Charge-offs
Transfers to foreclosed properties

Total net additions/(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 )

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2020

$

2,053 
2,278

$

2019 

3,842
1,407 

(440)
(38)
(1,014)
(78)
(36)
672
2,725
123
2,848
0.64 %

$

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

0.44 % 

0.66

0.49 

(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 $119 million and  $260 million at December 31, 2020 and 

2019. 

(3 ) Outstanding consumer loans and leases exclude loans accounted for under the fair value option. 

Table 29 presents TDRs for the consumer real estate portfolio. Performing TDR balances are excluded from nonperforming loans 
and leases in Table 28. For more information on our loan modification programs offered in response to the pandemic, most of which 
are  not  TDRs,  see  Executive  Summary  –  Recent  Developments  –  COVID-19  Pandemic  on  page  48  and  Note  1  –  Summary  of 
Significant Accounting Principles to the Consolidated Financial Statements. 

Table 29  Consumer Real Estate Troubled Debt Restructurings 

(Dollars in millions)
Residential mortgage (1 , 2 )
Home equity (3 )

Nonperforming
$

1,195  $

248

2,899  $

836

Total consumer real estate troubled debt restructurings

$

1,443  $

3,735  $

4,094  $
1,084
5,178  $

921  $
252

3,832  $

977

1,173  $

4,809  $

4,753 
1,229 
5,982 

December 31, 2020
Performing

Total

Nonperforming

December 31, 2019 
Performing

Total 

(1 ) At December 31, 2020 and 2019, residential mortgage TDRs deemed collateral dependent totaled $1.4 billion and $1.2 billion, and included $1.0 billion and $748 million of loans classified as 

nonperforming and $361 million and $468 million of loans classified as performing. 

(2 ) At December 31, 2020 and 2019, residential mortgage performing TDRs include $1.5 billion and $2.1 billion of loans that were fully-insured. 
(3 ) At  December  31,  2020  and  2019,  home  equity  TDRs  deemed  collateral  dependent  totaled  $407  million  and  $442  million,  and  include  $216  million  and  $209  million  of  loans  classified  as 

nonperforming and $191 million and $233 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. 

Modifications  of  credit  card  and  other  consumer  loans  are 
made  through  programs  utilizing  direct  customer  contact,  but 
may also utilize external programs. At December 31, 2020 and 
2019,  our  credit  card  and  other  consumer  TDR  portfolio  was 
$701 million and $679 million, of which $614 million and $570 
million  were  current  or  less  than  30  days  past  due  under  the 
modified terms. 

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 
industry,  product, 
concentrations  of  credit  exposure  by 
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

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and  commercial  clients  contributing  to  the  $67.2  billion  loan 
growth in the first quarter of 2020 have largely been repaid, as 
emergency  or  contingent  funding  was  no  longer  needed  or 
clients were able to access capital markets. Additionally, as part 
of  the  CARES  Act,  we  had  $22.7  billion  of  PPP  loans 
outstanding  with  our  small  business  clients  at  December  31, 
2020, which are included in U.S. small business commercial in 
the  tables  in  this  section.  For  more  information  on  PPP  loans, 
see Note 1 – Summary of Significant Accounting Principles to the 
Consolidated Financial Statements. 

Credit quality of commercial real estate borrowers has begun 
to  stabilize  in  many  sectors  as  certain  economies  have 
reopened.  Certain  sectors,  including  hospitality  and  retail, 
continue  to  be  negatively  impacted  as  a  result  of  COVID-19. 
Moreover,  many  real  estate  markets,  while  improving,  are  still 
in  demand,  supply  chain 
experiencing  some  disruptions 
challenges and tenant difficulties. 

The  commercial  allowance  for  loan  and  lease  losses 
increased  $3.9  billion  during  2020  to  $8.7  billion  due  to  the 
deterioration in the economic outlook resulting from the impact 
of  COVID-19.  For  more  information,  see  Allowance  for  Credit 
Losses on page 99. 

Total  commercial  utilized  credit  exposure  decreased  $15.0 
billion during 2020 to $620.3 billion driven by lower loans and 
leases.  The  utilization  rate  for  loans  and  leases,  SBLCs  and 
financial  guarantees,  and  commercial  letters  of  credit,  in  the 
aggregate,  was  57  percent  at  December  31,  2020  and  58 
percent at December 31, 2019. 

Table  30  presents  commercial  credit  exposure  by  type  for 
utilized, unfunded and total binding committed credit exposure. 
includes  SBLCs  and 
Commercial  utilized  credit  exposure 
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 
risk 
exposure 
management purposes. 

types  are  considered  utilized 

for  credit 

non-U.S.  portfolio,  we  evaluate  exposures  by  region  and  by 
country.  Tables  34,  37  and  40  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 
industry  concentrations,  see 
more 
Commercial  Portfolio  Credit  Risk  Management  –  Industry 
Concentrations on page 95 and Table 37. 

information  on  our 

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 
these 
organizations as a result of another member default and under 
other  loss  scenarios.  For  more  information,  see  Note  12  – 
Commitments  and  Contingencies  to  the  Consolidated  Financial 
Statements. 

incurred  by  some  of 

losses 

the 

Commercial Credit Portfolio 
During 2020, commercial asset quality weakened as a result of 
the economic impact from COVID-19. However, there were also 
positive  signs  during  this  period.  The  draws  by  large  corporate 

Table 30  Commercial Credit Exposure by Type 

Commercial Utilized (1 )

Commercial Unfunded (2 , 3 , 4 )
December 31 

Total Commercial Committed 

(Dollars in millions)
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

Total

$

2020

$

499,065  $

47,179
34,616
22,618
8,378
6,424
855
1,168
620,303  $

2019
517,657  $

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

2020

404,740  $
—
538
4,827
9,556
—
280
—
419,941  $

2020

903,805  $

2019
405,834  $
—
468
5,101
15,135
—
451
—

2019 
923,491 
40,485 
47,179
36,530 
35,154
30,647 
27,445
22,182 
17,934
6,660 
6,424
1,500 
1,135
800 
1,168
426,989  $  1,040,244  $  1,062,295 

(1 ) Commercial utilized exposure includes loans of $5.9 billion and $7.7 billion and issued letters of credit with a notional amount of $89 million and $170 million accounted for under the fair value 

option at December 31, 2020 and 2019. 

(2 ) Commercial unfunded exposure includes commitments accounted for under the fair value option with a notional amount of $3.9 billion and $4.2 billion at December 31, 2020 and 2019. 
(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 $10.5 billion and $10.6 billion at December 31, 2020 and 2019. 

(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 $42.5  billion  and  $33.9  billion  at 
December 31, 2020 and 2019. Not reflected in utilized and committed exposure is additional non-cash derivative collateral held of $39.3 billion and $35.2 billion at December 31, 2020 and 
2019, which consists primarily of other marketable securities.

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Outstanding commercial loans and leases decreased $18.6 
billion during 2020 primarily driven by repayments due in part to 
reduced  working  capital  needs  and  a  favorable  capital  markets 
environment,  partially  offset  by  $22.7  billion  of  PPP  loans 
outstanding at December 31, 2020. Nonperforming commercial 
loans increased $728 million across industries, and commercial 

Table 31  Commercial Credit Quality 

reservable  criticized  utilized  exposure  increased  $27.2  billion 
spread  across  several 
travel  and 
entertainment,  as  a  result  of  weaker  economic  conditions 
arising from COVID-19. Table 31 presents our commercial loans 
and  leases  portfolio  and  related  credit  quality  information  at 
December 31, 2020 and 2019. 

industries, 

including 

(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 )

Outstandings

Nonperforming 
December 31 

Accruing Past Due 
90 Days or More (3 )

2020

2019

2020

2019

2020

2019 

$

288,728  $

90,460
379,188
60,364
17,098
456,650
36,469

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

1,243  $

418
1,661
404
87
2,152
75

2,227

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

1,499

$

228
10
238
6
25
269
115

384

106 
8 
114 
19 
20 
153 
97 

250 

Commercial loans excluding loans accounted for under the fair 
value option
Loans accounted for under the fair value option (2 )

Total commercial loans and leases

493,119
5,946
499,065  $

509,916
7,741 
517,657 

$

Includes card-related products. 

(1 )
(2 ) Commercial loans accounted for under the fair value option include U.S. commercial of $2.9 billion and $4.7 billion and non-U.S. commercial of $3.0 billion and $3.1 billion at December 31, 

2020 and 2019. For more information on the fair value option, see Note 21 – Fair Value Option to the Consolidated Financial Statements. 

(3 ) For  information  on  our  interest  accrual  policies  and  delinquency  status  for  loan  modifications  related  to  the  pandemic,  see  Note  1  –  Summary  of  Significant  Accounting  Principles  to  the 

Consolidated Financial Statements. 

Table 32 presents net charge-offs and related ratios for our commercial loans and leases for 2020 and 2019. 

Table 32  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

2020

2019

Net Charge-off Ratios (1 )
2019 
2020

$

$

718
155

873
270
59
1,202
267

$

1,469  $

256
84

340
29
21
390
272
662

0.23%
0.15

0.21
0.43
0.32
0.24
0.86
0.28

0.08% 
0.08 

0.08 
0.05 
0.10 
0.08 
1.83 
0.13 

(1 ) Net charge-off ratios are calculated as net charge-offs divided by average outstanding loans and leases excluding loans accounted for under the fair value option. 

Table 33 presents commercial reservable criticized utilized exposure by loan type. Criticized exposure corresponds to the Special 
Mention,  Substandard  and  Doubtful  asset  categories  as  defined  by  regulatory  authorities.  Total  commercial  reservable  criticized 
utilized  exposure  increased  $27.2  billion  during  2020,  which  was  spread  across  several  industries,  including  travel  and 
entertainment, as a result of weaker economic conditions arising from COVID-19. At December 31, 2020 and 2019, 79 percent and 
90 percent of commercial reservable criticized utilized exposure was secured. 

Table 33  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 

2020

2019 

$

$

21,388
5,051
26,439
10,213
714
37,366
1,300
38,666

6.83 %  $
5.03
6.40
16.42
4.18
7.59
3.56
7.31

$

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 

(1 ) Total  commercial  reservable  criticized  utilized  exposure  includes  loans  and  leases  of  $36.6  billion  and  $10.7  billion  and  commercial  letters  of  credit  of  $2.1  billion  and  $715  million  at 

December 31, 2020 and 2019. 

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

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

U.S. Commercial 
At December 31, 2020, 65 percent of the U.S. commercial loan 
portfolio, excluding  small  business,  was  managed  in  Global 
Banking,  18  percent  in  Global  Markets,  15  percent  in  GWIM 
(generally business-purpose loans for high net worth clients) and 
the  remainder  primarily  in  Consumer  Banking . U.S. commercial  
loans  decreased  $18.3  billion  during  2020  driven  by  Global 
Banking. Reservable criticized utilized exposure increased $13.1 
billion,  which  was  spread  across  several  industries,  including 
travel  and  entertainment,  as  a  result  of  weaker  economic 
conditions arising from COVID-19. 

Non-U.S. Commercial 
At December 31, 2020, 79 percent of the non-U.S. commercial 
loan portfolio was managed in Global Banking and 21 percent in 
Global  Markets.  Non-U.S.  commercial  loans  decreased  $14.5 
billion during 2020, primarily in Global Banking. For information 
on the non-U.S. commercial portfolio, see Non-U.S. Portfolio on 
page 97. 

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  declined  by  $2.3  billion  during 

2020  as  paydowns  exceeded  new  originations.  Reservable 
criticized  utilized  exposure  increased  $9.1  billion  to  $10.2 
billion  from  $1.1  billion,  or  16.42  and  1.75  percent  of  the 
commercial  real  estate  portfolio  at  December  31,  2020  and 
2019,  due  to  downgrades  driven  by  the  impact  of  COVID-19 
across  industries,  primarily  hotels.  Although  we  have  observed 
property-level  improvements  in  a  number  of  the  most  impacted 
sectors,  the  length  of  time  for  recovery  has  been  slower  than 
originally  anticipated,  which  has  prompted  additional 
downgrades.  The  portfolio  remains  diversified  across  property 
types and geographic regions. California represented the largest 
state  concentration  at  23  percent  and  24  percent  of  the 
commercial  real  estate  portfolio  at  December  31,  2020  and 
2019.  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  2020,  we  continued  to  see  low  default  rates  and 
varying  degrees  of  improvement  in  the  portfolio.  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 34 presents outstanding commercial real estate loans 
by  geographic  region,  based  on  the  geographic  location  of  the 
collateral, and by property type. 

Table 34  Outstanding Commercial Real Estate Loans 

(Dollars in millions)
By Geographic Region 

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

Total outstanding commercial real estate loans

By Property Type 
Non-residential 

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

Total non-residential

Residential

December 31 

2020

2019 

$

$

$

14,028  $
11,628
8,551
6,588
4,294
3,483
2,594
2,370
1,634
3,187
2,007

60,364  $

17,667  $

8,330
7,931
7,226
7,051
2,336
1,460
7,146
59,147
1,217

14,910 
12,408 
8,408 
5,937 
3,984 
3,203 
3,349 
2,468 
1,638 
3,724 
2,660 
62,689 

17,902 
8,677 
8,183 
6,982 
7,250 
3,438 
1,788 
6,958 
61,178 
1,511 
62,689 

Total outstanding commercial real estate loans

$

60,364  $

(1 )

Includes unsecured loans to real estate investment trusts and national home builders whose portfolios of properties span multiple geographic regions and properties in the states of Colorado, 
Utah, Hawaii, Wyoming and Montana. 

U.S. Small Business Commercial 
The U.S. small business commercial loan portfolio is comprised 
of small business card loans and small business loans primarily 
managed  in  Consumer  Banking,  and  includes  $22.7  billion  of 
PPP  loans  outstanding  at  December  31,  2020.  Excluding  PPP, 
credit card-related products were 50 percent and 52 percent of 
the  U.S.  small  business  commercial  portfolio  at  December  31, 

2020  and  2019.  Of  the  U.S.  small  business  commercial  net 
charge-offs, 91 percent and 94 percent were credit card-related 
products in 2020 and 2019. 

Nonperforming Commercial Loans, Leases and Foreclosed 
Properties Activity 
Table 35 presents the nonperforming commercial loans, leases 
and  foreclosed  properties  activity  during  2020  and  2019.

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Nonperforming  loans  do  not  include  loans  accounted  for  under 
the  fair  value  option.  During  2020,  nonperforming  commercial 
loans  and  leases  increased  $728  million  to  $2.2  billion, 
primarily  driven  by  the  impact  of  COVID-19.  At  December  31, 
2020,  84  percent  of  commercial  nonperforming  loans,  leases 
and  foreclosed  properties  were  secured  and  66  percent  were 

contractually  current.  Commercial  nonperforming  loans  were 
carried  at  81 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 35  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 additions to nonperforming loans and leases
Total nonperforming loans and leases, December 31

Foreclosed properties, December 31

Nonperforming commercial loans, leases and foreclosed properties, December 31

Nonperforming commercial loans and leases as a percentage of outstanding commercial loans and leases (4 )
Nonperforming commercial loans, leases and foreclosed properties as a percentage of outstanding commercial loans, leases 

and foreclosed properties (4 )

2020

2019 

$

1,499
3,518

$

(1,002)
(350)
(172)
(1,208)
(2)
(56)
728
2,227
41
2,268

1,102 
2,048 

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

0.45 %

0.29 % 

0.46

0.30 

Includes U.S. small business commercial activity. Small business card loans are excluded as they are not classified as nonperforming. 

(1 ) Balances do not include nonperforming loans held-for-sale of $359 million and $239 million at December 31, 2020 and 2019. 
(2 )
(3 ) Commercial loans and leases may be returned to performing status when all principal and interest is current and full repayment of the remaining contractual principal and interest is expected, or 
when the loan otherwise becomes well-secured and is in the process of collection. TDRs are generally classified as performing after a sustained period of demonstrated payment performance. 

(4 ) Outstanding commercial loans exclude loans accounted for under the fair value option. 

Table 36 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  and  Allowance  for  Credit  Losses 
to the Consolidated Financial Statements. For more information 
on  our  loan  modification  programs  offered  in  response  to  the 
pandemic, most of which are not TDRs, see Executive Summary 
– Recent Developments – COVID-19 Pandemic on page 48 and 
Note  1  –  Summary  of  Significant  Accounting  Principles  to  the 
Consolidated Financial Statements. 

Table 36  Commercial Troubled Debt Restructurings 

Nonperforming

December 31, 2020
Performing

Total

Nonperforming

December 31, 2019 
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 

$

509  $

49
558
137
42
737
—

Total commercial troubled debt restructurings

$

737  $

Industry Concentrations 
Table  37  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 decreased $22.1 billion, or two percent, during 2020 
in  commercial  committed 
to  $1.0  trillion.  The  decrease 
exposure  was  concentrated  in  the  Global  commercial  banks, 
Asset  managers  and  funds,  Utilities,  and  Real  estate  industry 
sectors.  Decreases  were  partially  offset  by  increased  exposure 
to  the  Finance  companies  and  Automobiles  and  components 
industry sectors. 

Industry  limits  are  used  internally  to  manage  industry 
concentrations  and  are  based  on  committed  exposure  that  is 

850  $
119
969
—
2
971
 29
1,000  $

1,359  $

168
1,527
137
44
1,708
 29
1,737  $

617  $

41
658
212
18
888
 —

888  $

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

1,616 
234 
1,850 
226 
49 
2,125 
 27
2,152 

determined on an industry-by-industry basis. A risk management 
framework is in place to set and approve industry limits as well 
as  to  provide  ongoing  monitoring.  The  MRC  oversees  industry 
limit governance. 

Asset managers and funds, our largest industry concentration 
with  committed  exposure  of  $101.5  billion,  decreased  $8.5 
billion, or eight percent, during 2020. 

Real  estate,  our  second  largest  industry  concentration  with 
committed exposure of $92.4 billion, decreased $4.0 billion, or 
four  percent,  during  2020.  For  more  information  on  the 
commercial  real  estate  and  related  portfolios,  see  Commercial 
Portfolio Credit Risk Management – Commercial Real Estate on 
page 94. 

Capital  goods,  our  third  largest  industry  concentration  with 
committed  exposure  of  $81.0  billion,  remained  flat  during 
2020.

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Given  the  widespread  impact  of  the  pandemic  on  the  U.S. 
and global economy, a number of industries have been and will 
likely continue to be adversely impacted. We continue to monitor 
all  industries,  particularly  higher  risk  industries  which  are 
experiencing  or  could  experience  a  more  significant  impact  to 
their  financial  condition.  The  impact  of  the  pandemic  has  also 
placed  significant  stress  on  global demand for oil. Our energy-

related  committed  exposure  decreased  $3.3  billion,  or  nine 
percent,  during  2020  to  $33.0  billion,  driven  by  declines  in 
exploration  and  production,  refining  and  marketing  exposure, 
energy equipment  and  services, partially offset by  an increase 
in  our  integrated  client  exposure.  For  more  information  on 
COVID-19,  see  Executive  Summary  –  Recent  Developments  – 
COVID-19 Pandemic on page 48. 

Table 37  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
Retailing
Consumer services
Food, beverage and tobacco
Commercial services and supplies
Transportation
Energy
Utilities
Individuals and trusts
Technology hardware and equipment
Media
Software and services
Global commercial banks
Automobiles and components
Consumer durables and apparel
Vehicle dealers
Pharmaceuticals and biotechnology
Telecommunication services
Insurance
Food and staples retailing
Financial markets infrastructure (clearinghouses)
Religious and social organizations

Commercial 
Utilized 

Total Commercial 
Committed (2 )

December 31 

2020

2019

2020

2019 

68,093  $
69,267
39,911
46,948
33,759
41,669
24,548
24,749
32,000
22,871
21,154
23,426
13,936
12,387
18,784
10,515
13,144
11,709
20,751
10,956
9,232
15,028
5,217
9,411
5,921
5,209
4,939
4,769
620,303  $

71,386  $
70,361
41,082
40,173
34,353
41,889
26,663
25,868
28,434
24,163
23,103
23,449
16,406
12,383
18,927
10,646
12,445
10,432
30,171
7,345
10,193
18,013
5,964
9,154
6,673
6,290
5,496
3,844
635,306  $
$

101,540  $

92,414
80,959
70,004
57,880
56,212
50,792
49,710
48,026
44,628
38,149
33,444
32,983
29,234
25,881
24,796
24,677
23,647
22,922
20,765
20,223
18,696
16,349
15,605
13,491
11,810
8,648
6,759
1,040,244  $ 
(4,170)  $

110,069 
96,370 
80,892 
63,942 
55,918 
53,566 
52,129 
48,317 
49,071 
45,956 
38,944 
33,028 
36,326 
36,060 
27,817 
24,072 
23,645 
20,556 
32,345 
14,910 
21,245 
21,435 
20,206 
16,113 
15,218 
10,392 
7,997 
5,756 
1,062,295 
(3,349) 

Total commercial credit exposure by industry
Net credit default protection purchased on total commitments (4 )
Includes U.S. small business commercial exposure. 
Includes the notional amount of unfunded legally binding lending commitments net of amounts distributed (i.e., syndicated or participated) to other financial institutions. The distributed amounts 
were $10.5 billion and $10.6 billion at December 31, 2020 and 2019. 
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. 

$

(1 )

(2 )

(3 )

(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, 2020 and 2019, 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 
$4.2  billion  and  $3.3  billion.  We  recorded  net  losses  of  $240 
million in 2020 compared to net losses of $145 million in 2019 
for  these  same  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  44.  For  more  information,  see  Trading  Risk  Management 
on page 102.

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Tables  38  and  39  present  the  maturity  profiles  and  the 
credit exposure debt ratings of the net credit default protection 
portfolio at December 31, 2020 and 2019. 

Table 38  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 

2020

2019 

65 %

34
1
100 %

54 % 

45 
1 
100 % 

Table 39  Net Credit Default Protection by Credit 

Exposure Debt Rating 

Net 
Notional (1 )

Percent of 
Total 

Net 
Notional (1 )

Percent of 
Total 

December 31 

2020

2019 

$

(250)
(1,856)
(1,363)
(465)
(182)
(54)

6.0 %  $

44.5
32.7
11.2
4.4
1.2

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

20.8 % 
32.5 
22.9 
11.1 
3.6 
9.1 

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

Total net credit 

default protection

$ 

(4,170)

100.0 %  $ 

(3,349)

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 

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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. 

in  government  policies.  A 

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 
risk 
instability  and  changes 
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 40 presents our 20 largest non-U.S. country exposures 
at  December  31,  2020.  These  exposures  accounted  for  90 
percent  and  88  percent  of  our  total  non-U.S.  exposure  at 
December 31, 2020 and 2019. Net country exposure for these 
20  countries  increased  $21.2  billion  in  2020.  The  majority  of 
the  increase  was  due  to  higher  deposits  with  central  banks  in 
Germany and Japan. 

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.

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Table 40  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 
2020 

Hedges and 
Credit Default 
Protection 

Net Country 
Exposure at 
December 31 
2020 

Increase 
(Decrease) 
from 
December 31 
2019 

$

31,817  $
29,169
8,657
8,219
12,679
10,098
6,559
5,854
4,654
4,115
5,161
5,428
3,811
4,434
3,712
2,456
2,471
2,835
2,785
2,218

18,201  $
10,772
8,681
8,353
1,086
67
4,242
696
4,109
278
856
221
2,817
452
1,379
1,784
1,334
1,156
1,050
136

6,601  $
2,155
1,624
988
1,115
1,529
372
708
486
359
488
353
412
584
205
553
505
262
100
266

4,086  $
4,492
2,628
4,329
3,325
1,952
2,235
3,288
997
4,603
2,214
1,989
130
1,128
1,112
1,568
797
914
253
77

60,705  $
46,588
21,590
21,889
18,205
13,646
13,408
10,546
10,246
9,355
8,719
7,991
7,170
6,598
6,408
6,361
5,107
5,167
4,188
2,697

(1,233)  $
(1,685)
(456)
(1,098)
(709)
(226)
(321)
(253)
(562)
(73)
(168)
(180)
(275)
(61)
(121)
(669)
(140)
(351)
(23)
(10)

59,472  $
44,903
21,134
20,791
17,496
13,420
13,087
10,293
9,684
9,282
8,551
7,811
6,895
6,537
6,287
5,692
4,967
4,816
4,165
2,687

3,628 
14,075 
1,012 
4,536 
6,964 
(2,167) 
1,985 
(1,479) 
(643) 
1,456 
(154) 
(4,206) 
(490) 
(519) 
(1,524) 
315 
(1,540) 
94 
798 
(900) 

$

157,132  $

67,670  $

19,665  $

42,117  $

286,584  $

(8,614)  $

277,970  $

21,241 

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

Total top 20 non-U.S. 
countries exposure

Our largest non-U.S. country exposure at December 31, 2020 
was  the  U.K.  with  net  exposure  of  $59.5  billion,  which 
represents  a  $3.6  billion  increase  from  December  31,  2019. 
Our second largest non-U.S. country exposure was Germany with 
net  exposure  of  $44.9  billion  at  December  31,  2020,  a  $14.1 
billion  increase  from  December  31,  2019.  The  increase  in 
Germany  was  primarily  driven  by  an  increase  in  deposits  with 
the central bank. 

In  light  of  the  global  pandemic,  we  are  monitoring  our  non-
U.S. exposure closely, particularly in countries where restrictions 
on  certain  activities,  in  an  attempt  to  contain  the  spread  and 
impact  of  the  virus,  have affected  and will likely continue to 
adversely affect economic activity. We are managing the impact 
to  our  international  business  operations  as  part  of  our  overall 
response framework and are taking actions to manage exposure 
carefully in impacted regions while supporting the needs of our 
clients. The magnitude and duration of the pandemic and its full 
impact on the global economy continue to be highly uncertain. 

The impact of COVID-19 could have an adverse impact on the 
global  economy  for  a  prolonged  period  of  time.  For  more 
information  on  how  the  pandemic  may  affect  our  operations, 
see  Executive  Summary  –  Recent  Developments  –  COVID-19 
Pandemic on  page 48  and Item 1A. Risk Factors of our 2020 
Annual Report on Form 10-K. 

Table  41  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, 2020. Local exposure, defined as 
exposure  booked  in  local  offices  of  a  respective  country  with 
clients  in  the  same  country,  is  excluded.  At  December  31, 
2020, the U.K. and France were the only countries where their 
respective  total  cross-border  exposures  exceeded  one  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, 2020. 

Table 41  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 

2020  $
2019
2018
2020
2019
2018

4,733  $
1,859
1,505
3,073
736
633

2,269  $
3,580
3,458
1,726
2,473
2,385

95,180  $
93,232
46,191
26,399
23,172
29,847

102,182
98,671
51,154
31,198
26,381
32,865

3.62 % 
4.05 
2.17 
1.11 
1.08 
1.40

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Allowance for 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  ECL  inherent  in  the  Corporation’s  relevant 
financial assets. Upon adoption of the new accounting standard, 
the  Corporation  recorded  a  net  increase  of  $3.3  billion  in  the 
allowance  for  credit  losses  which  was  comprised  of  a  net 
increase  of  $2.9  billion  in  the  allowance  for  loan  and  lease 
losses  and  an  increase  of  $310  million  in  the  reserve  for 
unfunded lending commitments. The net increase was primarily 
driven  by  a  $3.1  billion  increase  related  to  the  credit  card 
portfolio. 

The  allowance  for  credit  losses  further  increased  by  $7.2 
billion  from  January  1,  2020  to  $20.7  billion  at  December  31, 
2020, which included a $5.0 billion reserve increase related to 
the  commercial  portfolio  and  a  $2.2  billion  reserve  increase 
related to the consumer portfolio. The increases were driven by 
deterioration in the economic outlook resulting from the impact 
of COVID-19. 

The  following  table  presents  an  allocation  of  the  allowance 
for  credit  losses  by  product  type  for  December  31,  2020, 
January 1, 2020 and December 31, 2019 (prior to the adoption 
of the CECL accounting standard). 

Table 42  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

Amount 

Percent of 
Total 

Percent of 
Loans and 
Leases 
Outstanding (1 )

December 31, 2020

Amount 

Percent of 
Total 

January 1, 2020

Percent of 
Loans and 
Leases 
Outstanding (1 )

Amount 

Percent of 
Total 

Percent of 
Loans and 
Leases 
Outstanding (1 )

December 31, 2019 

459

399

8,420

752

41

10,071

5,043

1,241

2,285

162

8,731

18,802

1,878

2.44 %

0.21 %  $

2.12

44.79

4.00

0.22

53.57

26.82

6.60

12.15

0.86

46.43

100.00 %

1.16

10.70

0.82

n/m

2.35

1.55

1.37

3.79

0.95

1.77

2.04

212

228

6,809

566

55

7,870

2,723

668

1,036

61

4,488

12,358

1,123

1.72 %

0.09 %  $

1.84

55.10

4.58

0.45

63.69

22.03

5.41

8.38

0.49

36.31

100.00 %

0.57

6.98

0.62

n/m

1.69

0.84

0.64

1.65

0.31

0.88

1.27

325

221

3,710

234

52

4,542

3,015

658

1,042

159

4,874

9,416

813 

$

10,229

3.45 %

0.14 % 

2.35

39.39

2.49

0.55

48.23

32.02

6.99

11.07

1.69

51.77

100.00 %

0.55 

3.80 

0.26 

n/m 

0.98 

0.94 

0.63 

1.66 

0.80 

0.96 

0.97 

Allowance for credit losses

$

20,680

$

13,481

(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 $298 million at December 31, 2020 and $257 million at January 1, 2020 and December 31, 2019 and home 
equity  loans  of  $437  million  at  December  31,  2020  and  $337  million  at  January  1,  2020  and  December  31,  2019.  Commercial  loans  accounted  for  under  the  fair  value  option  include  U.S. 
commercial loans of $2.9 billion, $5.1 billion and $4.7 billion at December 31, 2020, January 1, 2020 and December 31, 2019, and non-U.S. commercial loans of $3.0 billion, $3.2 billion and 
$3.1 billion at December 31, 2020, January 1, 2020 and December 31, 2019. 
Includes allowance for loan and lease losses for U.S. small business commercial loans of $1.5 billion, $831 million and $523 million at December 31, 2020, January 1, 2020 and December 31, 
2019. 
n/m = not meaningful 

(2 )

Net charge-offs for 2020 were $4.1 billion compared to $3.6 
billion  in  2019  driven  by  increases  in  commercial  losses.  The 
provision for credit losses increased $7.7 billion to $11.3 billion 
during 2020 compared to 2019. The allowance for credit losses 
included a reserve build of $7.2 billion for 2020, excluding the 
impact  of  the  new  accounting  standard,  primarily  due  to  the 
deterioration in the economic outlook resulting from the impact 
of  COVID-19  on  both  the  consumer  and  commercial  portfolios. 
The  provision  for  credit  losses  for  the  consumer  portfolio, 
including unfunded lending commitments, increased $2.0 billion 
to $4.9 billion during 2020 compared to 2019. The provision for 
credit losses  for  the  commercial  portfolio, including unfunded 

lending  commitments,  increased  $5.7  billion  to  $6.5  billion 
during 2020 compared to 2019. 

The  following  table  presents  a  rollforward  of  the  allowance 
for credit losses, including certain loan and allowance ratios for 
2020,  noting  that  measurement  of  the  allowance  for  credit 
losses  for  2019  was  based  on  management’s  estimate  of 
probable 
the 
Corporation’s credit loss accounting policies and activity related 
to  the  allowance  for  credit  losses,  see  Note  1  –  Summary  of 
Significant Accounting Principles and Note 5 – Outstanding Loans 
and Leases and Allowance for Credit Losses to the Consolidated 
Financial Statements.

losses.  For  more 

information  on 

incurred 

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Table 43  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

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: 

Loans and leases outstanding at December 31 (3 )
Allowance for loan and lease losses as a percentage of total loans and leases outstanding at December 31 (3 )
Consumer allowance for loan and lease losses as a percentage of total consumer loans and leases outstanding at December 

31 (4 )

Commercial allowance for loan and lease losses as a percentage of total commercial loans and leases outstanding at 

December 31 (5 )

Average loans and leases outstanding (3 )
Annualized net charge-offs as a percentage of average loans and leases outstanding (3 )
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 (6 )

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 (6 )

62539financials

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2020

2019 

$

12,358

$

9,601 

(40)
(58)
(2,967)
(372)
(307)
(3,744)

(1,163)
(168)
(275)
(69)
(1,675)
(5,419)

70
131
618
250
23
1,092

178
13
5
10
206
1,298
(4,121)
10,565
—
18,802
1,123
755
1,878
20,680

921,180

2.04 %

2.35

1.77
974,281

0.42 %
380
4.56

$

$

$

(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 

975,091 

0.97 % 

0.98 

0.96 
951,583 

0.38 % 
265 
2.58 

9,854

$

4,151 

181 %

148 % 

$

$

$

$

(1 )

Includes U.S. small business commercial charge-offs of $321 million in 2020 compared to $320 million in 2019. 
Includes U.S. small business commercial recoveries of $54 million in 2020 compared to $48 million in 2019. 

(2 )
(3 ) Outstanding loan and lease balances and ratios do not include loans accounted for under the fair value option of $6.7 billion and $8.3 billion at December 31, 2020 and 2019. Average loans 

accounted for under the fair value option were $8.2 billion in 2020 compared to $6.8 billion in 2019. 

(4 ) Excludes consumer loans accounted for under the fair value option of $735 million and $594 million at December 31, 2020 and 2019. 
(5 ) Excludes commercial loans accounted for under the fair value option of $5.9 billion and $7.7 billion at December 31, 2020 and 2019. 
(6 ) Primarily includes amounts related to credit card and unsecured consumer lending portfolios in Consumer Banking.

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Market Risk Management

Interest Rate Risk

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 105.

We have been affected, and expect

to continue to be

affected, by market stress resulting from the pandemic that

began in the first quarter of 2020. For more information on the

effects of

the pandemic, see Executive Summary – Recent

Developments – COVID-19 Pandemic on page 48.

Our traditional banking loan and deposit products are non-

trading positions and are generally reported at amortized cost

for assets or the amount owed for liabilities (historical cost).

However,

these positions are still subject

to changes in

economic value based on varying market conditions, with one of

the primary risks being changes in the levels of interest rates.

The risk of adverse changes in the economic value of our non-

trading positions arising from changes in interest

rates is

managed through our ALM activities. We have elected to

account for certain assets and liabilities under the fair value

option.

Our trading positions are reported at fair value with changes

reflected in income. Trading positions are subject to various

changes in market-based risk factors. The majority of this risk is

generated by our activities in the interest rate, foreign exchange,

credit, equity and commodities markets. In addition, the values

of assets and liabilities could change due to market liquidity,

correlations across markets and expectations of market

volatility. We seek to manage these risk exposures by using a

variety of techniques that encompass a broad range of financial

instruments.

The key

risk management

techniques are

discussed in more detail

in the Trading Risk Management

section.

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.

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

risks. The Enterprise Model Risk Policy defines

model risk standards, consistent with our 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 Enterprise

Model Risk Committee (EMRC), a subcommittee of the MRC,

oversees that model standards are consistent with model risk

validation process across the Corporation.

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.

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 certificates, commercial mortgages

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 107.

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

Bank of America 2020 101

requirements and monitors the effective challenge in the model

options. Hedging instruments used to mitigate this risk include

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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 105. 

We  have  been  affected,  and  expect  to  continue  to  be 
affected,  by  market  stress  resulting  from  the  pandemic  that 
began in the first quarter of 2020. For more information  on  the 
effects  of 
the  pandemic,  see  Executive  Summary  –  Recent 
Developments – COVID-19 Pandemic  on page 48. 

Our  traditional  banking  loan  and  deposit  products  are  non-
trading  positions  and  are  generally  reported  at  amortized  cost 
for  assets  or  the  amount  owed  for  liabilities  (historical  cost). 
However,  these  positions  are  still  subject  to  changes  in 
economic value based on varying market conditions, with one of 
the  primary  risks  being  changes  in  the  levels  of  interest  rates. 
The  risk  of adverse  changes in  the  economic value of our  non-
trading  positions  arising  from  changes  in  interest  rates  is 
managed  through  our  ALM  activities.  We  have  elected  to 
account  for  certain  assets  and  liabilities  under  the  fair  value 
option. 

Our trading positions are reported at fair value with changes 
reflected  in  income.  Trading  positions  are  subject  to  various 
changes in market-based risk factors. The majority of this risk is 
generated by our activities in the interest rate, foreign exchange, 
credit, equity and commodities markets. In addition, the values 
of  assets  and  liabilities  could  change  due  to  market  liquidity, 
correlations  across  markets  and  expectations  of  market 
volatility.  We  seek  to  manage  these  risk  exposures  by  using  a 
variety of techniques that encompass a broad range of financial 
techniques  are 
instruments.  The  key 
discussed  in  more  detail  in  the  Trading  Risk  Management 
section. 

risk  management 

risks 

trading 

include  ownership  of  market 

Global  Risk  Management  is  responsible  for  providing  senior 
management  with  a  clear  and  comprehensive  understanding  of 
to  which  we  are  exposed.  These 
the 
responsibilities 
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. 

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  risks.  The  Enterprise  Model  Risk  Policy  defines 
model  risk  standards,  consistent  with  our  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  Enterprise 
Model  Risk  Committee  (EMRC),  a  subcommittee  of  the  MRC, 
oversees  that  model  standards  are  consistent  with  model  risk 
requirements and monitors the effective challenge in the model 
validation process across the Corporation. 

62539financials

101

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 
liabilities, 
deposits, borrowings and derivatives. Hedging instruments used 
to  mitigate  these  risks  include  derivatives  such  as  options, 
futures, forwards and swaps. 

trading-related  assets  and 

to 

risk 

this 

include 

investments 

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 
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. 

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  certificates,  commercial  mortgages 
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 107. 

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

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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  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 
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. 

further  exacerbated 

the  Corporation.  These  measures 

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 
include 
portfolio  of 
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 
respective 
limitations.  Additionally,  risk  managers  independently  evaluate 
the risk of the portfolios under the current market environment 
and potential future environments. 

their 

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 

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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 73. 

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 
the  appropriate 
management committees. 

to  management 

reported 

through 

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 
review.  Certain 
to  management 
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. 

for 

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 44 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  44  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

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trading  activities  as  presented  in  Table  44  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  44 
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  44  presents  year-end,  average,  high  and  low  daily 
trading VaR for 2020 and 2019 using a 99 percent confidence 

Table 44  Market Risk VaR for Trading Activities 

level. The amounts disclosed in Table 44 and Table 45 align to 
the  view  of  covered  positions  used  in  the  Basel  3  capital 
calculations.  Foreign  exchange  and  commodity  positions  are 
always  considered  covered  positions,  regardless  of  trading  or 
banking  treatment  for  the  trade,  except  for  structural  foreign 
currency  positions  that  are  excluded  with  prior  regulatory 
approval. 

The annual average of total covered positions and less liquid 
trading positions portfolio VaR increased for 2020 compared to 
2019  primarily  due  to  the  impact  of  market  volatility  related  to 
the pandemic in the VaR look back period. 

(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

2020

2019 

Year 
End

Average

High (1 )

Low (1 )

Year 
End

Average

High (1 )

Low (1 )

$

$

8
30
79
20
4
(72)
69
52

121
52
11
(17)
46
(4)
163 

 $

$

 $

7
19
 58
24
 6
(61)
53
27

80
52
13
(24)
41
(15)
106

 $

25
39
 91
162
 12
—
171
—

169
84
17
—
86
—
171

2
7
 25
12
 3
—
27
— 

30
7
9
—
9
—
32 

 $

$

 $

4
25
 26
29
 4
(47)
41
—

41
8
10
(9)
9
(5)
45  $

 $

6
24
23
22
 6
(49)
32
 3

35
10
10
(10)
10
(7)
38

 $

13
49
32
33
 31
—
47
 —

53
13
17
—
16
—
56

2
14 
16 
14 
 4
— 
24 
 —

27 
7 
4 
— 
5 
— 
28 

(1 ) The high and low for each portfolio may have occurred on different trading days than the high and low for the components. Therefore the impact from less liquid exposures and the amount of 

portfolio diversification, which is the difference between the total portfolio and the sum of the individual components, is not relevant. 

The graph below presents the daily covered positions and less liquid trading positions portfolio VaR for 2020, corresponding to 

the data in Table 44. Peak VaR in mid-March 2020 was driven by increased market realized volatility and higher implied volatilities. 

Additional  VaR  statistics  produced  within  our  single  VaR 
model are provided in Table 45 at the same level of detail as in 
Table 44. 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 45 

presents  average  trading  VaR  statistics  at  99  percent  and  95 
percent  confidence  levels  for  2020  and  2019.  The  increase  in 
VaR for the 99 percent confidence level for 2020 was primarily 
due  to  COVID-19  related  market  volatility,  which  impacted  the 
99 percent VaR average more severely than the 95 percent VaR 
average.

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Table 45  Average Market Risk VaR for Trading Activities – 99 percent and 95 percent VaR Statistics 

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(Dollars in millions)
Foreign exchange
Interest rate
Credit
Equity
Commodities 
Portfolio diversification

Total covered positions portfolio
Impact from less liquid exposures

Total covered positions and less liquid trading positions portfolio

Fair value option loans
Fair value option hedges
Fair value option portfolio diversification

Total fair value option portfolio

Portfolio diversification

Total market-based portfolio

Backtesting 
is  evaluated  by 
The  accuracy  of  the  VaR  methodology 
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 
risk  management.  Senior 
management  regularly  reviews  and  evaluates  the  results  of 
these tests. 

to  senior  market 

During  2020,  there  were  seven  days  where  this  subset  of 
trading  revenue  had  losses  that  exceeded  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. For more 
information  on 
fair  value,  see  Note  20  –  Fair  Value 
Measurements  to  the  Consolidated  Financial  Statements. 

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2020

2019 

99 percent

95 percent

99 percent

$

$

$

 7
19
58
24
6
(61)
53
27
80
52
13
(24)
41
(15)
106  $

$

 4
9
18
13
 3
(26)
21
2 
23
13
7
(8)
12
(6)
29  $

6
24
23
22
 6
(49)
32
3
35
10
10
(10)
10
(7)
 38

95 percent 
 3
15 
15 
11 
 3
(29) 
18 
 2
20 
5 
6 
(5) 
6 
(5) 
 21

$

$

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  2020  and  2019.  During  2020,  positive  trading-related 
revenue  was  recorded  for  98  percent  of  the  trading  days,  of 
which  87  percent  were  daily  trading  gains  of  over  $25  million, 
and  the  largest  loss  was  $90  million.  This  compares  to  2019 
where  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. 

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

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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 
liquidity  planning.  For  more 
consolidated  capital  and 
information, see Managing Risk on page 70. 

Interest Rate Risk Management for the Banking 
Book 
The  following  discussion  presents  net  interest  income  for 
banking book activities. 

Interest rate risk represents the most significant market risk 
exposure  to  our  banking  book  balance  sheet. Interest rate  risk 
is  measured  as  the  potential  change  in  net  interest  income 
caused  by  movements  in  market  interest  rates.  Client-facing 
activities,  primarily  lending  and  deposit-taking,  create  interest 
rate sensitive positions on our balance sheet. 

We prepare forward-looking forecasts of net interest income. 
The  baseline  forecast  takes  into  consideration  expected  future 
business  growth,  ALM  positioning -and  the  direction  of  interest 
rate movements as implied by the market-based forward curve. 

We  then  measure  and  evaluate  the  impact  that  alternative 
interest rate scenarios have on the baseline forecast in order to 
assess interest rate sensitivity under varied conditions. The net 
interest  income  forecast  is  frequently  updated  for  changing 
assumptions and differing outlooks based on economic trends, 
market conditions and business strategies. Thus, we continually 
monitor  our  balance  sheet  position  in  order  to  maintain  an 
acceptable level of exposure to interest rate changes. 

The  interest  rate  scenarios  that  we  analyze  incorporate 
balance  sheet  assumptions  such  as  loan  and  deposit  growth 
and pricing, changes in funding mix, product repricing, maturity 
characteristics and investment securities premium amortization. 
Our  overall  goal  is  to  manage  interest  rate  risk  so  that 
movements in interest rates do not significantly adversely affect 
earnings and capital. 

Table 46 presents the spot and 12-month forward rates used 

in our baseline forecasts at December 31, 2020 and 2019. 

Table 46  Forward Rates 

Federal 
Funds 

December 31, 2020 
Three-month 
LIBOR 

10-Year 
Swap 

Spot rates
12-month forward rates

0.25 %
0.25

0.24 %
0.19

Spot rates
12-month forward rates

December 31, 2019 

1.75 %
1.50

1.91 %
1.62

0.93 % 
1.06 

1.90 % 
1.92 

Table 47 shows the pretax impact to forecasted net interest 
income over the next 12 months from December 31, 2020 and 
2019  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.  The  interest  rate 
scenarios also assume U.S. dollar rates are floored at zero. 

During  2020,  the  asset  sensitivity  of  our  balance  sheet 
increased in both up-rate and down-rate scenarios primarily due 
to continued deposit growth invested in long-term securities. We 
continue  to  be  asset  sensitive  to  a  parallel  upward  move  in 
interest  rates  with  the  majority  of  that  impact  coming  from  the 
short  end  of  the  yield  curve.  Additionally,  higher  interest  rates 
impact  the  fair  value  of  debt  securities  and,  accordingly,  for 
debt  securities  classified  as  AFS,  may  adversely  affect 
accumulated  OCI  and  thus  capital  levels  under  the  Basel  3 
capital  rules.  Under  instantaneous  upward  parallel  shifts,  the 
near-term  adverse  impact  to  Basel  3  capital  is  reduced  over 
time  by  offsetting  positive  impacts  to  net  interest  income.  For 
more  information  on  Basel  3,  see  Capital  Management  – 
Regulatory Capital on page 74. 

Table 47  Estimated Banking Book Net Interest Income 

Sensitivity to Curve Changes 

Short 
Rate 
(bps) 

Long 
Rate 
(bps) 

December 31 

2020

2019 

(Dollars in millions)
Parallel Shifts 
+100 bps 

instantaneous shift

+100

+100  $

10,468

 $

4,190

-25 bps 

instantaneous shift

-25

-25

(2,766)

(1,500) 

Flatteners 

Short-end 

instantaneous change 

+100

Long-end 

instantaneous change

—

—

-25

6,321

2,641 

(1,686)

(653) 

Steepeners 
Short-end 

instantaneous change

-25

—

(1,084)

(844) 

Long-end 

instantaneous change

— 

+100

4,333

1,561 

The sensitivity analysis in Table 47 assumes that we take no 
action in response to these rate shocks and does not assume 
in  other  macroeconomic  variables  normally 
any  change 
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  47  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 non-
interest-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

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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 
interest  rate 
exchange  contracts, 
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. 

including  cross-currency 

Changes  to  the  composition  of  our  derivatives  portfolio 
during  2020  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 results on both open and terminated cash 
flow hedge derivative instruments recorded in accumulated OCI 
were  a  gain  of  $580  million  and  a  loss  of  $496  million,  on  a 
pretax  basis,  at  December  31,  2020  and  2019.  These  gains 
and 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, 
2020,  the  after-tax  net  gains  are  expected  to  be  reclassified 
into earnings as follows: a gain of $187 million within the next 
year, a gain of $358 million in years two through five, a loss of 
$59 million in years six through ten, with the remaining loss of 
$50  million  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, 2020. 

Table  48  presents  derivatives  utilized  in  our  ALM  activities 
and  shows  the  notional  amount,  fair  value,  weighted-average 
receive-fixed and pay-fixed rates, expected maturity and average 
estimated  durations  of  our  open  ALM  derivatives  at 
December 31, 2020 and 2019. These amounts do not include 
derivative  hedges  on  our  MSRs.  During  2020,  the  fair  value  of 
receive-fixed  interest  rate  swaps  increased  while  pay-fixed 
interest swaps decreased, primarily driven by lower swap rates 
on hedges of U.S. dollar long-term debt. 

Table 48  Asset and Liability Management Interest Rate and Foreign Exchange Contracts 

December 31, 2020 
Expected Maturity 

(Dollars in millions, average estimated duration in 

years) 

Receive-fixed interest rate swaps (1 )

Fair 
Value
$  14,885

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 )

Notional amount

Foreign exchange contracts (1 , 4 , 5 )

Notional amount (6 )

Futures and forward rate contracts

Notional amount

Option products

Notional amount

Net ALM contracts

(5,502)

(235) 

(1,014) 

349 

47 

— 

$ 

8,530

Total

2021

2022

2023

2024

2025

Thereafter 

$269,015

$ 11,050

$ 20,908

$ 30,654

$ 31,317

$ 32,898

$142,188 

1.54 %

3.25 %

0.91 %

1.48 %

1.17 %

1.07 %

1.69 % 

$252,698

$  7,562

$ 21,667

$ 24,671

$ 24,406

$ 32,052

$142,340 

0.89 %

0.57 %

0.10 %

1.28 %

0.86 %

0.68 %

1.00 % 

$223,659

$ 18,769

$ 12,245

$  9,747

$ 22,737

$ 28,222

$131,939 

112,465

27,424

16,038

8,066

3,819

4,446

52,672 

(42,490)

(69,299)

2,841

2,505

4,735

4,369

12,359 

14,255

14,255

17

—

—

—

—

17

—

—

—

—

— 

— 

Average 
Estimated 
Duration 

8.08 

6.52 

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Table 48 Asset and Liability Management Interest Rate and Foreign Exchange Contracts (continued)

December 31, 2019 
Expected Maturity 

(Dollars in millions, average estimated duration in 

years) 

Receive-fixed interest rate swaps (1 )

Fair 
Value
$  12,370

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 )

Notional amount

Foreign exchange contracts (1 , 4 , 5 )

Notional amount (6 )

Option products

Notional amount

Net ALM contracts

(2,669)

(290) 

(1,258) 

414 

— 

$  8,567 

Total

2020

2021

2022

2023

2024

Thereafter 

$215,123 
2.68 %

$ 16,347

$ 14,642

$ 21,616

$ 36,356

$ 21,257

$104,905 

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 

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

—

— 

Average 
Estimated 
Duration 

6.47 

6.99 

(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, 2020 and 2019, the notional amount of same-currency basis swaps included $223.7 billion and $152.2 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  $(42.5)  billion  at  December  31,  2020  was  comprised  of  $34.2  billion  in  foreign  currency-denominated  and  cross-currency  receive-fixed 
swaps, $(74.3) billion in net foreign currency forward rate contracts, $(3.1) billion in foreign currency-denominated interest rate swaps and $711 million in net foreign currency futures contracts. 
Foreign exchange contracts of $(53.1) billion at December 31, 2019 were 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 foreign currency futures contracts. 

(6 ) Reflects the net of long and short positions. Amounts shown as negative reflect a net short position. 

Mortgage Banking Risk Management 
We originate, fund and service mortgage loans, which subject us 
to  credit,  liquidity  and  interest  rate  risks,  among  others.  We 
determine whether loans will be held for investment or held for 
sale at the time of commitment and manage credit and liquidity 
risks  by  selling  or  securitizing  a  portion  of  the  loans  we 
originate. 

Interest  rate  risk  and  market  risk  can  be  substantial  in  the 
mortgage business. Changes in interest rates and other market 
factors impact the volume of mortgage originations. Changes in 
interest  rates  also  impact  the  value  of  interest  rate  lock 
commitments (IRLCs) and the related residential first mortgage 
loans held-for-sale (LHFS) between the date of the IRLC and the 
date the loans are sold to the secondary market. An increase in 
mortgage  interest  rates  typically  leads  to  a  decrease  in  the 
value  of  these  instruments.  Conversely,  when  there  is  an 
increase  in  interest  rates,  the  value  of  the  MSRs  will  increase 
driven by lower prepayment expectations.  Because the interest 
rate risks of these hedged items offset, we combine them into 
one  overall  hedged  item  with  one  combined  economic  hedge 
portfolio consisting of derivative contracts and securities. 

During  2020,  2019  and  2018,  we  recorded  gains  of  $321 
million, $291 million and $244 million related to the change in 
fair value of the MSRs, IRLCs and LHFS, net of gains and losses 
on the hedge portfolio. For more information on MSRs, see Note 
20  –  Fair  Value  Measurements  to  the  Consolidated  Financial 
Statements. 
Compliance and Operational Risk Management 
Compliance  risk  is  the  risk  of  legal  or  regulatory  sanctions, 
material  financial  loss  or  damage  to  the  reputation  of  the 
Corporation arising from the failure of the Corporation to comply 
with the requirements of applicable laws, rules, regulations and 
our  internal  policies  and  procedures  (collectively,  applicable 
laws, rules and regulations). 

Operational risk is the risk of loss resulting from inadequate 
or  failed  processes,  people  and  systems  or  from  external 

events. Operational risk may occur anywhere in the Corporation, 
including  third-party  business  processes,  and  is  not  limited  to 
operations  functions.  Effects  may  extend  beyond  financial 
losses and may result in reputational risk impacts. Operational 
risk  includes  legal  risk.  Additionally,  operational  risk  is  a 
component in the calculation of total RWA used in the Basel 3 
capital  calculation.  For  more 
information  on  Basel  3 
calculations, see Capital Management on page 73. 

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  and  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.

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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 
for 
responsibilities 
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. 

integrity  of  our,  or 

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  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. 

Climate Risk Management 
Climate-related  risks  are  divided  into  two  major  categories:  (1) 
risks  related  to  the  transition  to  a  low-carbon  economy,  which 
may  entail  extensive  policy,  legal,  technology  and  market 

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changes, and (2) risks related to the physical impacts of climate 
change,  driven  by  extreme  weather  events,  such  as  hurricanes 
and  floods,  as  well  as  chronic  longer-term  shifts,  such  as 
temperature increases and sea level rises. These changes and 
events  can  have  broad  impacts  on  operations,  supply  chains, 
distribution  networks,  customers,  and  markets  and  are 
otherwise  referred  to,  respectively,  as  transition  risk  and 
physical risk. The financial impacts of transition risk can lead to 
and amplify credit risk. Physical risk can also lead to increased 
credit  risk  by  diminishing  borrowers’  repayment  capacity  or 
collateral values. 

As climate risk is interconnected with all key risk types, we 
have  developed  and  continue  to  enhance  processes  to  embed 
climate  risk  considerations  into  our  Risk  Framework  and  risk 
management programs established for strategic, credit, market, 
liquidity,  compliance,  operational  and  reputational  risks.  A  key 
element  of  how  we  manage  climate 
the  Risk 
Identification process through which climate and other risks are 
identified across all FLUs and control functions, prioritized in our 
risk  inventory  and  evaluated  to  determine  estimated  severity 
and  likelihood  of  occurrence.  Once  identified,  climate  risks  are 
assessed for potential impacts and incorporated into the design 
of  macroeconomic  scenarios  to  generate  loss  forecasts  and 
assess  how  climate-related  impacts  could  affect  us  and  our 
clients. 

risk 

is 

Our  governance  framework  establishes  oversight  of  climate 
risk  practices  and  strategies  by  the  Board,  supported  by  its 
Corporate  Governance,  ESG,  and  Sustainability  Committee,  the 
ERC  and  the  Global  Environmental,  Social  and  Governance 
Committee, a management-level committee comprised of senior 
leaders  across  every  major  FLU  and  control  function.  The 
Climate  Risk  Steering  Council  oversees  our  climate  risk 
management  practices,  shapes  our  approach  to  managing 
climate-related risks in line with our Risk Framework and meets 
monthly.  In  2020,  the  climate  risk  management  effort  was 
bolstered  through  the  appointment  of  a  Global  Climate  Risk 
Executive who reports to the CRO, and establishment of a new 
division within our Global Risk organization to drive execution of 
the climate risk management program with the support of FLUs, 
Technology  &  Operations  and  Risk  partners.  For  additional 
information about climate risk, see the Bank of America website 
(the content of which is not incorporated by reference into this 
Annual Report on Form 10-K). 

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

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liabilities  may  change  subsequent  to  the  balance  sheet  date, 
often  significantly,  due  to  the  nature  and  magnitude  of  future 
credit and market conditions. Such credit and market conditions 
may  change  quickly  and  in  unforeseen  ways  and  the  resulting 
volatility  could  have  a  significant,  negative  effect  on  future 
operating results. These fluctuations would not be indicative of 
deficiencies in our models or inputs. 

Allowance for Credit Losses 
On  January  1,  2020,  the  Corporation  adopted  the  new 
accounting  standard  that  requires  the  measurement  of  the 
allowance  for  credit  losses,  which  includes  the  allowance  for 
loan  and  lease  losses  and  the  reserve  for  unfunded  lending 
commitments, to be based on management’s best estimate of 
lifetime  ECL  inherent  in  the  Corporation's  relevant  financial 
assets. 

that 

options.

variables 

incorporate 

borrower-controlled

extension
include 

The Corporation's estimate of lifetime ECL includes the use 
of  quantitative  models 
forward-looking 
macroeconomic scenarios that are applied over the contractual 
life  of  the  loan  portfolios,  adjusted  for  expected  prepayments 
These 
and
macroeconomic  scenarios 
that  have 
historically  been  key  drivers  of  increases  and  decreases  in 
credit  losses.  These  variables  include,  but  are  not  limited  to, 
unemployment rates, real estate prices, gross domestic product 
and  corporate  bond  spreads.  As  any  one  economic  outlook  is 
leverages  multiple 
the  Corporation 
inherently  uncertain, 
scenarios. The scenarios that are chosen each quarter and the 
amount of weighting given to each scenario depend on a variety 
of  factors  including  recent  economic  events,  leading  economic 
indicators,  views  of  internal  and  third-party  economists  and 
industry trends. 

factors 

The  Corporation  also  includes  qualitative  reserves  to  cover 
losses that are expected but, in the Corporation's assessment, 
may  not  be  adequately  reflected  in  the  economic  assumptions 
described  above.  For  example, 
the  Corporation 
considers  include  changes  in  lending  policies  and  procedures, 
business  conditions,  the  nature  and  size  of  the  portfolio, 
portfolio  concentrations,  the  volume  and  severity  of  past  due 
loans and nonaccrual loans, the effect of external factors such 
as  competition  and  legal  and  regulatory  requirements,  among 
inherent 
others.  Further, 
uncertainty  in  quantitative  models  that  are  built  on  historical 
data. 

the  Corporation  considers 

the 

The  allowance  for  credit  losses  can  also  be  impacted  by 
unanticipated changes in asset quality of the portfolio, such as 
increases in risk rating downgrades in our commercial portfolio, 
deterioration  in  borrower  delinquencies  or  credit  scores  in  our 
credit  card  portfolio  or  increases  in  LTVs  in  our  consumer  real 
estate  portfolio.  In  addition,  while  we  have  incorporated  our 
estimated  impact  of  COVID-19  into  our  allowance  for  credit 
losses,  the  ultimate  impact  of  the  pandemic  is  still  unknown, 
including  how  long  economic  activities  will  be  impacted  and 
what  effect  the  unprecedented  levels  of  government  fiscal  and 
monetary  actions  will  have  on  the  economy  and  our  credit 
losses. 

credit 

losses 

As described above, the process to determine the allowance 
for 
requires  numerous  estimates  and 
assumptions, some of which require a high degree of judgment 
and  are  often  interrelated.  Changes  in  the  estimates  and 
assumptions can result in significant changes in the allowance 
for credit losses. Our process for determining the allowance for 
credit  losses  is  further  discussed  in  Note  1  –  Summary  of 
Significant Accounting Principles and Note 5 – Outstanding Loans 

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and Leases and Allowance for Credit Losses 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. 

that 

requires 

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 
review  and  approval  of 
quantitative  models  used  for  deal  pricing,  financial  statement 
fair  value  determination  and  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 
20 – Fair Value Measurements and Note 21 – Fair Value Option 
to the Consolidated Financial Statements. 

Level 3 Assets and Liabilities 
Financial  assets  and  liabilities,  and  MSRs,  where  values  are 
based on valuation techniques that require inputs that are both 
unobservable  and  are  significant  to  the  overall  fair  value 
measurement  are  classified  as  Level  3  under  the  fair  value 
hierarchy  established  in  applicable  accounting  standards.  The 
fair  value  of  these  Level  3  financial  assets  and  liabilities  and 
MSRs is determined using pricing models, discounted cash flow 
methodologies or similar techniques for which the determination 
of  fair  value  requires  significant  management  judgment  or 
estimation. 

Level 3 financial instruments may be hedged with derivatives 
classified as Level 1 or 2; therefore, gains or losses associated 
with  Level  3  financial  instruments  may  be  offset  by  gains  or 
losses associated with financial instruments classified in other 
levels of the fair value hierarchy. The Level 3 gains and losses 
recorded  in  earnings  did  not  have  a  significant  impact  on  our 
liquidity  or  capital.  We  conduct  a  review  of  our  fair  value 
hierarchy  classifications  on  a  quarterly  basis.  Transfers  into  or 
out  of  Level  3  are  made  if  the  significant  inputs  used  in  the 
financial  models  measuring  the  fair  values  of  the  assets  and

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We  completed  our  annual  goodwill  impairment  test  as  of 
June  30,  2020.  In  performing  that  test,  we  compared  the  fair 
value  of  each  reporting  unit  to  its  estimated  carrying  value  as 
measured  by  allocated  equity.  We  estimated  the  fair  value  of 
each  reporting  unit  based  on  the  income  approach  (which 
utilizes  the  present  value  of  cash  flows  to  estimate  fair  value) 
and  the  market  multiplier  approach  (which  utilizes  observable 
market  prices  and  metrics  of  peer  companies  to  estimate  fair 
value). 

Our  discounted  cash  flows  were  generally  based  on  the 
Corporation’s  three-year  internal  forecasts  with  a  long-term 
growth  rate  of  3.68  percent.  Our  estimated  cash  flows 
considered  the  current  challenging  global  industry  and  market 
conditions  related  to  the  pandemic,  including  the  low  interest 
rate  environment.  The  cash  flows  were  discounted  using  rates 
that  ranged  from  9  percent  to  12  percent,  which  were  derived 
from a capital asset pricing model that incorporates the risk and 
uncertainty in the cash flow forecasts, the financial markets and 
industries similar to each of the reporting units. 

Under the market multiplier approach, we estimated the fair 
value  of  the  individual  reporting  units  utilizing  various  market 
multiples,  primarily  various  pricing  multiples,  from  comparable 
publicly-traded  companies  in  industries  similar  to  the  reporting 
unit  and  then  factored  in  a  control  premium  based  upon 
observed  comparable  premiums  paid  for  change-in-control 
transactions for financial institutions. 

Based  on  the  results  of  the  test,  we  determined  that  each 
reporting  unit’s  estimated  fair  value  exceeded  its  respective 
carrying value and that the goodwill assigned to each reporting 
unit was not impaired. The fair values of the reporting units as a 
percentage of their carrying values ranged from 109 percent to 
213 percent. It currently remains difficult to estimate the future 
economic  impacts  related  to  the  pandemic.  If  economic  and 
market  conditions 
internationally) 
deteriorate,  our  reporting  units  could  be  negatively  impacted, 
which could change our key assumptions and related estimates 
and may result in a future impairment charge. 

in  the  U.S.  and 

(both 

Certain Contingent Liabilities 
For more information on the complex judgments associated with 
certain  contingent  liabilities,  see  Note  12  –  Commitments  and 
Contingencies to the Consolidated Financial Statements.

liabilities  became  unobservable  or  observable,  respectively,  in 
the current marketplace. For more information on transfers into 
and out of Level 3 during 2020, 2019 and 2018, see Note 20 – 
Fair  Value  Measurements 
the  Consolidated  Financial 
to 
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  19  –  Income  Taxes  to  the  Consolidated  Financial 
Statements  for  a  table  of  significant  tax  attributes  and 
additional information. For more information, see Item 1A. Risk 
Factors of our 2020 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 , andNote  7  –  Goodwill  and  Intangible  Assets  to  the 
Consolidated Financial Statements. 

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Non-GAAP Reconciliations 
Tables 49 and 50 provide reconciliations of certain non-GAAP financial measures to GAAP financial measures. 

Table 49  Five-year Reconciliations to GAAP Financial Measures (1 )

(Dollars in millions, shares in thousands)

2020

2019

2018

2017

2016 

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

average tangible common shareholders’ equity 

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

Tangible shareholders’ equity

Preferred stock

Tangible common shareholders’ equity

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

year-end tangible common shareholders’ equity 

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

Tangible shareholders’ equity

Preferred stock

Tangible common shareholders’ equity

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

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

Tangible assets

(68,951)
(1,862)
821

(68,951)
(1,721)
773

$  267,309  $  267,889  $  264,748  $  271,289  $  265,843 
(69,750) 
(3,382) 
1,644 
$  197,317  $  197,990  $  194,645  $  200,814  $  194,355 
(24,656) 
$  173,693  $  174,954  $  171,696  $  176,626  $  169,699 

(69,286)
(2,652)
1,463

(68,951)
(2,058)
906

(24,188)

(22,949)

(23,036)

(23,624)

(68,951)
(2,151)
920

(68,951)
(1,661)
713

$  272,924  $  264,810  $  265,325  $  267,146  $  266,195 
(69,744) 
(2,989) 
1,545 
$  202,742  $  194,911  $  195,458  $  196,826  $  195,007 
(25,220) 
$  178,232  $  171,510  $  173,132  $  174,503  $  169,787 

(68,951)
(2,312)
943

(68,951)
(1,774)
858

(22,323)

(22,326)

(23,401)

(24,510)

$ 2,819,627  $2,434,079  $2,354,507  $2,281,234  $2,188,067 
(69,744) 
(2,989) 
1,545 
$ 2,749,445  $2,364,180  $2,284,640  $2,210,914  $2,116,879 

(68,951)
(2,312)
943

(68,951)
(1,774)
858

(68,951)
(1,661)
713

(68,951)
(2,151)
920

(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 54. 

Table 50  Quarterly Reconciliations to GAAP Financial Measures (1 )

(Dollars in millions)

Fourth

Third

Second

First

Fourth

Third

Second

First 

2020 Quarters

2019 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

$  271,020  $  267,323  $  266,316  $  264,534  $  266,900  $  270,430  $  267,975  $  266,217 

(68,951)

(2,173)

910

(68,951)

(68,951)

(1,976)

(1,640)

855

790

(68,951)

(1,655)

728

(68,951)

(68,951)

(1,678)

(1,707)

730

752

(68,951)

(1,736)

770

(68,951) 

(1,763) 

841 

$  200,806  $  197,251  $  196,515  $  194,656  $  197,001  $  200,524  $  198,058  $  196,344 

(24,180)

(23,427)

(23,427)

(23,456)

(23,461)

(23,800)

(22,537)

(22,326) 

Tangible common shareholders’ equity

$  176,626 

$  173,824  $  173,088  $  171,200  $  173,540  $  176,724  $  175,521  $  174,018 

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

$  272,924  $  268,850  $  265,637  $  264,918  $  264,810  $  268,387  $  271,408  $  267,010 

(68,951)

(2,151)

920

(68,951)

(68,951)

(2,185)

(1,630)

910

789

(68,951)

(1,646)

790

(68,951)

(68,951)

(1,661)

(1,690)

713

734

(68,951)

(1,718)

756

(68,951) 

(1,747) 

773 

$  202,742  $  198,624  $  195,845  $  195,111  $  194,911  $  198,480  $  201,495  $  197,085 

(24,510)

(23,427)

(23,427)

(23,427)

(23,401)

(23,606)

(24,689)

(22,326) 

Tangible common shareholders’ equity

$  178,232 

$  175,197  $  172,418  $  171,684  $  171,510  $  174,874  $  176,806  $  174,759 

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

Assets

Goodwill

Intangible assets (excluding MSRs)

Related deferred tax liabilities

Tangible assets

$ 2,819,627  $ 2,738,452  $2,741,688  $ 2,619,954   $ 2,434,079   $2,426,330  $ 2,395,892  $ 2,377,164 

(68,951)

(2,151)

920

(68,951)

(68,951)

(2,185)

(1,630)

910

789

(68,951)

(1,646)

790

(68,951)

(68,951)

(1,661)

(1,690)

713

734

(68,951)

(1,718)

756

(68,951) 

(1,747) 

773 

$ 2,749,445  $ 2,668,226  $2,671,896  $ 2,550,147   $ 2,364,180   $2,356,423  $ 2,325,979  $ 2,307,239 

(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 54.

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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 

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115

(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 

U.S. commercial
Non-U.S. commercial
Commercial real estate (4 )
Commercial lease financing

U.S. small business commercial (5 )

Total commercial loans excluding loans accounted for under the fair value option

Commercial loans accounted for under the fair value option (3 )

Total commercial

Less: Loans of business held for sale (6 )

Total loans and leases

2020

2019

December 31 
2018

2017

2016 

$  223,555  $  236,169  $  208,557  $  203,811  $  191,797 
66,443 
92,278 
9,214 
95,962 
626 
456,320 
1,051 
457,371 

57,744
96,285
—
96,342
166
454,348
928
455,276

48,286
98,338
—
91,166
202
446,549
682
447,231

40,208
97,608
—
90,998
192
465,175
594
465,769

34,311
78,708
—
91,363
124
428,061
735
428,796

288,728
90,460
60,364
17,098
456,650
36,469
493,119
5,946
499,065
—

270,372 
89,397 
57,355 
22,375 
439,499 
12,993 
452,492 
6,034 
458,526 
(9,214) 
$  927,861  $  983,426  $  946,895  $  936,749  $  906,683 

284,836
97,792
58,298
22,116
463,042
13,649
476,691
4,782
481,473
—

299,277
98,776
60,845
22,534
481,432
14,565
495,997
3,667
499,664
—

307,048
104,966
62,689
19,880
494,583
15,333
509,916
7,741
517,657
—

(1 )

Includes primarily auto and specialty lending loans and leases of $46.4 billion, $50.4 billion, $50.1 billion, $52.4 billion and $50.7 billion, U.S. securities-based lending loans of $41.1 billion, 
$36.7 billion, $37.0 billion, $39.8 billion and $40.1 billion and non-U.S. consumer loans of $3.0 billion, $2.8 billion, $2.9 billion, $3.0 billion and $3.0 billion at December 31, 2020, 2019, 
2018, 2017 and 2016, respectively. 

(2 ) Substantially all of other consumer at December 31, 2020, 2019, 2018 and 2017 is consumer overdrafts. Other consumer at December 31, 2016 also includes consumer finance loans of $465 

million. 

(3 ) Consumer loans accounted for under the fair value option include residential mortgage loans of $298 million, $257 million, $336 million, $567 million and $710 million, and home equity loans of 
$437 million, $337 million, $346 million, $361 million and $341 million at December 31, 2020, 2019, 2018, 2017 and 2016, respectively. Commercial loans accounted for under the fair value 
option include U.S. commercial loans of $2.9 billion, $4.7 billion, $2.5 billion, $2.6 billion and $2.9 billion, and non-U.S. commercial loans of $3.0 billion, $3.1 billion, $1.1 billion, $2.2 billion 
and $3.1 billion at December 31, 2020, 2019, 2018, 2017 and 2016, respectively. 
Includes U.S. commercial real estate loans of $57.2 billion, $59.0 billion, $56.6 billion, $54.8 billion and $54.3 billion, and non-U.S. commercial real estate loans of $3.2 billion, $3.7 billion, 
$4.2 billion, $3.5 billion and $3.1 billion at December 31, 2020, 2019, 2018, 2017 and 2016, respectively. 
Includes card-related products. 

(5 )
(6 ) Represents non-U.S. credit card loans, which were included in assets of business held for sale on the Consolidated Balance Sheet.

(4 )

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Table II  Nonperforming Loans, Leases and Foreclosed Properties (1 )

(Dollars in millions)
Consumer 

Residential mortgage
Home equity
Direct/Indirect consumer
Other consumer

Total consumer (2 )

Commercial 

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

U.S. small business commercial

Total commercial (3 )
Total nonperforming loans and leases

Foreclosed properties

2020

2019

December 31 
2018

2017

2016 

$

2,005  $

1,470  $

649
71
— 
2,725

1,243
418
404
87
2,152
75
2,227
4,952
164

536
47
—
2,053

1,094
43
280
32
1,449
50
1,499
3,552
285

1,893  $
1,893
56
 —
3,842

2,476  $
2,644
46
 —
5,166

794
80
156
18
1,048
54
1,102
4,944
300

814
299
112
24
1,249
55
1,304
6,470
288

3,056 
2,918 
28 
 2
6,004 

1,256 
279 
72 
36 
1,643 
60 
1,703 
7,707 
377 
8,084 

Total nonperforming loans, leases and foreclosed properties

$

5,116  $

3,837  $

5,244  $

6,758  $

(1 ) Balances exclude foreclosed properties insured by certain government-guaranteed loans, principally FHA-insured loans, that entered foreclosure of $119 million, $260 million, $488 million, $801 

(2 )

(3 )

million and $1.2 billion at December 31, 2020, 2019, 2018, 2017 and 2016, respectively. 
In 2020, $372 million in interest income was estimated to be contractually due on $2.7 billion of consumer loans and leases classified as nonperforming at December 31, 2020, as presented in 
the table above, plus $4.4 billion of TDRs classified as performing at December 31, 2020. Approximately $254 million of the estimated $372 million in contractual interest was received and 
included in interest income for 2020. 
In 2020, $115 million in interest income was estimated to be contractually due on $2.2 billion of commercial loans and leases classified as nonperforming at December 31, 2020, as presented 
in the table above, plus $1.0 billion of TDRs classified as performing at December 31, 2020. Approximately $71 million of the estimated $115 million in contractual interest was received and 
included in interest income for 2020. 

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

2020

2019

December 31 
2018

2017

2016 

$

$

762
903
— 
33
— 
1,698

1,088  $
1,042
—
33
—
2,163

228
10 
6
25
269
115
384

106
8
19
20
153
97
250

1,884  $

3,230  $

994
 —
38
 —
2,916

197
 —
4
29
230
84
314

900
 —
40
 —
4,170

144
 3
4
19
170
75
245

$

2,082  $

2,413  $

3,230  $

4,415  $

4,793 
782 
 66
34 
 4
5,679 

106 
 5
7 
19 
137 
71 
208 
5,887 

(1 ) Our policy is to classify consumer real estate-secured loans as nonperforming at 90 days past due, except for the fully-insured loan portfolio and loans accounted for under the fair value option. 
(2 ) Balances are fully-insured loans.

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Table IV  Selected Loan Maturity Data (1 , 2 )

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(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 )
(3 ) Loan maturities include non-U.S. commercial and commercial real estate loans. 

Includes loans accounted for under the fair value option. 

Due in One 
Year or Less 
82,577
14,073
33,196
129,846

$

$

27 %

December 31, 2020 

Due After One 
Year Through 
Five Years 

Due After 
Five Years

$

$

$

$

198,898
37,552
54,488
290,938

60 %

46,911
244,027
290,938

$

$

$

$

46,642
5,552
8,989
61,183

$

$

Total 
328,117 
57,177 
96,673 
481,967 

13 %

100 % 

32,280 
28,903 
61,183 

Table V  Allowance for Credit Losses (1 )

(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 (2 )
Direct/Indirect consumer
Other consumer

Total consumer charge-offs

U.S. commercial (3 )
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 (2 )
Direct/Indirect consumer
Other consumer

Total consumer recoveries

U.S. commercial (4 )
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 (5 )

Total allowance for loan and lease losses, December 31
Less: Allowance included in assets of business held for sale (6 )

Allowance for loan and lease losses, December 31
Reserve for unfunded lending commitments, January 1
Provision for unfunded lending commitments
Other (5 )

Reserve for unfunded lending commitments, December 31
Allowance for credit losses, December 31

2020

2019

2018

2017

2016 

$  12,358  $

9,601  $  10,393  $  11,237  $  12,234 

(40)
(58)
(2,967)
—
(372)
(307)
(3,744)
(1,163)
(168)
(275)
(69)
(1,675)
(5,419)

(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) 

70
131
618
—
250
23
1,092
178
13
5 
10 
206
1,298
(4,121)
10,565
—
18,802
— 
18,802
1,123
755
— 
1,878

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 
$  20,680  $  10,229  $  10,398  $  11,170  $  11,999

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

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

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 ) On  January  1,  2020,  the  Corporation  adopted  the  CECL  accounting  standard,  which  increased  the  allowance  for  loan  and  lease  losses  by  $2.9  billion  and  the  reserve  for  unfunded  lending 

commitments by $310 million. For more information, see Note 1 – Summary of Significant Accounting Principles to the Consolidated Financial Statements. 

(2 ) Represents amounts related to the non-U.S. credit card loan portfolio, which was sold in 2017. 
(3 )

Includes U.S. small business commercial charge-offs of $321 million, $320 million, $287 million, $258 million and $253 million in 2020, 2019, 2018, 2017 and 2016, respectively. 
Includes U.S. small business commercial recoveries of $54 million, $48 million, $47 million, $43 million and $45 million in 2020, 2019, 2018, 2017 and 2016, respectively. 

(4 )
(5 ) Primarily  represents  write-offs  of  purchased  credit-impaired  loans  for  years  prior  to  2020,  the  net  impact  of  portfolio  sales,  consolidations  and  deconsolidations,  foreign  currency  translation 

adjustments, transfers to held for sale and certain other reclassifications. 

(6 ) Represents allowance related to the non-U.S. credit card loan portfolio, which was sold in 2017.

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Table V Allowance for Credit Losses (continued)

(Dollars in millions)
Loan and allowance ratios (7) : 

Loans and leases outstanding at December 31 (8) 
Allowance for loan and lease losses as a percentage of total loans and leases outstanding 

at December 31 (8 )

Consumer allowance for loan and lease losses as a percentage of total consumer loans and 

leases outstanding at December 31 (9 )

Commercial allowance for loan and lease losses as a percentage of total commercial loans 

and leases outstanding at December 31 (10 )

Average loans and leases outstanding (8 )
Net charge-offs as a percentage of average loans and leases outstanding (8 )
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 (11 )

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 (11 )

2020

2019

2018

2017

2016

$921,180

$975,091

$942,546

$931,039

$908,812 

2.04 %

0.97 %

1.02 %

1.12 %

1.26 % 

2.35

0.98

1.08

1.18

1.36 

1.77
$974,281

0.96
$951,583

0.97
$927,531

1.05
$911,988

1.16 
$892,255 

0.42 %

0.38 %

0.41 %

0.44 %

0.43 % 

380
4.56

265
2.58

194
2.55

161
2.61

149 
3.00 

$  9,854

$  4,151

$  4,031

$  3,971

$  3,951 

181 %

148 %

113 %

99 %

98 %

(7 ) 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. 

(8 ) Outstanding  loan  and  lease  balances  and  ratios  do  not  include  loans  accounted  for  under  the  fair  value  option  of  $6.7  billion,  $8.3  billion,  $4.3  billion,  $5.7  billion  and  $7.1  billion  at 
December 31, 2020, 2019, 2018, 2017 and 2016, respectively. Average loans accounted for under the fair value option were $8.2 billion, $6.8 billion, $5.5 billion, $6.7 billion and $8.2 billion 
in 2020, 2019, 2018, 2017 and 2016, respectively. 

(9 ) Excludes consumer loans accounted for under the fair value option of $735 million, $594 million, $682 million, $928 million and $1.1 billion at December 31, 2020, 2019, 2018, 2017 and 

2016, respectively. 

(10 ) Excludes commercial loans accounted for under the fair value option of $5.9 billion, $7.7 billion, $3.7 billion, $4.8 billion and $6.0 billion at December 31, 2020, 2019, 2018, 2017 and 2016, 

respectively. 

(11 ) Primarily includes amounts related to credit card and unsecured consumer lending portfolios in Consumer Banking and, in 2017 and 2016,  the non-U.S. credit card portfolio in All Other. 

Table VI  Allocation of the Allowance for Credit Losses by Product Type (1 )

(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 (2 )
Non-U.S. commercial
Commercial real estate
Commercial lease financing

Total commercial
Total allowance for loan and lease losses

Less: Allowance included in assets of 

business held for sale (3 )

Allowance for loan and lease losses
Reserve for unfunded lending commitments

Allowance for credit losses

2020

2019

December 31 
2018

2017

2016 

Amount 

Percent 
of Total

Amount 

Percent 
of Total

Amount 

Percent 
of Total

Amount 

Percent 
of Total

Amount 

Percent 
of Total 

$ 

459
399
8,420
—
752
41
10,071
5,043
1,241
2,285
162
8,731

2.44 %  $ 
2.12
44.79
 —
4.00
0.22
53.57
26.82
6.60
12.15
0.86
46.43

18,802  100.00 %

325
221
3,710
—
234
52
4,542
3,015
658
1,042
159
4,874
9,416  100.00 %

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
9,601  100.00 % 

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 % 

15.14 
25.56 
2.12 
2.13 
0.44 
54.21 
28.97 
7.61 
8.01 
1.20 
45.79 

10,393  100.00 % 

11,480  100.00 % 

—
18,802
1,878
$ 20,680

—
9,416
813
$ 10,229

—
9,601
797
$ 10,398

—
10,393
777
$ 11,170

(243) 
11,237 
762 
$ 11,999 

(1 ) On  January  1,  2020,  the  Corporation  adopted  the  CECL  accounting  standard.  For  more  information,  see  Note  1  –  Summary  of  Significant  Accounting  Principles  to  the  Consolidated  Financial 

(2 )

Statements. 
Includes allowance for loan and lease losses for U.S. small business commercial loans of $1.5 billion, $523 million, $474 million, $439 million and $416 million at December 31, 2020, 2019, 
2018, 2017 and 2016, respectively. 

(3 ) Represents allowance for loan and lease losses related to the non-U.S. credit card loan portfolio, which was sold in 2017.

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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 and Allowance for Credit Losses
Note 6 – Securitizations and Other Variable Interest Entities
Note 7 – Goodwill and Intangible Assets
Note 8 – Leases
Note 9 – Deposits
Note 10 – Federal Funds Sold or Purchased, Securities Financing Agreements, Short-term Borrowings 

and Restricted Cash

Note 11 – Long-term Debt
Note 12 – Commitments and Contingencies
Note 13 – Shareholders’ Equity
Note 14 – Accumulated Other Comprehensive Income
Note 15 – Earnings Per Common Share
Note 16 – Regulatory Requirements and Restrictions
Note 17 – Employee Benefit Plans
Note 18 – Stock-based Compensation Plans
Note 19 – Income Taxes
Note 20 – Fair Value Measurements
Note 21 – Fair Value Option
Note 22 – Fair Value of Financial Instruments
Note 23 – Business Segment Information
Note 24 – Parent Company Information
Note 25 – Performance by Geographical Area
Glossary
Acronyms

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157

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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 
to  permit 
that 
preparation  of 
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 
the 
of  unauthorized  acquisition,  use,  or  disposition  of 
Corporation’s  assets  that  could  have  a  material  effect  on  the 
financial statements. 

recorded  as  necessary 

financial  statements 

transactions  are 

of 

the 

assessed 

Management 

effectiveness 

the 
Corporation’s  internal  control  over  financial  reporting  as  of 
December  31,  2020  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,  2020,  the  Corporation’s  internal  control  over 
financial reporting is effective. 

31, 

2020 

The  Corporation’s  internal  control  over  financial  reporting  as 
of  December 
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, 2020. 

audited 

been 

has 

Brian T. Moynihan 
Chairman, Chief Executive Officer and President 

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. 

Paul M. Donofrio 
Chief Financial Officer

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Report of Independent Registered Public Accounting Firm 

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Bank of America Corporation and Subsidiaries 

To the Board of Directors and Shareholders of Bank 
of America Corporation: 

Opinions on the Financial Statements and Internal 
Control over Financial Reporting 
We  have  audited  the  accompanying  consolidated  balance 
sheets of Bank of America Corporation and its subsidiaries (the 
“Corporation”)  as  of  December  31,  2020  and  2019,  and  the 
related  consolidated  statements  of  income,  comprehensive 
income,  changes  in  shareholders’  equity  and  cash  flows  for 
each  of  the  three  years  in  the  period  ended  December  31, 
2020, 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,  2020,  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, 2020 
and 2019, and the results of its operations and its cash flows 
for  each  of  the  three  years  in  the  period  ended  December  31, 
2020 
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, 
-
2020,  based  on  criteria  established  in  Internal  Control
Integrated Framework (2013) issued by the COSO. 

Change in Accounting Principle 
As  discussed 
financial 
to 
statements,  the  Corporation  changed  the  manner  in  which  it 
accounts  for  credit  losses  on  certain  financial  instruments  in 
2020. 

the  consolidated 

in  Note  1 

is  responsible 

Basis for Opinions 
The  Corporation’s  management 
for  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  financial  statements  are  free  of 
material  misstatement,  whether  due  to  error  or  fraud,  and 
whether  effective  internal  control  over  financial  reporting  was 
in  all  material  respects.  Our  audits  of  the 
maintained 
consolidated 
performing 
statements 
procedures to assess the risks of material 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 

included 

financial 

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 
included  obtaining  an 
reporting 
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. 

financial 

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  the  company;  (ii)  provide 
reasonable  assurance  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. 

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. 

Critical Audit Matters 
The  critical  audit  matters  communicated  below  are  matters 
arising  from  the  current  period  audit  of  the  consolidated 
financial statements that were communicated or required 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 - Commercial  and 
Consumer Card Loans 
As  described  in  Notes  1  and  5  to  the  consolidated  financial 
statements, the allowance for loan and lease losses represents 
management’s  estimate  of  the  expected  credit  losses  in  the 
Corporation’s  loan  and  lease  portfolio,  excluding  loans  and 
unfunded  lending  commitments  accounted  for  under  the  fair 
value option. As of December 31, 2020, the allowance for loan 
and lease losses was $18.8 billion on total loans and leases of

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also  included  the  involvement  of  professionals  with  specialized 
skill and knowledge to assist in evaluating the appropriateness 
of  certain 
forecast  models,  the  reasonableness  of 
economic  forecast  scenarios  and  related  weightings  and  the 
reasonableness of certain qualitative reserves. 

loss 

carries 

certain 

the  Corporation 

Valuation of Certain Level 3 Financial Instruments 
As  described  in  Notes  1  and  20  to  the  consolidated  financial 
statements, 
financial 
instruments at fair value, which includes $10.0 billion of assets 
and  $7.4  billion  of  liabilities  classified  as  Level  3  fair  value 
measurements  on  a  recurring  basis  and  $1.7  billion  of  assets 
classified as Level 3 fair value measurements on a nonrecurring 
basis,  for  which  the  determination  of  fair  value  requires 
significant  management 
The 
Corporation  determines  the  fair  value  of  Level  3  financial 
flow 
instruments  using  pricing  models,  discounted  cash 
methodologies,  or  similar  techniques  that  require  inputs  that 
are  both  unobservable  and  are  significant  to  the  overall  fair 
value measurement.  Unobservable inputs, such as volatility or 
price,  may 
quantitative-based 
extrapolations or other internal methodologies which incorporate 
management estimates and available market information. 

judgment  or  estimation. 

determined 

using 

be 

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, which in 
turn  led  to  a  high  degree  of  auditor  judgment  and  effort  in 
performing 
of 
including 
professionals  with  specialized  skill  and  knowledge  to  assist  in 
evaluating certain audit evidence. 

involvement 

procedures, 

the 

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 financial instruments 
the 
and 
independently  developed  estimate  of  fair  value.  Developing  the 
independent  estimate  involved  testing  the  completeness  and 
accuracy  of  data  provided  by  management  and  evaluating  the 
reasonableness of management’s assumptions used to develop 
the significant unobservable inputs. 

comparison  of  management’s  estimate 

to 

Charlotte, North Carolina 
February 24, 2021 

We have served as the Corporation’s auditor since 1958.

include 

through 

variables 

information 

$921.2  billion,  which  excludes  loans  accounted  for  under  the 
fair value option. For commercial and consumer card loans, the 
expected  credit  loss  is  estimated  using  quantitative  methods 
that  consider  a  variety  of  factors  such  as  historical  loss 
experience, the current credit quality of the portfolio as well as 
an  economic  outlook  over  the  life  of  the  loan.  In  its  loss 
forecasting  framework,  the  Corporation  incorporates  forward 
looking 
the  use  of  macroeconomic 
scenarios applied over the forecasted life of the assets. These 
macroeconomic  scenarios 
that  have 
historically  been  key  drivers  of  increases  and  decreases  in 
credit  losses.  These  variables  include,  but  are  not  limited  to, 
unemployment rates, real estate prices, gross domestic product 
levels  and  corporate  bond  spreads.  The  scenarios  that  are 
chosen  and  the  amount  of  weighting  given  to  each  scenario 
depend on a variety of factors including recent economic events, 
leading  economic  indicators,  views  of  internal  as  well  as  third-
party  economists  and  industry  trends.  Also  included  in  the 
allowance  for  loan  losses  are  qualitative  reserves  to  cover 
losses that are expected but, in the Corporation's assessment, 
may not be adequately reflected in the quantitative methods or 
the  economic  assumptions.  Factors  that  the  Corporation 
considers  include  changes  in  lending  policies  and  procedures, 
business  conditions,  the  nature  and  size  of  the  portfolio, 
portfolio  concentrations,  the  volume  and  severity  of  past  due 
loans and nonaccrual loans, the effect of external factors such 
as  competition,  and  legal  and  regulatory  requirements,  among 
inherent 
others.  Further, 
uncertainty  in  quantitative  models  that  are  built  on  historical 
data. 

the  Corporation  considers 

the 

The  principal  considerations  for  our  determination  that 
performing  procedures  relating  to  the  allowance  for  loan  and 
lease losses for the commercial and consumer card portfolios is 
a  critical  audit  matter  are  (i)  the  significant  judgment  and 
estimation  by  management  in  developing  lifetime  economic 
forecast  scenarios,  related  weightings  to  each  scenario  and 
certain qualitative reserves, which in turn led to a high degree of 
in  performing 
auditor 
procedures  and  in  evaluating  audit  evidence  obtained,  and  (ii) 
the audit effort involved professionals with specialized skill and 
knowledge to assist in evaluating certain audit evidence. 

judgment,  subjectivity  and  effort 

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,  including 
controls  over  the  evaluation  and  approval  of  models,  forecast 
scenarios  and  related  weightings,  and  qualitative  reserves. 
testing 
These  procedures  also 
management’s  process  for  estimating  the  allowance  for  loan 
losses,  including  (i)  evaluating  the  appropriateness  of  the  loss 
the 
forecast  models  and  methodology, 
(ii)  evaluating 
reasonableness  of  certain  macroeconomic  variables, 
(iii) 
evaluating  the  reasonableness  of  management’s  development, 
selection and weighting of economic forecast scenarios used in 
the  loss  forecast  models,  (iv)  testing  the  completeness  and 
accuracy of data used in the estimate, and (v) evaluating certain 
qualitative  reserves  made  to  the  model  output  results  to 
determine the overall allowance for loan losses. The procedures 

included,  among  others, 

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Bank of America Corporation and Subsidiaries 

Consolidated Statement of Income 

(In millions, except per share information)
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

62539financials

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2020

2019

2018 

$

$

51,585
8,225
43,360

71,236  $
22,345
48,891

66,769 
18,607 
48,162 

34,551
8,355
(738)
42,168
85,528

11,320

32,725
7,141
5,222
3,433
1,701
1,694
3,297
55,213
18,995
1,101

33,015
9,034
304
42,353
91,244

33,078 
9,008 
772 
42,858 
91,020 

3,590

3,282 

31,977
6,588
4,646
2,762
1,934
1,597
5,396
54,900
32,754
5,324

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 

17,894  $

27,430  $

1,421

1,432

16,473  $

25,998  $

$

$

$

1.88  $
1.87
8,753.2
8,796.9

2.77  $
2.75
9,390.5
9,442.9

2.64 
2.61 
10,096.5 
10,236.9 

2020

2019

2018 

$

17,894  $

27,430  $

28,147 

4,799
(498)
826
(98)
(52)
4,977

5,875
(963)
616
136
(86)
5,578

$

22,871  $

33,008  $

(3,953) 
749 
(53) 
(405) 
(254) 
(3,916) 
24,231

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See accompanying Notes to Consolidated Financial Statements.

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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 $108,856 and $50,364 measured at fair value)

Trading account assets (includes $91,510 and $90,946 pledged as collateral)
Derivative assets
Debt securities: 

Carried at fair value
Held-to-maturity, at cost (fair value – $448,180 and $219,821)

Total debt securities

Loans and leases (includes $6,681 and $8,335 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 $1,585 and $3,709 measured at fair value)
Customer and other receivables
Other assets (includes $15,718 and $15,518 measured at fair value)

Total assets

Liabilities 
Deposits in U.S. offices: 
Noninterest-bearing
Interest-bearing (includes $481 and $508 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 $135,391 and $16,008 measured at fair value)

Trading account liabilities
Derivative liabilities
Short-term borrowings (includes $5,874 and $3,941 measured at fair value)
Accrued expenses and other liabilities (includes $16,311 and $15,434 measured at fair value
  and  $1,878 and $813 of reserve for unfunded lending commitments)
Long-term debt (includes $32,200 and $34,975 measured at fair value)

Total liabilities

Commitments and contingencies (Note 6 – Securitizations and Other Variable Interest Entities 

and Note 12 – Commitments and Contingencies) 

Shareholders’ equity 
Preferred stock, $0.01 par value; authorized – 100,000,000 shares; issued and outstanding – 3,931,440 and 3,887,440 shares
Common stock and additional paid-in capital, $0.01  par value; authorized – 12,800,000,000 shares; 

issued and outstanding – 8,650,814,105  and 8,836,148,954 shares

Retained earnings
Accumulated other comprehensive income (loss)

Total shareholders’ equity
Total liabilities and shareholders’ equity

Assets of consolidated variable interest entities included in total assets above (isolated to settle the liabilities of the variable interest entities) 
Trading account assets
Loans and leases
Allowance for loan and lease losses

Loans and leases, net of allowance

All other assets

Total assets of consolidated variable interest entities

Liabilities of consolidated variable interest entities included in total liabilities above 

Short-term borrowings (includes $22 and $0 of non-recourse short-term borrowings)

Long-term debt (includes $7,053 and $8,717 of non-recourse debt)

All other liabilities (includes $16 and $19 of non-recourse liabilities)

Total liabilities of consolidated variable interest entities

See accompanying Notes to Consolidated Financial Statements.

62539financials

121

December 31 

2020

2019 

$

36,430  $

344,033
380,463
6,546

304,058
198,854
47,179

30,152 
131,408 
161,560 
7,107 

274,597 
229,826 
40,485 

246,601
438,249
684,850
927,861
(18,802)
909,059
11,000
68,951
9,243
64,221
135,203

256,467 
215,730 
472,197 
983,426 
(9,416) 
974,010 
10,561 
68,951 
9,158 
55,937 
129,690 
$  2,819,627  $  2,434,079 

$

650,674  $

1,038,341

403,305 
940,731 

17,698
88,767
1,795,480

170,323
71,320
45,526
19,321

181,799
262,934
2,546,703

13,719 
77,048 
1,434,803 

165,109 
83,270 
38,229 
24,204 

182,798 
240,856 
2,169,269 

24,510

23,401 

85,982
164,088
(1,656)
272,924

91,723 
156,319 
(6,633) 
264,810 
$  2,819,627  $  2,434,079 

$

$

$

$

5,225 
23,636
(1,693)
21,943
1,387
28,555 

454 

7,053

16
7,523 

$

$

$

$

5,811
38,837 
(807) 
38,030 
540 
44,381 

2,175

8,718 

22 
10,915

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Bank of America Corporation and Subsidiaries
Bank of America Corporation and Subsidiaries
Bank of America Corporation and Subsidiaries

Consolidated Statement of Changes in Shareholders’ Equity
Consolidated Statement of Changes in Shareholders’ Equity 

Prefe 
Sto 

rred 
ck 
2,323

$  2

Common Stock and 
Additional Paid-in Capital
Shares
Amount 
10,287.3  $

138,089  $

Accumulated 
Other 
Comprehensive 
Income (Loss) 

Total 
Shareholders’ 
Equity

Retained 
Earnings 

113,816  $

(7,082)  $

267,146 

(32)

57

25 

(In millions) 
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

Issuance of preferred stock
Redemption of preferred stock
Common stock issued under employee plans, net, and other
Common stock repurchased
Balance, December 31, 2019
Cumulative adjustment for adoption of credit loss 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

4,515
(4,512)

58.2
(676.2)

$  22,326

9,669.3  $

901
(20,094)
118,896  $

3,643
(2,568)

123.3
(956.5)

$  23,401

8,836.1  $

971
(28,144)
91,723  $

Issuance of preferred stock
Redemption of preferred stock
Common stock issued under employee plans, net, and other
Common stock repurchased
Balance, December 31, 2020

2,181
(1,072)

41.7
(227.0)

$  24,510

8,650.8  $

1,284
(7,025)
85,982  $

(1,270)

(3,953)
749
(53)
(405)
(254)

1,270
28,147

(5,424)
(1,451)

(12)

136,314  $

(12,211)  $

5,875
(963)
616
136
(86)

165
27,430

(6,146)
(1,432)

(12)

156,319  $

(6,633)  $

4,799
(498)
826
(98)
(52)

(2,406)
17,894

(6,289)
(1,421)

(9)

— 
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 

(2,406) 
17,894 
4,799 
(498) 
826 
(98) 
(52) 

(6,289) 
(1,421) 
2,181 
(1,072) 
1,275 
(7,025) 

164,088  $

(1,656)  $

272,924

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See accompanying Notes to Consolidated Financial Statements.
See accompanying Notes to Consolidated Financial Statements.

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Bank of America Corporation and Subsidiaries
Bank of America Corporation and Subsidiaries
Bank of America Corporation and Subsidiaries

Consolidated Statement of Cash Flows
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

62539financials

123

2020

2019

2018 

$

17,894  $

27,430  $

28,147 

11,320
(411)
1,843
4,101
(1,737)
2,031
—

3,590
(217)
1,729
2,066
2,435
1,974
2,072

3,282 
(154) 
2,063 
1,824 
3,041 
1,729 
— 

(19,657)

(28,874)

(28,071) 

19,049

30,191

28,972 

16,942
(12,883)
(4,385)
3,886
37,993

561
(29,461)

77,524
91,084
(194,877)

93,835
(257,535)

13,351
(5,229)
36,571
(3,489)
(177,665)

360,677
5,214
(4,893)

57,013
(47,948)

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)

2,181
(1,072)
(7,025)
(7,727)
(601)
355,819
2,756
218,903
161,560
380,463  $

3,643
(2,568)
(28,144)
(5,934)
(698)
3,377
(368)
(15,844)
177,404
161,560  $

(23,673) 
11,920 
13,010 
(2,570) 
39,520 

3,659 
(48,384) 

5,117 
78,513 
(76,640) 

18,789 
(35,980) 

21,365 
(4,629) 
(31,292) 
(1,986) 
(71,468) 

71,931 
10,070 
(12,478) 

64,278 
(53,046) 

4,515 
(4,512) 
(20,094) 
(6,895) 
(651) 
53,118 
(1,200) 
19,970 
157,434 
177,404 

8,662  $
2,894

22,196  $

4,359

19,087 
2,470

$

$

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122 Bank of America 2020
122 Bank of America 2020

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See accompanying Notes to Consolidated Financial Statements.
See accompanying Notes to Consolidated Financial Statements.
See accompanying Notes to Consolidated Financial Statements.
See accompanying Notes to Consolidated Financial Statements.

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Bank of America Corporation and Subsidiaries 
Notes to Consolidated Financial Statements 

NOTE 1 Summary of Significant Accounting 
Principles 
Bank  of  America  Corporation,  a  bank  holding  company  and  a 
financial holding company, provides a diverse range of financial 
services  and  products  throughout  the  U.S.  and  in  certain 
international  markets.  The  term  “the  Corporation”  as  used 
herein  may  refer  to  Bank  of  America  Corporation,  individually, 
Bank  of  America  Corporation  and  its  subsidiaries,  or  certain  of 
Bank of America Corporation’s subsidiaries or affiliates. 

Principles of Consolidation and Basis of Presentation 
The Consolidated Financial Statements include the accounts of 
the  Corporation  and  its  majority-owned  subsidiaries  and  those 
variable  interest  entities  (VIEs)  where  the  Corporation  is  the 
primary  beneficiary.  Intercompany  accounts  and  transactions 
have  been  eliminated.  Results  of  operations  of  acquired 
companies  are  included  from  the  dates  of  acquisition,  and  for 
VIEs,  from  the  dates  that  the  Corporation  became  the  primary 
beneficiary.  Assets  held  in  an  agency  or  fiduciary  capacity  are 
not  included  in  the  Consolidated  Financial  Statements.  The 
Corporation accounts for investments in companies for which it 
owns a voting interest and for which it has the ability to exercise 
significant  influence  over  operating  and  financing  decisions 
using  the  equity  method  of  accounting.  These  investments  are 
included in other assets. Equity method investments are subject 
to  impairment  testing,  and  the  Corporation’s  proportionate 
share of income or loss is included in other income. 

The preparation of the Consolidated Financial Statements in 
conformity  with  accounting  principles  generally  accepted  in  the 
United  States  of  America  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. 

New Accounting Standards 

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 (ECL) 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.  Prior  to 
January  1,  2020,  the  allowance 
losses  was 
determined  based  on  management’s  estimate  of  probable 
incurred losses. 

for  credit 

Reference Rate Reform 
The Financial Accounting Standards Board (FASB) issued a new 
accounting  standard  in  March  2020,  which  was  subsequently 
amended  in  January  2021,  related  to  contracts  or  hedging 
relationships  that  reference  London  Interbank  Offered  Rate 
(LIBOR)  or  other  reference  rates  that  are  expected  to  be 
discontinued  due  to  reference  rate  reform.  The  new  standard 
provides  for  optional  expedients  and  other  guidance  regarding 
the  accounting  related  to  modifications  of  contracts,  hedging 

124
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relationships  and  other  transactions  affected  by  reference  rate 
reform. The Corporation has elected to retrospectively adopt the 
new standard as of January 1, 2020. The adoption did not have 
a material accounting impact on the Corporation’s consolidated 
financial position or results of operations; however, it did  ease 
the  administrative  burden  in  accounting  for  certain  effects  of 
reference rate reform. 

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 
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. 

regulations,  and  amounts  due 

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 
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 
to 
counterparties  when 
financing 
agreements  do  not  create  material  credit  risk  due  to  these 
collateral provisions; therefore, an allowance for loan losses is 
not necessary. 

return  collateral  pledged 

appropriate.  Securities 

from  or 

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,  2020  and  2019,  the  fair  value  of  this  collateral 
was  $812.4  billion  and  $693.0  billion,  of  which  $758.5  billion 
and  $593.8  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.

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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. 

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  include  derivatives  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 
risk  management  activities).  The 
(referred 
foreign  currency 
Corporation  manages 
exchange  rate  sensitivity  predominantly  through  the  use  of 
derivatives.  Derivatives  utilized  by  the  Corporation  include 
swaps,  futures  and  forward  settlement  contracts,  and  option 
contracts. 

to  as  other 

rate  and 

interest 

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 
flow  methodologies  or  similar 
models,  discounted  cash 
techniques for which the determination of fair value may require 
significant management judgment or estimation. 

Valuations  of  derivative  assets  and  liabilities  reflect  the 
value of the instrument including counterparty credit risk. These 
values  also  take  into  account  the  Corporation’s  own  credit 
standing. 

Trading Derivatives and Other Risk Management Activities 
Derivatives  held  for  trading  purposes  are  included  in  derivative 
assets  or  derivative  liabilities  on  the  Consolidated  Balance 
Sheet with changes in fair value included in 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 

62539financials

125

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. 

for  undertaking 

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 
various  accounting  hedges. 
strategies 
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 
forecasted  transaction.  The 
item  or 
flows  of  a  hedged 
Corporation  discontinues  hedge  accounting  when 
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. 

it 

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-bearing 
liabilities, such adjustments are amortized to earnings over the 
remaining life of the respective asset or liability. 

interest-earning  assets  and 

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 
income  (OCI)  and  are  reclassified  into  the  line  item  in  the 
income  statement  in  which  the  hedged  item  is  recorded  in  the 
same period the hedged item affects earnings. Components of 
a derivative that are excluded in assessing hedge effectiveness 
are  recorded  in  the  same  income  statement  line  item  as  the 
hedged item. 

Net  investment  hedges  are  used  to  manage  the  foreign 
exchange  rate  sensitivity  arising  from  a  net  investment  in  a 
foreign operation. Changes in the spot prices of derivatives that 
are designated as net investment hedges of foreign operations 
are  recorded  as  a  component  of  accumulated  OCI.  The 
remaining  components  of  these  derivatives  are  excluded  in

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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 asset and liability management (ALM) 
activities  and  are  reported  on  the  Consolidated  Balance  Sheet 
as  either  debt  securities  carried  at  fair  value  or  as  held-to-
maturity  (HTM)  debt  securities.  Debt  securities  carried  at  fair 
value  are  either  available-for-sale 
(AFS)  securities  with 
unrealized  gains  and  losses  net-of-tax  included  in  accumulated 
OCI  or  carried  at  fair  value  with  unrealized  gains  and  losses 
reported  in  market  making  and  similar  activities.  HTM  debt 
securities  are  debt  securities  that  management  has  the  intent 
and  ability  to  hold  to  maturity  and  are  reported  at  amortized 
cost. 

The Corporation evaluates each AFS security where the value 
has declined below amortized cost. 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 through 
earnings.  For  AFS  debt  securities  the  Corporation  intends  to 
hold,  the  Corporation  evaluates  the  debt  securities  for  ECL 
except  for  debt  securities  that  are  guaranteed  by  the  U.S. 
Treasury, U.S. government agencies or sovereign entities of high 
credit  quality  where  the  Corporation  applies  a  zero  credit  loss 
assumption.  For  the  remaining  AFS  debt  securities,  the 
Corporation  considers  qualitative  parameters  such  as  internal 
and external credit ratings and the value of underlying collateral. 
If an AFS debt security fails any of the qualitative parameters, a 
discounted  cash  flow  analysis  is  used  by  the  Corporation  to 
determine  if  a  portion  of  the  unrealized  loss  is  a  result  of  an 
expected credit loss. The Corporation will then recognize either 
credit loss expense or a reversal of credit loss expense in other 
income  for  the  amount  necessary  to  adjust  the  debt  securities 
valuation  allowance  to  its  current  estimate  of  excepted  credit 
losses.  Cash  flows  expected  to  be  collected  are  estimated 
using  all  relevant  information  available  such  as  remaining 
payment  terms,  prepayment  speeds,  the  financial  condition  of 
the  issuer,  expected  defaults  and  the  value  of  the  underlying 
collateral. 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 allowance recorded is limited to 
the difference between the amortized cost and the fair value of 
the asset. 

The Corporation separately evaluates its HTM debt securities 
for  any  credit  losses,  of  which  substantially  all  qualify  for  the 
zero  loss  assumption.  For  the  remaining  securities,  the 
Corporation  performs  a  discounted  cash  flow  analysis  to 
estimate any credit losses which are then recognized as part of 
the allowance for credit losses. 

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. 

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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 

for  purchased 

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,  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. 
for 
Under  applicable  accounting  guidance, 

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 includes both the allowance for 
loan  and  lease  losses  and  the  reserve  for  unfunded  lending 
commitments  and  represents  management’s  estimate  of  the 
ECL  in  the  Corporation’s  loan  and  lease  portfolio,  excluding 
loans  and  unfunded  lending  commitments  accounted  for  under 
the  fair  value  option.  The  ECL  on  funded  consumer  and 
commercial loans and leases is referred to as the allowance for 
loan  and  lease  losses  and  is  reported  separately  as  a  contra-
asset to loans and leases on the Consolidated Balance Sheet. 
The  ECL  for  unfunded  lending  commitments,  including  home

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equity lines of credit (HELOCs), standby letters of credit (SBLCs) 
and  binding  unfunded  loan  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. 

For  loans  and  leases,  the  ECL  is  typically  estimated  using 
quantitative methods that consider a variety of factors such as 
historical  loss  experience,  the  current  credit  quality  of  the 
portfolio  as  well  as  an  economic  outlook  over  the  life  of  the 
loan. The life of the loan for closed-ended products is based on 
the  contractual  maturity  of  the  loan  adjusted  for  any  expected 
prepayments.  The  contractual  maturity  includes  any  extension 
options that are at the sole discretion of the borrower. For open-
ended  products  (e.g.,  lines  of  credit),  the  ECL  is  determined 
based  on  the  maximum repayment  term associated  with  future 
draws  from  credit  lines  unless  those  lines  of  credit  are 
unconditionally cancellable (e.g., credit cards) in which case the 
Corporation does not record any allowance. 

In 

its 

loss 

framework, 

forecasting 

the  Corporation 
incorporates  forward-looking  information  through  the  use  of 
macroeconomic scenarios applied over the forecasted life of the 
assets.  These  macroeconomic  scenarios  include  variables  that 
have historically been key drivers of increases and decreases in 
credit  losses.  These  variables  include,  but  are  not  limited  to, 
unemployment rates, real estate prices, gross domestic product 
levels  and  corporate  bond  spreads.  As  any  one  economic 
outlook  is  inherently  uncertain,  the  Corporation  leverages 
multiple scenarios. The scenarios that are chosen each quarter 
and the weighting given to each scenario depend on a variety of 
factors  including  recent  economic  events,  leading  economic 
indicators,  views  of  internal  and  third-party  economists  and 
industry trends. 

The  estimate  of  credit  losses  includes  expected  recoveries 
of amounts previously charged off (i.e., negative allowance). If a 
loan has been charged off, the expected cash flows on the loan 
are  not  limited  by  the  current  amortized  cost  balance.  Instead, 
expected cash flows can be assumed up to the unpaid principal 
balance immediately prior to the charge-off. 

The  allowance  for  loan  and  lease  losses  for  troubled  debt 
restructurings (TDR) is measured based on the present value of 
projected  future  lifetime  principal  and  interest  cash  flows 
discounted  at  the  loan’s  original  effective  interest  rate,  or  in 
cases  where  foreclosure  is  probable  or  the  loan  is  collateral 
dependent,  at  the  loan’s  collateral  value  or  its  observable 
market  price,  if  available.  The  measurement  of  ECL  for  the 
renegotiated consumer credit card TDR portfolio is based on the 
present  value  of  projected  cash  flows  discounted  using  the 
average  TDR  portfolio  contractual  interest  rate,  excluding 
promotionally  priced  loans,  in  effect  prior  to  restructuring. 
Projected cash flows for TDRs use the same economic outlook 
as  discussed  above.  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. 

Also included in the allowance for loan and lease losses are 
qualitative reserves to cover losses that are expected but, in the 
Corporation's  assessment,  may  not  be  adequately  reflected  in 
the  quantitative  methods  or 
the  economic  assumptions 
described  above.  For  example,  factors  that  the  Corporation 
considers  include  changes  in  lending  policies  and  procedures, 
business  conditions,  the  nature  and  size  of  the  portfolio, 
portfolio  concentrations,  the  volume  and  severity  of  past  due 
loans and nonaccrual loans, the effect of external factors such 
as  competition,  and  legal  and  regulatory  requirements,  among 

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inherent 
others.  Further, 
uncertainty  in  quantitative  models  that  are  built  on  historical 
data. 

the  Corporation  considers 

the 

generally 

With the exception of the Corporation's credit card portfolio, 
the Corporation does not include reserves for interest receivable 
in  the  measurement  of  the  allowance  for  credit  losses  as  the 
Corporation 
as 
classifies 
nonperforming  at  90  days  past  due  and  reverses  interest 
income  for  these  loans  at  that  time.  For  credit  card  loans,  the 
Corporation  reserves  for  interest  and  fees  as  part  of  the 
allowance for loan and lease losses. Upon charge-off of a credit 
card loan, the Corporation reverses the interest and fee income 
against  the  income  statement  line  item  where  it  was  originally 
recorded. 

consumer 

loans 

The  Corporation  has  identified  the  following  three  portfolio 
segments  and  measures  the  allowance  for  credit  losses  using 
the following methods. 

using 

prepayments, 

Consumer Real Estate 
To estimate ECL for consumer loans secured by residential real 
estate, the Corporation estimates the number of loans that will 
default  over  the  life  of  the  existing  portfolio,  after  factoring  in 
estimated 
quantitative  modeling 
methodologies.  The  attributes  that  are  most  significant  in 
estimating the Corporation’s ECL 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  estimates  are  based  on  the 
Corporation’s  historical  experience  with  the  loan  portfolio, 
adjusted  to  reflect  the  economic  outlook.  The  outlook  on  the 
unemployment  rate  and  consumer  real  estate  prices  are  key 
factors that impact the frequency and severity of loss estimates. 
The  Corporation  does  not  reserve  for  credit  losses  on  the 
unpaid  principal  balance  of  loans  insured  by  the  Federal 
Housing  Administration  (FHA)  and  long-term  standby  loans,  as 
these loans are fully insured. The Corporation records a reserve 
for unfunded lending commitments for the ECL associated with 
the  undrawn  portion  of  the  Corporation’s  HELOCs,  which  can 
only  be  canceled  by  the  Corporation  if  certain  criteria  are  met. 
The  ECL  associated  with  these  unfunded  lending  commitments 
is calculated using the same models and methodologies noted 
above  and  incorporate  utilization  assumptions  at  time  of 
default. 

loans 

these 

For  loans  that  are  more  than  180  days  past  due  and 
collateral-dependent TDRs, the Corporation bases the allowance 
on the estimated fair value of the underlying collateral as of the 
reporting date less costs to sell. The fair value of the collateral 
securing 
is  generally  determined  using  an 
automated valuation model (AVM) that estimates the value of a 
property  by  reference  to  market  data  including  sales  of 
comparable  properties  and  price 
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 
these 
valuations, the Corporation believes that they are representative 
of this portfolio in the aggregate. 

trends  specific 

imprecision 

inherent 

there 

to 

in 

is 

For  loans  that  are  more  than  180  days  past  due  and 
collateral-dependent  TDRs,  with 
the 
Corporation’s fully insured portfolio, the outstanding balance of 
loans  that  is  in  excess  of  the  estimated  property  value  after

the  exception  of 

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adjusting  for  costs  to  sell  is  charged  off.  If  the  estimated 
property  value  decreases  in  periods  subsequent  to  the  initial 
charge-off,  the  Corporation  will  record  an  additional  charge-off; 
however,  if  the  value  increases  in  periods  subsequent  to  the 
charge-off, the Corporation will adjust the allowance to account 
for the increase but not to a level above the cumulative charge-
off amount. 

Credit Cards and Other Consumer 
Credit  cards  are  revolving  lines  of  credit  without  a  defined 
maturity  date.  The  estimated  life  of  a  credit  card  receivable  is 
determined  by  estimating  the  amount  and  timing  of  expected 
future  payments 
full  payments, 
(e.g.,  borrowers  making 
minimum  payments  or  somewhere  in  between)  that  it  will  take 
for  a  receivable  balance  to  pay  off.  The  ECL  on  the  future 
payments  incorporates  the  spending  behavior  of  a  borrower 
through  time  using  key  borrower-specific  factors  and  the 
economic  outlook  described  above.  The  Corporation  applies  all 
expected  payments 
in  accordance  with  the  Credit  Card 
Accountability  Responsibility  and  Disclosure  Act  of  2009  (i.e., 
paying  down  the  highest  interest  rate  bucket  first).  Then 
forecasted future payments are prioritized to pay off the oldest 
balance  until  it  is  brought  to  zero  or  an  expected  charge-off 
amount.  Unemployment  rate  outlook,  borrower  credit  score, 
delinquency  status  and  historical  payment  behavior  are  all  key 
inputs  into  the  credit  card  receivable  loss  forecasting  model. 
Future draws on the credit card lines are excluded from the ECL 
as they are unconditionally cancellable. 

The  ECL  for  the  consumer  vehicle  lending  portfolio  is  also 
determined  using  quantitative  methods  supplemented  with 
qualitative  analysis.  The  quantitative  model  estimates  ECL 
giving  consideration  to  key  borrower  and  loan  characteristics 
such  as  delinquency  status,  borrower  credit  score,  LTV  ratio, 
underlying collateral type and collateral value. 

Commercial 
The  ECL  on  commercial  loans  is  forecasted  using  models  that 
estimate  credit  losses  over  the  loan’s  contractual  life  at  an 
individual  loan  level.  The  models  use  the  contractual  terms  to 
forecast  future  principal  cash  flows  while  also  considering 
expected  prepayments.  For  open-ended  commitments  such  as 
revolving lines of credit, changes in funded balance are captured 
by forecasting a borrower’s draw and payment behavior over the 
remaining  life  of  the  commitment.  For  loans  collateralized  with 
commercial real estate and for which the underlying asset is the 
primary  source  of  repayment,  the  loss  forecasting  models 
consider  key  loan  and  customer  attributes  such  as  LTV  ratio, 
net  operating  income  and  debt  service  coverage,  and  captures 
variations in behavior according to property type and region. The 
outlook on the unemployment rate, gross domestic product, and 
forecasted real estate prices are utilized to determine indicators 
such  as  rent  levels  and  vacancy  rates,  which  impact  the  ECL 
estimate.  For  all  other  commercial  loans  and  leases,  the  loss 
forecasting  model  determines  the  probabilities  of  transition  to 
different credit risk ratings or default at each point over the life 
of the asset based on the borrower’s current credit risk rating, 
industry sector, size of the exposure and the geographic market. 
The  severity  of  loss  is  determined  based  on  the  type  of 
collateral  securing  the  exposure,  the  size  of  the  exposure,  the 
borrower’s  industry  sector,  any  guarantors  and  the  geographic 
market.  Assumptions  of  expected  loss  are  conditioned  to  the 
economic  outlook,  and  the  model  considers  key  economic 
variables  such  as  unemployment  rate, gross  domestic product, 
corporate bond spreads, real estate and other asset prices and 
equity market returns. 

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In  addition  to  the  allowance  for  loan  and  lease  losses,  the 
Corporation  also  estimates  ECL  related  to  unfunded  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. Reserves are estimated for the unfunded exposure using 
the  same  models  and  methodologies  as  the  funded  exposure 
and  are 
lending 
reserves 
commitments. 

for  unfunded 

reported  as 

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  FHA  or  through 
individually  insured  long-term  standby  agreements  with  Fannie 
Mae (FNMA) or Freddie Mac (FHLMC) (the fully-insured portfolio). 
Residential mortgage loans in the fully-insured portfolio are not 
placed on nonaccrual status and, therefore, are not reported as 
nonperforming.  Junior-lien  home  equity  loans  are  placed  on 
nonaccrual  status  and  classified  as  nonperforming  when  the 
underlying  first-lien  mortgage  loan  becomes  90  days  past  due 
even if the junior-lien loan is current. The outstanding balance of 
real  estate-secured  loans  that  is  in  excess  of  the  estimated 
property value less costs to sell is charged off no later than the 
end of the month in which the loan becomes 180 days past due 
unless the loan is fully insured, or for loans in bankruptcy, within 
60  days  of  receipt  of  notification  of  filing,  with  the  remaining 
balance classified as nonperforming. 

Consumer  loans  secured  by  personal  property,  credit  card 
loans  and  other  unsecured  consumer  loans  are  not  placed  on 
nonaccrual  status  prior  to  charge-off  and,  therefore,  are  not 
reported  as  nonperforming  loans,  except  for  certain  secured 
consumer  loans,  including  those  that  have  been  modified  in  a 
TDR. Personal property-secured loans (including auto loans) are 
charged  off  to  collateral  value  no  later  than  the  end  of  the 
month  in  which  the  account  becomes  120  days  past  due,  or 
upon repossession of an auto or, for loans in bankruptcy, within 
60 days of receipt of notification of filing. Credit card and other 
unsecured customer loans are charged off no later than the end 
of the month in which the account becomes 180 days past due, 
within  60  days  after  receipt  of  notification  of  death  or 
bankruptcy, or upon confirmation of fraud. 

Commercial  loans  and  leases,  excluding  business  card 
loans,  that  are  past  due  90  days  or  more  as  to  principal  or 
interest,  or  where  reasonable  doubt  exists  as  to  timely 
collection,  including  loans  that  are  individually  identified  as 
being  impaired,  are  generally  placed  on  nonaccrual  status  and 
classified  as  nonperforming  unless  well-secured  and  in  the 
process of collection. 

Business card loans are charged off in the same manner as 
consumer credit card loans. 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

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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 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. 

COVID-19 Programs 
The  Corporation  has  implemented  various  consumer  and 
commercial loan modification programs to provide its borrowers 
relief from the economic impacts of the COVID-19 pandemic (the 
pandemic).  In  accordance  with  the  Coronavirus  Aid,  Relief,  and 
Economic Security Act (CARES Act), the Corporation has elected 
to not apply TDR classification to eligible COVID-19 related loan 
modifications that were performed after March 1, 2020 to loans 
that were current as of December 31, 2019. Accordingly, these 
restructurings are not classified as TDRs. The availability of this 
election expires upon the earlier of January 1, 2022 or 60 days 
after  the national emergency related to COVID-19 terminates. In 

that 

addition, for loans modified in response to the pandemic that do 
not  meet  the  above  criteria  (e.g.,  current  payment  status  at 
December  31,  2019),  the  Corporation  is  applying  the  guidance 
included  in  an  interagency  statement  issued  by  the  bank 
regulatory  agencies.  This  guidance  states 
loan 
modifications performed in light of the pandemic, including loan 
payment  deferrals  that  are  up  to  six  months  in  duration,  that 
were  granted  to  borrowers  who  were  current  as  of  the 
implementation  date  of  a 
loan  modification  program  or 
modifications granted under government mandated modification 
programs,  are  not  TDRs.  For  loan  modifications  that  include  a 
payment deferral and are not TDRs, the borrowers' past due and 
nonaccrual  status  have  not  been  impacted  during  the  deferral 
period. The Corporation has continued to accrue interest during 
the deferral period using a constant effective yield method. For 
most mortgage, HELOC and commercial loan modifications, the 
contractual  interest  that  accrued  during  the  deferral  period  is 
payable  at  the  maturity  of  the  loan.  The  Corporation  includes 
these  amounts  with  the  unpaid  principal  balance  when 
computing  its  allowance  for  credit  losses.  Amounts  that  are 
subsequently  deemed  uncollectible  are  written  off  against  the 
allowance for credit losses. 

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. 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, upon the sale of a loan, are recognized 
as part of the gain or loss in noninterest income. 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. 

federal 

Other Assets 
For  the  Corporation’s  financial  assets  that  are  measured  at 
amortized cost and are not included in debt securities or loans 
and leases on the Consolidated Balance Sheet, the Corporation 
evaluates  these  assets  for  ECL  using  various  techniques.  For 
assets  that  are  subject  to  collateral  maintenance  provisions, 
including 
funds  sold  and  securities  borrowed  or 
purchased  under  agreements  to  resell,  where  the  collateral 
consists  of  daily  margining  of  liquid  and  marketable  assets 
where  the  margining  is  expected  to  be  maintained  into  the 
foreseeable  future,  the  expected  losses  are  assumed  to  be 
zero.  For  all  other  assets,  the  Corporation  performs  qualitative 
analyses,  including  consideration  of  historical  losses  and 
current  economic  conditions,  to  estimate  any  ECL  which  are 
then  included  in  a  valuation  account  that  is  recorded  as  a 
contra-asset  against  the  amortized  cost  basis  of  the  financial 
asset.

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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 
liabilities  are  recognized  based  on  the  present  value  of  the 
remaining 
the 
Corporation’s  incremental  borrowing  rate.  Right-of-use  assets 
initially equal the lease liability, adjusted for any lease payments 
made  prior  to  lease  commencement  and  for  any  lease 
incentives. 

lease  payments  and  discounted  using 

lease  commencement, 

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 

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. 

its  goodwill 

impairment 

testing, 

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.  The  Corporation  has  an 
unconditional  option  to  bypass  the  qualitative  assessment  for 
any  reporting  unit  in  any  period  and  proceed  directly  to 
performing  the  quantitative  goodwill  impairment  test.  The 
Corporation may resume performing the qualitative assessment 
in any subsequent period. 

When  performing  the  quantitative  assessment,  if  the  fair 
value of the reporting unit exceeds its carrying value, goodwill of 
the  reporting  unit  would  not  be  considered  impaired.  If  the 
carrying  value  of  the  reporting  unit  exceeds  its  fair  value,  a 
goodwill impairment loss would be recognized for the amount by 
which the reporting unit’s allocated equity exceeds its fair value. 
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 

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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 
the  VIE.  The 
consolidation  status  of  the  VIEs  with  which  the  Corporation  is 
involved may change as a result of such reassessments. 

interests 

financial 

its 

in 

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 
representations  and 
than  standard 
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 
investors  share 
one  or  a 
responsibility for the design of the trust or have control over the 
significant  activities  of  the  trust  through  liquidation  or  other 
substantive rights. 

limited  number  of  third-party 

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

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that  most  significantly 

the  economic 
activities 
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. 

impact 

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 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. 

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  than  exchange-traded 
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 

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discounted 

pricing  models, 

fair  value  of  the  assets  or  liabilities.  Level  3  assets 
and  liabilities  include  financial  instruments  for  which 
the  determination  of  fair  value  requires  significant 
management judgment or estimation. The fair value for 
such  assets  and  liabilities  is  generally  determined 
flow 
using 
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. 

cash 

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  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. 

future  because  of 

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. 

fixed 

rates 

fees  are 

Interchange 

Card Income 
Card income includes annual, late and over-limit fees as well as 
interchange,  cash  advances  and  other  miscellaneous  items 
from  credit  and  debit  card  transactions  and  from  processing 
card transactions for merchants. Card income is presented net 
of  direct  costs. 
recognized  upon 
settlement  of  the  credit  and  debit  card  payment  transactions 
and  are  generally  determined  on  a  percentage  basis  for  credit 
cards  and 
the 
corresponding  payment  network’s  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  and  merchants  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

for  debit  cards  based  on 

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transaction  activity  and  other  historical  card  performance.  The 
liability is reduced as the points are redeemed. The Corporation 
also makes payments to credit card partners. The payments are 
based  on  revenue-sharing  agreements  that  are  generally  driven 
by  cardholder  transactions  and  partner  sales  volumes.  As  part 
of  the  revenue-sharing  agreements,  the  credit  card  partner 
provides the Corporation exclusive rights to market to the credit 
card  partner’s  members  or  customers  on  behalf  of  the 
Corporation. 

Service Charges 
Service  charges  include  deposit  and  lending-related  fees. 
Deposit-related  fees  consist  of  fees  earned  on  consumer  and 
commercial deposit activities and are generally recognized when 
the transactions occur or as the service is performed. Consumer 
fees  are  earned  on  consumer  deposit  accounts  for  account 
maintenance  and  various  transaction-based  services,  such  as 
ATM  transactions,  wire  transfer  activities,  check  and  money 
order  processing  and  insufficient  funds/overdraft  transactions. 
Commercial  deposit-related  fees  are  from  the  Corporation’s 
Global Transaction Services business and consist of commercial 
deposit  and  treasury  management  services,  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. 

Investment and Brokerage Services 
Investment  and  brokerage  services  consist  of  asset 
management  and  brokerage  fees.  Asset  management  fees  are 
earned  from  the  management  of  client  assets  under  advisory 
agreements  or  the  full  discretion  of  the  Corporation’s  financial 
advisors  (collectively  referred  to  as  assets  under  management 
(AUM)). Asset management fees are earned as a percentage of 
the client’s AUM and generally range from 50 basis points (bps) 
to 150 bps of the AUM. In cases where a third party is used to 
obtain  a  client’s  investment  allocation,  the  fee  remitted  to  the 
third party is recorded net and is not reflected in the transaction 
price, as the Corporation is an agent for those services. 

Brokerage  fees  include  income  earned  from  transaction-
based  services  that  are  performed  as  part  of  investment 
management services and are based on a fixed price per unit or 
as a percentage of the total transaction amount. Brokerage fees 
also  include  distribution  fees  and  sales  commissions  that  are 
primarily in the 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 
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. 

information 

trade 

to 

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 

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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 

Financial  advisory  services  consist  of  fees  earned  for 
assisting  clients  with  transactions  related  to  mergers  and 
acquisitions  and 
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,  2020,  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. 

Paycheck Protection Program 
The  Corporation  is  participating  in  the  Paycheck  Protection 
Program (PPP), which is a loan program that originated from the 
CARES  Act  and  was  subsequently  expanded  by  the  Paycheck 
Protection Program and Health Care Enhancement Act. The PPP 
is  designed  to  provide  U.S.  small  businesses  with  cash-flow 
fully  guaranteed  by  the  Small
assistance  through 

loans 

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the  proceeds 

Business  Administration  (SBA).  If  the  borrower  meets  certain 
criteria  and  uses 
towards  certain  eligible 
expenses,  the  borrower’s  obligation  to  repay  the  loan  can  be 
forgiven  up  to  the  full  principal  amount  of  the  loan  and  any 
accrued  interest.  Upon  borrower  forgiveness,  the  SBA  pays  the 
Corporation  for  the  principal  and  accrued  interest  owed  on  the 
loan. If the full principal of the loan is not forgiven, the loan will 
operate  according  to  the  original  loan  terms  with  the  100 
percent SBA guaranty remaining. As of December 31, 2020, the 

Corporation  had  approximately  332,000  PPP  loans  with  a 
carrying  value  of  $22.7  billion.  As  compensation  for  originating 
the loans, the Corporation received lender processing fees from 
the  SBA,  which  are  capitalized,  along  with  the  loan  origination 
costs,  and  will  be  amortized  over  the  loans’  contractual  lives 
and  recognized  as  interest  income.  Upon  forgiveness  of  a  loan 
and  repayment  by  the  SBA,  any  unrecognized  net  capitalized 
fees and costs related to the loan will be recognized as interest 
income in that period. 

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 2020, 
2019  and  2018.  For  more  information,  see  Note  1  –  Summary  of  Significant  Accounting  Principles.  For  a  disaggregation  of 
noninterest income by business segment and All Other , see  Note 23 – Business Segment Information. 

(Dollars in millions)
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

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 (loss)

Total noninterest income

2020

2019

2018 

$

34,029  $

9,790
903
4,128
2,735
51,585

1,943
987
974
4,321
8,225

$

43,360  $

43,086  $
11,806
4,843
5,196
6,305
71,236

7,188
7,208
1,249
6,700
22,345
48,891  $

$

3,954  $
1,702
5,656

3,834  $
1,963
5,797

5,991
1,150
7,141

10,708
3,866
14,574

4,698
861
1,621
7,180
34,551
8,355
(738)
42,168  $

6,588
1,086
7,674

10,241
3,661
13,902

2,998
1,184
1,460
5,642
33,015
9,034
304
42,353  $

$

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 

2,722 
1,347 
1,258 
5,327 
33,078 
9,008 
772 
42,858 

(1)  Gross interchange fees were $9.2 billion, $10.0 billion and $9.5 billion for 2020, 2019 and 2018, respectively, and are presented net of $5.5 billion, $6.2 billion and $5.6 billion of expenses for 

rewards and partner payments as well as certain other card costs for the same periods.

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NOTE 3 Derivatives 

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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 in qualifying hedge accounting relationships. 
in  qualifying  hedge 
Derivatives  that  are  not  designated 
risk 
accounting 
referred 
the 
management  derivatives.  For  more 

to  as  other 
information  on 

relationships  are 

62539financials

134

instruments 

Corporation’s  derivatives  and  hedging  activities,  see  Note  1  – 
Summary  of  Significant  Accounting  Principles.  The  following 
tables  present  derivative 
the 
Consolidated  Balance  Sheet  in  derivative  assets  and  liabilities 
at December 31, 2020 and 2019. 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. 

included  on 

Gross Derivative Assets

Gross Derivative Liabilities 

December 31, 2020 

Trading and 
Other Risk 
Management 
Derivatives 

Qualifying 
Accounting 
Hedges

Contract/ 
Notional (1) 

Trading and 
Other Risk 
Management 
Derivatives 

Qualifying 
Accounting 
Hedges

Total 

Total 

(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

$  13,242.8  $
3,222.2
1,530.5
1,545.8

199.9  $
3.5
—
45.3

37.1
53.4
—
5.0

13.3
0.3
—
52.6

1.9
2.0
 —
1.5

2.3
0.2

1,475.8
3,710.7
289.6
279.3

320.2
106.2
599.1
541.2

36.4
63.6
24.6
24.7

322.7
63.6

301.5
68.6

10.9  $

0.1
—
—

0.3
—
—
—

—
—
—
—

—
—
 —
—

—
—

210.8  $
3.6
—
45.3

209.3  $
3.6
40.5
—

1.3  $
—
—
—

210.6 
3.6 
40.5 
— 

37.4
53.4
—
5.0

13.3
0.3
—
52.6

1.9
2.0
 —
1.5

2.3
0.2

39.7
54.5
4.8
—

14.5
1.4
48.8
—

4.4
1.0
 1.4
—

4.4
1.0

0.6
0.5
—
—

—
—
—
—

—
—
 —
—

—
—

40.3 
55.0 
4.8 
— 

14.5 
1.4 
48.8 
— 

4.4 
1.0 
 1.4
— 

4.4 
1.0 

4.4
0.6
423.3  $

$

—
—
11.3  $

$

1.9
0.4
431.6  $

4.4
0.6
434.6  $
(344.9)
(42.5)
47.2

—
—
2.4  $

$

1.9 
0.4 
434.0 
(344.9) 
(43.6) 
45.5 

(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 $2.2 

billion and $269.8 billion at December 31, 2020.

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(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) 

Trading and 
Other Risk 
Management 
Derivatives 

Qualifying 
Accounting 
Hedges

Total 

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

5.4
0.8
334.3  $

$

—
—
10.5  $

$

2.0
0.4
335.5  $

5.4
0.8
344.8  $
(270.4)
(33.9)
40.5

0.9
0.3
—
—

—
—
—
—

  —
—
—
—

—
—

—
—

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. 

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,  2020  and  2019  by  primary  risk  (e.g., 
interest rate risk) and the platform, where applicable, on which 
these  derivatives  are  transacted.  Balances  are  presented  on  a 
gross  basis,  prior  to  the  application  of  counterparty  and  cash 
collateral  netting.  Total  gross  derivative  assets  and  liabilities 
are  adjusted  on  an  aggregate  basis  to  take  into  consideration 
the  effects  of  legally  enforceable  master  netting  agreements 
which include reducing the balance for counterparty netting and 
cash collateral received or paid. 

For  more  information  on  offsetting  of  securities  financing 
agreements,  see  Note  10  –  Federal  Funds  Sold  or  Purchased, 
Securities  Financing  Agreements,  Short-term  Borrowings  and 
Restricted Cash.

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(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 

Over-the-counter
Exchange-traded
Over-the-counter cleared

Derivative assets/liabilities, after netting

Other gross derivative assets/liabilities (2) 

Total derivative assets/liabilities

Less: Financial instruments collateral (3) 

Total net derivative assets/liabilities

Derivative 
Assets 

Derivative 
Liabilities 

Derivative 
Assets 

Derivative 
Liabilities 

December 31, 2020

December 31, 2019 

$

247.7  $
—
10.2

243.5  $
 —
9.1

203.1  $
 0.1
6.0

196.6 
0.1 
5.3 

92.2
1.4

31.3
32.3

3.5
0.7
—

5.2
2.2

379.9
33.0
13.8

96.5
1.3

28.3
31.0

5.0
0.7
 —

5.6
1.9

378.9
31.7
12.3

69.2
0.5

21.3
26.4

2.8
0.8
 —

6.4
2.5

302.8
27.3
9.0

(345.7)
(29.5)
(12.2)
39.3
7.9
47.2
(16.1)
31.1  $

(347.2)
(29.5)
(11.8)
34.4
11.1
45.5
(16.6)
28.9  $

(274.7)
(21.5)
(8.1)
34.8
5.7
40.5
(14.6)
25.9  $

$

73.1 
0.5 

17.8 
22.8 

4.2 
0.8 
 0.1

6.6 
2.2 

298.3 
23.7 
8.1 

(269.3) 
(21.5) 
(8.1) 
31.2 
7.0 
38.2 
(16.1) 
22.1 

(1)  OTC  derivatives  include  bilateral  transactions  between  the  Corporation  and  a  particular  counterparty.  OTC-cleared  derivatives  include  bilateral  transactions  between  the  Corporation  and  a 

counterparty where the transaction is cleared through a clearinghouse. Exchange-traded derivatives include listed options transacted on an exchange. 

(2)  Consists of derivatives entered into under master netting agreements where the enforceability of these agreements is uncertain under bankruptcy laws in some countries or industries. 
(3)  Amounts  are  limited  to  the  derivative  asset/liability  balance  and,  accordingly,  do  not  include  excess  collateral  received/pledged.  Financial  instruments  collateral  includes  securities  collateral 
received or pledged and cash securities held and posted at third-party custodians that are not offset on the Consolidated Balance Sheet but shown as a reduction to derive net derivative assets 
and liabilities. 

ALM and Risk Management Derivatives 
The  Corporation’s  ALM  and  risk  management  activities  include 
the  use  of  derivatives  to  mitigate  risk  to  the  Corporation 
including  derivatives  designated  in  qualifying  hedge  accounting 
relationships  and  derivatives  used  in  other  risk  management 
activities.  Interest  rate,  foreign  exchange,  equity,  commodity 
and  credit  contracts  are  utilized  in  the  Corporation's  ALM  and 
risk management activities. 

The  Corporation  maintains  an  overall  interest  rate  risk 
management strategy that incorporates the use of interest rate 
contracts,  which  are  generally  non-leveraged  generic  interest 
rate  and  basis  swaps,  options,  futures  and  forwards,  to 
minimize significant fluctuations in earnings caused by interest 
rate volatility. The Corporation’s goal is to manage interest rate 
sensitivity and volatility so that movements in interest rates do 
not significantly adversely affect earnings or capital. As a result 
of  interest  rate  fluctuations,  hedged  fixed-rate  assets  and 
liabilities appreciate or depreciate in fair value. Gains or losses 
on  the  derivative  instruments  that  are  linked  to  the  hedged 
fixed-rate  assets  and  liabilities  are  expected  to  substantially 
offset this unrealized appreciation or depreciation. 

Market risk, including interest rate risk, can be substantial in 
the mortgage business. Market risk in the mortgage business is 
the  risk  that  values  of  mortgage  assets  or  revenues  will  be 
adversely  affected  by  changes  in  market  conditions  such  as 
interest  rate  movements.  To  mitigate  the  interest  rate  risk  in 
mortgage  banking  production  income,  the  Corporation  utilizes 

forward 
loan  sale  commitments  and  other  derivative 
instruments,  including  purchased  options,  and  certain  debt 
securities.  The  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,

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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 
foreign  currency-
issuing 
denominated debt (net investment hedges). 

Fair Value Hedges 
The following table summarizes information related to fair value hedges for 2020, 2019 and 2018. 

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

2020

Derivative
2019

2018

2020

Hedged Item 
2019

2018 

$

$

7,091  $

783
(44)
7,830  $

6,113  $

119
(102)

6,130  $

(1,538)  $
(1,187)
(52)
(2,777)  $

(7,220)  $
(783)
49
(7,954)  $

(6,110)  $
(101)
98
(6,113)  $

1,429 
1,079 
50 
2,558 

(1)  Amounts are recorded in interest expense in the Consolidated Statement of Income. 
(2) 

In 2020, 2019 and 2018, the derivative amount includes gains (losses) of $701 million, $73 million and $(116) million in interest expense, $73 million, $28 million and $(992) million in market 
making  and  similar  activities,  and  $9  million,  $18  million  and  $(79)  million  in  accumulated  OCI,  respectively.  Line  item  totals  are  in  the  Consolidated  Statement  of  Income  and  on  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, 3, 4)  
Trading account assets (5) 

Carrying Value 

Cumulative 
Fair Value 
Adjustments (1) 

Carrying Value 

Cumulative 
Fair Value 
Adjustments (1) 

$

December 31, 2020
(150,556)  $
116,252
427

(8,910)  $
114
15 

December 31, 2019 
(162,389)  $
1,654
—

(8,685) 
64 
 —

(1)  For assets, increase (decrease) to carrying value and for liabilities, (increase) decrease to carrying value. 
(2)  At December 31, 2020 and 2019, the cumulative fair value adjustments remaining on long-term debt and AFS debt securities from discontinued hedging relationships resulted in an (increase) 
decrease in the related liability of $(3.7) billion and $1.3 billion and an increase (decrease) in the related asset of $(69) million and $8 million, which are being amortized over the remaining 
contractual life of the de-designated hedged items. 

(3)  These amounts include the amortized cost basis of the prepayable financial assets used to designate hedging relationships in which the hedged item is the last layer expected to be remaining at 
the  end  of  the  hedging  relationship  (i.e.  last-of-layer  hedging  relationship).  At December  31,  2020,  the  amortized  cost  of  the  closed  portfolios  used  in  these  hedging  relationships  was $34.6 
billion, of which $7.0 billion was designated in the last-of-layer hedging relationship. The cumulative basis adjustments associated with these hedging relationships were not significant. 

(4)  Carrying value represents amortized cost. 
(5)  Represents hedging activities related to precious metals inventory. 

Cash Flow and Net Investment Hedges 
The  following  table  summarizes  certain  information  related  to 
cash  flow  hedges  and  net  investment  hedges  for  2020,  2019 
and 2018. Of the $426 million after-tax net gain ($566 million 
pretax)  on  derivatives  in  accumulated  OCI  at  December  31, 
2020,  gains  of  $190  million  after-tax  ($254  million  pretax) 
related to both open and terminated hedges are expected to be 

reclassified  into  earnings  in  the  next  12  months.  These  net 
gains  reclassified  into  earnings  are  expected  to  primarily 
increase  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 forecasted MBS purchases (1) 
Price risk on certain compensation plans (2) 

Total

Net investment hedges 

Foreign exchange risk (3) 

Gains (Losses) Recognized in 
Accumulated OCI on Derivatives 
2019

2018

2020

Gains (Losses) in Income 
Reclassified from Accumulated OCI 
2019

2018 

2020

$

$

$

$

763
241 
85
1,089  $

(834)  $

671 
—
34
705 

22 

$

$

$

(159)  $
 —
4
(155)  $

989  $

 (7)
 9
12
 14

4

$

$

$

(104)  $
 —
(2)
(106)  $

(165) 
 —
27 
(138) 

366  $

411 

(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 

and similar activities were gains (losses) of $(11) million, $154 million and $47 million in 2020, 2019 and 2018, respectively.

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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 2020, 2019 and 2018. These 
gains  (losses)  are  largely  offset  by  the  income  or  expense 
recorded on the hedged item. 

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) 

Price risk on certain compensation plans (4) 

2020

2019

2018 

 $

446
(68)

315  $ 
(58)

(107) 
9 

(2,971)
700

1,112
943

3,278 
(495) 

(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 $165 million, $73 million and $47 million in 
2020, 2019 and 2018. 

(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. 
(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. At both December 31, 2020 
and  2019,  the  Corporation  had  transferred  $5.2  billion  of  non-
U.S.  government-guaranteed  mortgage-backed  securities  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 as of both transfer dates. At December 
31, 2020 and 2019, the fair value of the transferred securities 
was $5.5 billion and $5.3 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. 

interest 

fees  primarily 

Sales and trading revenue includes changes in the fair value 
and realized gains and losses on the sales of trading and other 
assets,  net 
from 
income,  and 
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 

62539financials

138

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  2020,  2019  and  2018.  This 
table  includes  debit  valuation  adjustment  (DVA)  and  funding 
valuation  adjustment  (FVA)  gains  (losses).  Global  Markets 
results  in  Note  23  –  Business  Segment  Information  are 
presented  on  a  fully  taxable-equivalent  (FTE)  basis.  The  table 
below is not presented on an FTE basis. 

Sales and Trading Revenue 

Market 
making 
and similar 
activities 

Net 
Interest 
Income

Other (1) 

Total 

(Dollars in millions)
Interest rate risk
Foreign exchange risk
Equity risk
Credit risk
Other risk

Total sales and trading 

$ 

2,211  $ 
1,482
3,656
812
308

2020 
2,400  $
(20)
(77)
1,638
4

231  $ 

3
1,801
328
44

4,842 
1,465 
5,380 
2,778 
356 

revenue

$ 

8,469  $ 

3,945  $ 

2,407  $  14,821 

Interest rate risk
Foreign exchange risk
Equity risk
Credit risk
Other risk

$ 

1,000  $ 
1,288
3,563
1,091
120

Total sales and trading 

2019 
1,817  $
62
(634)
1,807
70

113  $ 

57
1,569
519
53

2,930 
1,407 
4,498 
3,417 
243 

revenue

$ 

7,062  $ 

3,122  $ 

2,311  $  12,495 

2018 

Interest rate risk 
Foreign exchange risk
Equity risk
Credit risk
Other risk

Total sales and trading 

$

$

810
1,504
3,870
1,034
40

1,651
31
(657)
1,886
197

 $

245  $ 

22
1,643
600
49

2,706 
1,557 
4,856 
3,520 
286 

revenue

$ 

7,258  $ 

3,108  $ 

2,559  $  12,925 

(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  $1.9 billion, $1.7 billion and $1.7 
billion in 2020, 2019 and 2018, respectively. 

transactions  and 

to  manage  credit 

Credit Derivatives 
The  Corporation  enters  into  credit  derivatives  primarily  to 
risk 
facilitate  client 
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

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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. 

or  higher  as  investment  grade.  Non-investment  grade  includes 
non-rated  credit  derivative 
instruments.  The  Corporation 
discloses internal categorizations of investment grade and non-
investment grade consistent with how risk is managed for these 
instruments. 

Credit  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-

Credit  derivative  instruments  where  the  Corporation  is  the 
seller of credit protection and their expiration at December 31, 
2020 and 2019 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, 2020 
Carrying Value 

Over Five 
Years

Total 

1  $

35  $

94  $

233
234

4
—
4
238  $

364
399

—
—
—

399  $

— $
2
2  $
Maximum Payout/Notional 

— $
10
10  $

33,474  $
13,664
47,138

75,731  $
28,770
104,501

87,218  $
35,978
123,196

30,961
36,128
67,089

$

114,227  $

1,061
364
1,425
105,926  $

77
27
104
123,300  $

—  $
26
26

21
345
366
392  $

— $
64
64  $

—  $
70
70

35
344
379
449  $

—  $
6
6  $

$

$

$

$

$

$

$

$

$

$

55,827  $
19,049
74,876

67,838  $
26,521
94,359

71,320  $
29,618
100,938

56,488
28,707
85,195

$

160,071  $

—
657
657
95,016  $

62
104
166
101,104  $

December 31, 2019 
Carrying Value 

5  $

60  $

292
297

—
—
—

561
621

—
—
—

3  $
2
5  $
Maximum Payout/Notional 

1  $
1
2  $

297  $

621  $

972  $

1,163
1,257

—
—
—
1,257  $

$

 572
947

1,519  $

16,822  $

9,852
26,674

—
5
5
26,679  $

164  $
808
972

—
—
—

639  $

1,125
1,764  $

17,708  $
12,337
30,045

76
60
136
30,181  $

130 
1,786 
1,916 

25 
345 
370 
2,286 

 572
1,023 
1,595 

213,245 
88,264 
301,509 

32,099 
36,524 
68,623 
370,132 

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 

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.

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Credit-related Contingent Features and Collateral 
The Corporation executes the majority of its derivative contracts 
in the OTC market with large, international financial institutions, 
including  broker-dealers  and,  to  a  lesser  degree,  with  a  variety 
of  non-financial  companies.  A  significant  majority  of  the 
derivative  transactions  are  executed  on  a  daily  margin  basis. 
Therefore, events such as a credit rating downgrade (depending 
on  the  ultimate  rating  level)  or  a  breach  of  credit  covenants 
would  typically  require  an  increase  in  the  amount  of  collateral 
required of the counterparty, where applicable, and/or allow the 
Corporation  to  take  additional  protective  measures  such  as 
early termination of all trades. Further, as previously discussed 
on  page  135,  the  Corporation  enters  into  legally  enforceable 
master  netting  agreements  that  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,  2020  and 
2019,  the  Corporation  held  cash  and  securities  collateral  of 
$96.5 billion and $84.3 billion and posted cash and securities 
collateral of $88.6 billion and $69.1 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, 2020, 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  $2.6  billion, 
including $1.2 billion 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, 
2020  and  2019,  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, 2020 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, 2020 

(Dollars in millions) 
Bank of America Corporation
Bank of America, N.A. and subsidiaries (1) 

$

One 
incremental 
notch 

Second 
incremental 
notch 

300  $

61

735 
570 

(1) 

Included in Bank of America Corporation collateral requirements in this table. 

The  following  table  presents  the  derivative  liabilities  that 
would be subject to unilateral termination by counterparties and 
the  amounts  of  collateral  that  would  have  been  contractually 
required  at  December  31,  2020  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, 2020 

(Dollars in millions) 
Derivative liabilities
Collateral posted

One 
incremental 
notch 

Second 
incremental 
notch 

$

45  $
23

1,035 
544 

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. 

The table below presents credit valuation adjustment (CVA), 
DVA and FVA gains (losses) on derivatives (excluding the effect 
of  any  related  hedge  activities),  which  are  recorded  in  market 
making  and  similar  activities,  for  2020,  2019  and  2018.  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) 

(Dollars in millions)
Derivative assets (CVA)
Derivative assets/liabilities (FVA)
Derivative liabilities (DVA)

2020

2019

2018 

$

(118)  $

(24)
24

$

72
(2)
(147)

77
(15) 
(19) 

(1)  At  December  31,  2020,  2019  and  2018,  cumulative  CVA  reduced  the  derivative  assets 
balance  by  $646  million,  $528  million  and  $600  million,  cumulative  FVA  reduced  the  net 
derivatives  balance  by  $177  million,  $153  million  and  $151  million,  and  cumulative  DVA 
reduced  the  derivative  liabilities  balance  by  $309  million,  $285  million  and  $432  million, 
respectively.

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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, 2020 and 2019. 

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  (3) 

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 (3) 

Total debt securities (3,4) 

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) 

Amortized 
Cost 

Gross 
Gross 
Unrealized 
Unrealized 
Gains 
Losses 
December 31, 2020 

Fair 
Value 

$  59,518  $ 
5,112
15,470
899
80,999
114,157
14,009
2,656
211,821
16,417
228,238
11,720
239,958
438,279

2,370  $

161
1,025
127
3,683
2,236
15
61
5,995
389
6,384
429
6,813
10,095

$  678,237  $  16,908  $

(39)  $  61,849 
5,260 
(13)
16,491 
(4)
1,009 
(17)
84,609 
(73)
116,380 
(13)
14,017 
(7)
2,711 
(6)
217,717 
(99)
16,774 
(32)
234,491 
(131)
12,110 
(39)
246,601 
(170)
(194)
448,180 
(364)  $  694,781 

December 31, 2019 

$ 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)
1,077 
(9)
143,267 
(241)
68,528 
(195)
11,991 
(2)
3,941 
—
227,727 
(438)
17,912 
(6)
245,639 
(444)
10,828 
(23)
256,467 
(467)
219,821 
(342)
(809)  $ 476,288 

(1)  At  December  31,  2020  and  2019,  the  underlying  collateral  type  included  approximately  37  percent  and  49  percent  prime,  two  percent  and  six  percent  Alt-A  and  61  percent  and  45  percent 

subprime. 

(2)  Primarily includes non-U.S. securities used to satisfy certain international regulatory requirements. Any changes in value are reported in market making and similar activities. For detail on the 

components, see Note 20 – Fair Value Measurements. 
Includes securities pledged as collateral of $65.5 billion and $67.0 billion at December 31, 2020 and 2019. 

(3) 
(4)  The Corporation held debt securities from FNMA and FHLMC that each exceeded 10 percent of shareholders’ equity, with an amortized cost of $260.1 billion and $118.1 billion, and a fair value of 
$267.5 billion and $120.7 billion at December 31, 2020, and 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. 

At December 31, 2020, 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 $4.7 billion, net of the related income tax 
expense of $1.6 billion. The Corporation had nonperforming AFS 
debt  securities  of  $20  million  and  $9  million  at  December  31, 
2020 and 2019. 

Effective January 1, 2020, the Corporation adopted the new 
accounting standard for credit losses that requires evaluation of 
AFS  and  HTM  debt  securities  for  any  expected  losses  with 
recognition  of  an  allowance  for  credit  losses,  when  applicable. 
For  more  information,  see  Note  1  –  Summary  of  Significant 
Accounting  Principles.  At  December  31,  2020,  the  Corporation 
had  $200.0  billion  in  AFS  debt  securities,  which  were  primarily 

U.S. agency and U.S. Treasury securities that have a zero credit 
loss  assumption.  For  the  remaining  $34.5  billion  in  AFS  debt 
securities, the amount of ECL was insignificant. Substantially all 
of  the  Corporation's  HTM  debt  securities  are  U.S.  agency  and 
U.S. Treasury securities and have a zero credit loss assumption. 
At  December  31,  2020  and  2019,  the  Corporation  held 
equity securities at an aggregate fair value of $769 million and 
$891  million  and  other  equity  securities,  as  valued  under  the 
measurement  alternative,  at  a  carrying  value  of  $240  million 
and $183 million, both of which are included in other assets. At 
December  31,  2020  and  2019,  the  Corporation  also  held 
money  market  investments  at  a  fair  value  of  $1.6  billion  and 
$1.0  billion,  which  are  included  in  time  deposits  placed  and 
other short-term investments.

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The gross realized gains and losses on sales of AFS debt securities for 2020, 2019 and 2018 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

2020

2019

2018 

$

 423
(12)
411  $

336  $
(119)
217  $

169 
(15) 
154 

103  $

 54

$

 37

$

$

$

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, 2020 and 2019. 

Total AFS Debt Securities in a Continuous Unrealized Loss Position 

(Dollars in millions)
Continuously unrealized loss-positioned 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 AFS debt securities in a continuous 

unrealized loss position

Continuously unrealized loss-positioned 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 AFS debt securities in a continuous
  unrealized loss position

Less than Twelve Months

Fair 
Value 

Gross 
Unrealized 
Losses 

Twelve Months or Longer
Gross 
Fair 
Unrealized 
Value 
Losses 
December 31, 2020 

Total 

Fair 
Value 

Gross 
Unrealized 
Losses 

$

2,841  $

(39)  $

2  $

187
566
342
3,936
8,282
1,861
576
14,655
4,108

(2)
(4)
(9)
(54)
(9)
(6)
(2)
(71)
(29)

364
9
56
431
498
135
396
1,460
617

—  $
(11)
—
(8)
(19)
(4)
(1)
(4)
(28)
(3)

2,843  $

551
575
398
4,367
8,780
1,996
972
16,115
4,725

(39) 
(13) 
(4) 
(17) 
(73) 
(13) 
(7) 
(6) 
(99) 
(32) 

$

18,763  $

(100)  $

2,077  $

(31)  $

20,840  $

(131) 

December 31, 2019 

$ 

17,641  $
255
2,180
122
20,198
12,836
851
938
34,823
4,286

(41)  $ 

(1)
(22)
(6)
(70)
(71)
—
—
(141)
(5)

17,238  $
925
442
22
18,627
18,866
837
222
38,552
190

(142)  $ 

34,879  $

(23)
(3)
(3)
(171)
(124)
(2)
—
(297)
(1)

1,180
2,622
144
38,825
31,702
1,688
1,160
73,375
4,476

(183) 
(24) 
(25) 
(9) 
(241) 
(195) 
(2) 
— 
(438) 
(6) 

$ 

39,109  $

(146)  $ 

38,742  $

(298)  $ 

77,851  $

(444)

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The remaining contractual maturity distribution and yields of the Corporation’s debt securities carried at fair value and HTM debt 
securities at December 31, 2020 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 

1
4
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Due in One 
Year or Less 

Amount

Yield (1) 

Due after One Year 
through Five Years 
Yield (1) 

Amount

Due after Five Years 
through Ten Years 
Yield (1) 

Amount

Due after 
Ten Years

Total 

Amount

Yield (1) 

Amount

Yield (1) 

(Dollars in millions)

Amortized cost of debt securities carried at fair value 

Mortgage-backed securities: 

Agency

Agency-collateralized mortgage obligations

Commercial

Non-agency residential

Total mortgage-backed securities

U.S. Treasury and agency securities

Non-U.S. securities

Other taxable securities, substantially all asset-backed 

securities

Total taxable securities

Tax-exempt securities

$

—

—

26

—

26

10,020

22,862

699

33,607

872

Total amortized cost of debt securities carried at 

fair value

$  34,479

Amortized cost of HTM debt securities (2) 

Debt securities carried at fair value 

Mortgage-backed securities: 

Agency

Agency-collateralized mortgage obligations

Commercial

Non-agency residential

Total mortgage-backed securities

U.S. Treasury and agency securities

Non-U.S. securities

Other taxable securities, substantially all asset-backed 

securities

Total taxable securities

Tax-exempt securities

Total debt securities carried at fair value

Fair value of HTM debt securities (2) 

$

$

15

—

—

26

—

26

10,056

23,187

702

33,971

874

$  34,845

$

14

—

3.04

—

3.04

1.26

0.31

1.15

0.61

0.87

0.62

3.78

— %  $

5.69 %  $

7

—

6,669

—

6,676

29,533

926

1,336

38,471

8,430

$  46,901

$

$

66

7

—

7,077

—

7,084

30,873

940

1,369

40,266

8,554

—

2.52

—

2.52

1.85

1.81

2.46

1.99

1.27

1.86

2.73

56

24

7,711

1

7,792

74,665

581

366

83,404

4,397

$  87,801

$  17,133

$

61

24

8,242

7

8,334

75,511

582

379

84,806

4,566

4.44 %  $  59,455

3.36 %  $  59,518

3.36 % 

2.57

2.32

—

2.34

0.74

1.09

2.26

0.89

1.66

0.93

1.86

5,088

1,077

1,620

67,240

32

532

255

68,059

2,718

$  70,777

$ 421,065

2.94

2.64

6.77

3.40

2.55

1.79

1.60

3.38

1.41

3.30

2.40

5,112

15,483

1,621

81,734

114,250

24,901

2,656

223,541

16,417

$ 239,958

$ 438,279

2.94 

2.43 

6.77 

3.23 

1.07 

0.42 

2.00 

1.80 

1.38 

1.77 

2.38 

$  61,781

$  61,849 

5,236

1,160

1,776

69,953

33

534

264

70,784

2,780

5,260 

16,505 

1,783 

85,397 

116,473 

25,243 

2,714 

229,827 

16,774 

$ 246,601 

$ 448,180 

$  48,820

$

69

$  89,372

$  17,139

$  73,564

$ 430,958

(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.

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NOTE 5 Outstanding Loans and Leases and Allowance for Credit Losses 
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, 2020 and 2019. 

(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 (2) 
Other consumer 
Total consumer

Consumer loans accounted for under the fair value 

option (3) 

Total consumer loans and leases

Commercial 

U.S. commercial
Non-U.S. commercial
Commercial real estate (4) 
Commercial lease financing
U.S. small business commercial (5) 

Total commercial

Commercial loans accounted for under the fair value 

option (3) 

30-59 Days 
Past Due (1) 

60-89 Days 
Past Due (1) 

$ 

1,157
126

$

273
28

445
209
—
2,238

2,238

561
61
128
86
84
920

175
61

122
17

341
67
 —
783

783

214
44
113
20
56
447

90 Days or  
More 
Past Due (1) 

Total Past 
Due 30 Days 
or More 
December 31, 2020 

Total Current 
or Less Than 
30 Days 
Past Due (1) 

Loans 
Accounted 
for Under the  
Fair Value 
Option 

Total 
Outstandings 

$ 

2,118
456

$  213,155
29,872

$  215,273 
30,328 

$

786
269

913
76

903
37
 —
2,984

1,308
121

1,689
313
 —
6,005

6,974
3,862

77,019
91,050
 124
422,056

2,984

6,005

422,056

$

735
735

512
11
226
57
123
929

1,287
116
467
163
263
2,296

287,441
90,344
59,897
16,935
36,206
490,823

8,282 
3,983 

78,708 
91,363 
124
428,061 

735 
428,796 

288,728 
90,460 
60,364 
17,098 
36,469 
493,119 

Total commercial loans and leases
Total loans and leases (6) 

920
3,158

$ 

447
1,230

$ 

929
3,913

$ 

2,296
8,301

$ 

490,823
$  912,879

$ 

5,946
5,946
6,681

5,946 
499,065 
$  927,861 

Percentage of outstandings

0.34 %

0.13 %

0.42 %

0.89 %

98.39 %

0.72 %

100.00 % 

(1)  Consumer real estate loans 30-59 days past due includes fully-insured loans of $225 million and nonperforming loans of $126 million. Consumer real estate loans 60-89 days past due includes 
fully-insured loans of $103 million and nonperforming loans of $95 million. Consumer real estate loans 90 days or more past due includes fully-insured loans of $762 million. Consumer real 
estate loans current or less than 30 days past due includes $1.2 billion and direct/indirect consumer includes $66 million of nonperforming loans. For information on the Corporation's interest 
accrual policies and delinquency status for loan modifications related to the pandemic, see Note 1 – Summary of Significant Accounting Principles. 

(2)  Total outstandings primarily includes auto and specialty lending loans and leases of $46.4 billion, U.S. securities-based lending loans of $41.1 billion and non-U.S. consumer loans of $3.0 billion. 
(3)  Consumer loans accounted for under the fair value option includes residential mortgage loans of $298 million and home equity loans of $437 million. Commercial loans accounted for under the 
fair value option includes U.S. commercial loans of $2.9 billion and non-U.S. commercial loans of $3.0 billion. For more information, see Note 20 – Fair Value Measurements and Note 21 – Fair 
Value Option. 

(4)  Total outstandings includes U.S. commercial real estate loans of $57.2 billion and non-U.S. commercial real estate loans of $3.2 billion. 
(5) 
(6)  Total  outstandings  includes  loans  and  leases  pledged  as  collateral  of  $15.5  billion.  The  Corporation  also  pledged  $153.1  billion  of  loans  with  no  related  outstanding  borrowings  to  secure 

Includes PPP loans. 

potential borrowing capacity with the Federal Reserve Bank and Federal Home Loan Bank.

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(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 (2) 
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

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Loans 
Accounted 
for Under 
the Fair 
Value Option 

Total 
Outstandings 

90 Days or 
More 
Past Due (1) 

Total Past 
Due 30 
Days 
or More 
December 31, 2019 

Total 
Current or 
Less Than 
30 Days 
Past Due (1) 

$

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

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 

Consumer loans accounted for under the fair value 

option (3) 

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 (4) 
Commercial lease financing
U.S. small business commercial

Total commercial

Commercial loans accounted for under the fair value 

option (3) 

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 (5) 

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

0.41 %

0.15 %

0.39 %

0.95 %

98.20 %

0.85 %

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 
fully-insured loans of $206 million and nonperforming loans of $114 million. Consumer real estate loans 90 days or more past due includes fully-insured loans of $1.1 billion. Consumer real 
estate loans current or less than 30 days past due includes $856 million and direct/indirect consumer includes $45 million of nonperforming loans. 

(2)  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. 
(3)  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 20 – Fair Value Measurements and Note 21 – Fair 
Value Option. 

(4)  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. 
(5)  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. 

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,  Fair  Isaac 
Corporation (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 $9.0 billion 
and $7.5 billion at December 31, 2020 and 2019, 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. 

increases  across  multiple 

Nonperforming Loans and Leases 
Commercial  nonperforming  loans  increased  to  $2.2  billion  at 
December  31,  2020  from  $1.5  billion  at  December  31,  2019 
industries. 
with  broad-based 
Consumer  nonperforming  loans  increased  to  $2.7  billion  at 
December  31,  2020  from  $2.1  billion  at  December  31,  2019 
driven  by  deferral  activity,  as  well  as  the 
inclusion  of 
$144 million of certain loans that were previously classified as 
purchased credit-impaired loans and accounted for under a pool 
basis. 

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, 2020 and 
2019.  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 information on the Corporation's 
interest  accrual  policies,  delinquency  status 
loan 
modifications  related  to  the  pandemic  and  the  criteria  for 
classification  as  nonperforming,  see  Note  1  –  Summary  of 
Significant Accounting Principles.

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Credit Quality 

(Dollars in millions)

Residential mortgage (2) 

With no related allowance (3) 

Home equity (2) 

With no related allowance (3) 

Credit Card
Direct/indirect consumer

Total consumer

U.S. commercial
Non-U.S. commercial
Commercial real estate
Commercial lease financing
U.S. small business commercial

Total commercial
Total nonperforming loans

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Nonperforming Loans 
and Leases 

Accruing Past Due 
90 Days or More (1) 

December 31 

2020

2019

2020

2019 

$

$

2,005
1,378
649
347

n/a

71
2,725
1,243
418
404
87
75
2,227
4,952

$

1,470 

$

n/a

536

n/a
n/a

47
2,053
1,094
43
280
32
50
1,499
3,552

$

$

 762
—
—
—
903
33
1,698
228
10
6
25
115
384
2,082

$

$

1,088 
— 
— 
— 
1,042 
33 
2,163 
106 
8 
19 
20 
97 
250 
2,413 

Percentage of outstanding loans and leases

0.54 %

0.36 %

0.23 %

0.25 % 

(1)  For information on the Corporation's interest accrual policies and delinquency status for loan modifications related to the pandemic, see Note 1 – Summary of Significant Accounting Principles. 
(2)  Residential mortgage loans accruing past due 90 days or more are fully-insured loans. At December 31, 2020 and 2019 residential mortgage includes $537 million and $740 million of loans on 
which interest had been curtailed by the FHA, and therefore were no longer accruing interest, although principal was still insured, and $225 million and $348 million of loans on which interest was 
still accruing. 

(3)  Primarily relates to loans for which the estimated fair value of the underlying collateral less any costs to sell is greater than the amortized cost of the loans as of the reporting date. 
n/a = not applicable 

Included in the December 31, 2020 nonperforming loans are 
$127 million and $17 million of residential mortgage and home 
equity  loans  that  prior  to  the  January  1,  2020  adoption  of  the 
new  credit  loss  standard  were  not  included  in  nonperforming 
loans,  as  they  were  previously  classified  as  purchased  credit-
impaired loans and accounted for under a pool basis. 

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  and  year  of  origination  for  term  loan 
balances at December 31, 2020, including revolving loans that 
converted  to  term  loans  without  an  additional  credit  decision 
after origination or through a TDR.

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(Dollars in millions) 
Total Residential Mortgage 
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

Total Residential Mortgage

Total Residential Mortgage 
Refreshed FICO score 

Total as of 
December 31, 
2020

2020

2019

2018

2017

2016

Prior 

Term Loans by Origination Year 

$  207,389  $ 

68,907  $ 

43,771  $ 

14,658  $ 

21,589  $ 

22,967  $ 

35,497 

3,138
1,210
11,818
$  223,555  $ 

1,970
702
3,826

684
174
2,014

75,405  $ 

46,643  $ 

128
47
370
15,203  $ 

70
39
342
22,040  $ 

96
37
1,970

25,070  $ 

190 
211 
3,296 
39,194 

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

Total Residential Mortgage

$

2,717  $
5,462
25,349
178,209
11,818
$  223,555  $ 

823  $

1,804
8,533
60,419
3,826

177  $
666
4,679
39,107
2,014

75,405  $ 

46,643  $ 

139  $
468
1,972
12,254
370
15,203  $ 

170  $
385
2,427
18,716
342
22,040  $ 

150  $
368
2,307
20,275
1,970

25,070  $ 

1,258 
1,771 
5,431 
27,438 
3,296 
39,194 

Home Equity - Credit Quality Indicators 

(Dollars in millions)
Total Home Equity 
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

Total Home Equity

Total Home Equity 
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

Total Home Equity

Home Equity 
Loans and 
Reverse 
Mortgages (1) 

Revolving 
Loans 

December 31, 2020 

Revolving 
Loans 
Converted to 
Term Loans 

Total 

$

$

$

$

33,447  $
351
513
34,311  $

1,919  $

126
172

2,217  $

22,639  $
94
118
22,851  $

1,082  $
1,798
5,762
25,669
34,311  $

250  $
263
556
1,148
2,217  $

244  $
568
2,905
19,134
22,851  $

8,889 
131 
223 
9,243 

588 
967 
2,301 
5,387 
9,243 

(1) 

Includes reverse mortgages of $1.3 billion and home equity loans of $885 million which are no longer originated. 

Credit Card and Direct/Indirect Consumer – Credit Quality Indicators By Vintage 

Direct/Indirect 

Term Loans by Origination Year

Credit Card 

Total Direct/ 
Indirect as of 
December 31, 
2020 

Revolving 
Loans

2020

2019

2018

2017

2016

Prior 

Total Credit 
Card as of 
December 31, 
2020 

Revolving 
Loans 

Revolving 
Loans 
Converted 
to Term 
Loans (3) 

$

959 

$

19  $

111 

$

200 

$

175 

$

243 

$

148 

$

63 

$

4,018  $  3,832  $

186 

2,143

7,431
36,064

20

80
120

653

559

329

301

176

105

9,419

9,201

2,848
12,540

2,015
10,588

1,033
5,869

739
3,495

400
1,781

316
1,671

27,585
37,686

27,392
37,642

44,766

44,098

74

115

84

67

52

276

— 

—

218 

193 
44 

 —

$

91,363 

$  44,337  $  16,226 

$  13,477 

$  7,490 

$  4,845 

$  2,557 

$  2,431 

$

78,708 

$  78,067  $

641 

(Dollars in millions) 
Refreshed FICO score 

Less than 620
Greater than or equal to 620 

and less than 680

Greater than or equal to 680 

and less than 740

Greater than or equal to 740

Other internal credit 

metrics (1, 2) 

Total credit card and other

 consumer

(1)  Other internal credit metrics may include delinquency status, geography or other factors. 
(2)  Direct/indirect consumer includes $44.1 billion of securities-based lending which is typically supported by highly liquid collateral with market value greater than or equal to the outstanding loan 

balance and therefore has minimal credit risk at December 31, 2020. 

(3)  Represents TDRs that were modified into term loans.

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(Dollars in millions) 
U.S. Commercial 
Risk ratings 
Pass rated
Reservable criticized

Total U.S. Commercial

Non-U.S. Commercial 
Risk ratings 
Pass rated
Reservable criticized

Total Non-U.S. Commercial

Commercial Real Estate 
Risk ratings 
Pass rated
Reservable criticized

Total Commercial Real Estate

Commercial Lease Financing 
Risk ratings 
Pass rated
Reservable criticized

Total Commercial Lease Financing

U.S. Small Business Commercial (3) 
Risk ratings 
Pass rated
Reservable criticized

Total U.S. Small Business Commercial
Total (1, 2) 

Term Loans 
Amortized Cost Basis by Origination Year 

Total as of 
December 31, 
2020

2020

2019

2018

2017

2016

Prior 

Revolving 
Loans 

$

$

$

$

$

$

$

$

$

$
$

268,812  $  33,456  $  33,305  $  17,363  $  14,102  $
2,542
288,728  $  35,980  $  35,847  $  20,052  $  14,956  $

19,916

2,689

2,524

854

7,420  $  21,784  $  141,382 
1,402
9,207 
8,118  $  23,186  $  150,589 

698

85,914  $  16,301  $  11,396  $
914
90,460  $  17,215  $  11,968  $

4,546

572

7,451  $

5,037  $

1,674  $

492

436

138

7,943  $

5,473  $

1,812  $

2,194  $  41,861 
1,735 
2,453  $  43,596 

259

50,260  $
10,104
60,364  $

8,429  $  14,126  $

933

2,558

8,228  $
2,115

9,362  $  16,684  $  10,343  $

4,599  $
1,582
6,181  $

3,299  $

606

3,905  $

6,542  $
1,436
7,978  $

5,037 
874 
5,911 

16,384  $
714
17,098  $

3,083  $

3,242  $

2,956  $

117

117

132

3,200  $

3,359  $

3,088  $

2,532  $
81
2,613  $

1,703  $
88
1,791  $

2,868  $

179

3,047  $

— 
— 
— 

1,148

28,786  $  24,539  $

172 
13 
185 
486,584  $  90,372  $  69,218  $  42,473  $  30,133  $  16,266  $  37,841  $  200,281 

735  $
175
910  $

527  $
113
640  $

29,934  $  24,615  $

837  $
210

855  $
322

1,177  $

1,047  $

1,121  $

1,360  $

239

76

(1)  Excludes $5.9 billion of loans accounted for under the fair value option at December 31, 2020. 
(2) 
(3)  Excludes U.S. Small Business Card loans of $6.5 billion. Refreshed FICO scores for this portfolio are $265 million for less than 620; $582 million for greater than or equal to 620 and less than 

Includes $58 million of loans that converted from revolving to term loans. 

680; $1.7 billion for greater than or equal to 680 and less than 740; and $3.9 billion greater than or equal to 740. 

Due to the economic impact of COVID-19, commercial asset 
quality weakened during 2020. Commercial reservable criticized 
utilized  exposure  increased  to  $38.7  billion  at  December  31, 
2020 from $11.5 billion (to 7.31 percent from 2.09 percent of 
total commercial reservable utilized exposure) at December 31, 
2019  with 
industries, 
increases  spread  across  multiple 
including  travel and entertainment. 

Troubled Debt Restructurings 
The Corporation has  been entering into loan modifications with 
borrowers  in  response  to  the  pandemic,  most  of  which  are  not 
classified  as  TDRs,  and  therefore  are  not  included  in  the 
discussion  below.  For  more  information  on  the  criteria  for 
classifying loans as TDRs, see Note 1 – Summary of Significant 
Accounting Principles. 

Consumer Real Estate 
Modifications  of  consumer  real  estate  loans  are  classified  as 
TDRs when the borrower is experiencing financial difficulties and 
a  concession  has  been  granted.  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 $372 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, 2020, of which $102 million 
were  classified  as  nonperforming  and  $68  million  were  loans 
fully insured. 

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 reach 180 days past 
due  prior  to  modification  are  charged  off  to  their  net  realizable 
value,  less  costs  to  sell,  before  they  are  modified  as  TDRs  in 
accordance with established policy. 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

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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,  2020  and  2019,  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 $123 million 
and  $229  million  at  December  31,  2020  and  2019.  The 
carrying  value  of  consumer  real  estate  loans,  including  fully-
insured loans, for which formal foreclosure proceedings were in 
process  at  December  31,  2020  was  $1.2  billion.  Although  the 
Corporation  has  paused  formal  loan  foreclosure  proceedings 
and foreclosure sales for occupied properties, during 2020, the 
Corporation  reclassified  $182  million  of  consumer  real  estate 

loans completed or which were in process prior to the pause in 
foreclosures, to foreclosed properties or, for properties acquired 
foreclosure  of  certain  government-guaranteed 
upon 
loans 
(principally  FHA-insured 
to  other  assets.  The 
loans), 
reclassifications  represent  non-cash  investing  activities  and, 
accordingly, are  not  reflected  in  the  Consolidated  Statement  of 
Cash Flows. 

The  table  below  presents  the  December  31,  2020,  2019 
and 2018 unpaid principal balance, carrying value, and average 
pre- and post-modification interest rates of consumer real estate 
loans that were modified in TDRs during 2020, 2019 and 2018. 
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 2020, 2019 and 2018 (1) 

(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 

December 31, 2020 

Post-
Modification 
Interest Rate (2) 

$

$

$

$

$

$

732  $

87

819  $

464  $
141
605  $

646
69
715

December 31, 2019 

377
101
478

December 31, 2018 

774  $
489

1,263  $

641
358
999

3.66 %
3.67
3.66

4.19 %
5.04
4.39

4.33 %
4.46
4.38

3.59 % 
3.61 
3.59 

4.13 % 
4.31 
4.17 

4.21 % 
3.74 
4.03 

(1)  For more information on the Corporation's loan modification programs offered in response to the pandemic, most of which are not TDRs, see Note 1 – Summary of Significant Accounting Principles. 
(2)  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. 

The  table  below  presents  the  December  31,  2020,  2019  and  2018  carrying  value  for  consumer  real  estate  loans  that  were 

modified in a TDR during 2020, 2019 and 2018, by type of modification. 

Consumer Real Estate – Modification Programs (1) 

(Dollars in millions)
Modifications under government programs 
Modifications under proprietary programs
Loans discharged in Chapter 7 bankruptcy (2) 
Trial modifications

Total modifications

2020

TDRs Entered into During 
2019

2018 

$

13
570
53
79

715  $

$

35
174
68
201
478  $

61
523 
130 
285 
999 

$

$

(1)  For more information on the Corporation's loan modification programs offered in response to the pandemic, most of which are not TDRs, see Note 1 – Summary of Significant Accounting Principles. 
(2) 

Includes loans discharged in Chapter 7 bankruptcy with no change in repayment terms that are classified as TDRs. 

The table below presents the carrying value of consumer real estate loans that entered into payment default during 2020, 2019 
and 2018 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 (1) 

(Dollars in millions)
Modifications under government programs 
Modifications under proprietary programs
Loans discharged in Chapter 7 bankruptcy (2) 
Trial modifications (3) 
Total modifications

2020

2019

2018 

$

$

$

16
51
19
54

140  $

26  $
88
30
57

201  $

39 
158 
64 
107 
368 

(1)  For more information on the Corporation's loan modification programs offered in response to the pandemic, most of which are not TDRs, see Note 1 – Summary of Significant Accounting Principles. 
(2) 

(3) 

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.

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to  assist  customers 

Credit Card and Other Consumer  
that  are 
The  Corporation  seeks 
experiencing 
loans  while 
financial  difficulty  by  modifying 
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. 

The  table  below  provides  information  on  the  Corporation’s 
Credit  Card  and  Other  Consumer  TDR  portfolio  including  the 
December 31, 2020, 2019 and 2018 unpaid principal balance, 
carrying  value,  and  average  pre- and  post-modification  interest 
rates  of  loans  that  were  modified  in  TDRs  during  2020,  2019 
and 2018. 

Credit Card and Other Consumer – TDRs Entered into During 2020, 2019 and 2018 (1) 

(Dollars in millions)
Credit card
Direct/Indirect consumer

Total

Credit card
Direct/Indirect consumer

Total

Credit card
Direct/Indirect consumer

Total

Unpaid Principal 
Balance 

Carrying 
Value (2) 

Pre-Modification 
Interest Rate 

Post-
Modification 
Interest Rate 

$

$

$

$

$

$

269  $

52

321  $

340  $

40

380  $

278  $

42

320  $

December 31, 2020 

277
37
314

18.16 %
5.83
16.70

December 31, 2019 

355
21
376

19.18 %
5.23
18.42

December 31, 2018 

292
23
315

19.49 %
5.10
18.45

5.63 % 
5.83 
5.65 

5.35 % 
5.21 
5.34 

5.24 % 
4.95 
5.22 

(1)  For more information on the Corporation's loan modification programs offered in response to the pandemic, most of which are not TDRs, see Note 1 – Summary of Significant Accounting Principles. 
(2) 

Includes accrued interest and fees. 

The table below presents the December 31, 2020, 2019 and 2018 carrying value for Credit Card and Other Consumer loans that 

were modified in a TDR during 2020, 2019 and 2018, by program type. 

Credit Card and Other Consumer – TDRs by Program Type at December 31 (1) 

(Dollars in millions)
Internal programs
External programs
Other

Total

2020

2019

2018 

$

$

$

225
73
16

314  $

247  $
108
21

376  $

199 
93 
23 
315 

(1) 

Includes  accrued  interest  and  fees.  For  more  information  on  the  Corporation's  loan  modification  programs  offered  in  response  to  the  pandemic,  most  of  which  are  not  TDRs,  see  Note  1  – 
Summary of Significant Accounting Principles. 

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 
credit card and other consumer. Based on historical experience, 
the  Corporation  estimates  that  13  percent  of  new  credit  card 
TDRs and 19 percent of new direct/indirect consumer TDRs may 
be in payment default within 12 months after modification. 

maturity  at  a  concessionary  (below  market)  rate  of  interest, 
payment  forbearances  or  other  actions  designed  to  benefit  the 
borrower  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  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 
information  on 
modifications for the U.S. small business commercial portfolio, 
see Credit Card and Other Consumer in this Note.

time  of  modification.  For  more 

the 

Commercial Loans 
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 
the  borrower. 
individual  circumstances  of 
reflects 
Modifications  that  result  in  a  TDR  may include extensions of 

the 

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in 

quality of the portfolio and an economic outlook over the life of 
the  loan.  Qualitative  reserves  cover  losses  that  are  expected 
but,  in  the  Corporation's  assessment,  may  not  be  adequately 
the  economic 
the  quantitative  methods  or 
reflected 
assumptions.  The  Corporation 
forward-looking 
incorporates 
the  use  of  several  macroeconomic 
through 
information 
scenarios  in  determining  the  weighted  economic  outlook  over 
the  forecasted  life  of  the  assets.  These  scenarios  include  key 
macroeconomic  variables  such  as  gross  domestic  product, 
unemployment  rate,  real  estate  prices  and  corporate  bond 
spreads.  The  scenarios  that  are  chosen  each  quarter  and  the 
weighting given to each scenario depend on a variety of factors 
including recent economic events, leading economic indicators, 
internal and third-party economist views, and industry trends. 

As of January 1, 2020, to determine the allowance for credit 
losses, the Corporation used a series of economic outlooks that 
resulted in an economic outlook that was weighted towards the 
potential  of  a  recession  with  some  expectation  of  tail  risk 
similar to the severely adverse scenario used in stress testing. 
Various economic outlooks were also used in the December 31, 
2020  estimate  for  allowance  for  credit  losses  that  included 
consensus  estimates,  multiple  downside  scenarios  which 
assumed a significantly longer period until economic recovery, a 
tail risk scenario similar to the severely adverse scenario used 
in stress testing and an upside scenario to reflect the potential 
for  continued  improvement  in  the  consensus  outlooks.  The 
weighted  economic  outlook  assumes 
the  U.S. 
unemployment  rate  at  the  end  of  2021  would  be  relatively 
consistent  with  the  level  as  of  December  2020,  slightly  above 
6.5 percent.  Additionally, in this economic outlook, U.S. gross 
domestic product returns to pre-pandemic levels in the early part 
of  2022.  The  allowance  for  credit  losses  considers  the  impact 
of  enacted  government  stimulus,  including  the  COVID-19 
Emergency  Relief  Act  of  2020,  and  continues  to  factor  in  the 
unprecedented nature of the current health crisis. 

that 

The  Corporation  also  factored  into  its  allowance  for  credit 
losses  an  estimated  impact  from  higher-risk  segments  that 
included  leveraged  loans  and  industries  such  as  travel  and 
entertainment,  which  have  been  adversely  impacted  by  the 
effects  of  COVID-19,  as  well  as  the  energy  sector.  The 
Corporation  also  holds  additional  reserves  for  borrowers  who 
their  credit 
take 
requested  deferrals 
characteristics and payment behavior subsequent to deferral. 

into  account 

that 

The allowance for credit losses at December 31, 2020 was 
$20.7  billion,  an  increase  of  $7.2  billion  compared  to 
January 1, 2020. The increase in the allowance for credit losses 
was  driven  by  the  deterioration  in  the  economic  outlook 
resulting  from  the  impact  of  COVID-19.  The  increase  in  the 
allowance for credit losses was comprised of a net increase of 
$6.4  billion  in  the  allowance  for  loan  and  lease  losses  and  a 
$755  million  increase  in  the  reserve  for  unfunded  lending 
commitments. The increase in the allowance for loan and lease 
losses  was  attributed  to  $418  million  in  the  consumer  real 
estate  portfolio,  $1.8  billion  in  the  credit  card  and  other 
consumer portfolio, and $4.2 billion in the commercial portfolio. 
Outstanding loans and leases excluding loans accounted for 
under  the  fair  value  option  decreased  $53.9  billion  in  2020, 
driven  by  consumer  loans,  which  decreased  $37.1  billion 
primarily due to a decline in credit card loans from reduced retail 
spending and higher payments.

At December 31, 2020 and 2019, the Corporation had $1.7 
billion  and  $2.2  billion  of  commercial  TDRs  with  remaining 
commitments  to  lend  additional  funds  to  debtors  of  $402 
million  and  $445  million.  The  balance  of  commercial  TDRs  in 
payment  default  was  $218  million  and  $207  million  at 
December 31, 2020 and 2019. 

Loans Held-for-sale 
The Corporation had LHFS of $9.2 billion at both December 31, 
2020  and  2019.  Cash  and  non-cash  proceeds  from  sales  and 
paydowns  of  loans  originally  classified  as  LHFS  were  $20.1 
billion,  $30.6  billion  and  $29.2  billion  for  2020,  2019  and 
2018, respectively. Cash used for originations and purchases of 
LHFS  totaled  approximately  $19.7  billion,  $28.9  billion  and 
$28.1 billion for 2020, 2019 and 2018, respectively. 

Accrued Interest Receivable 
Accrued interest receivable for loans and leases and loans held-
for-sale at December 31, 2020 and 2019 was $2.4 billion and 
$2.6  billion  and  is  reported  in  customer  and  other  receivables 
on the Consolidated Balance Sheet. 

Outstanding  credit  card  loan  balances  include  unpaid 
principal, interest and fees. Credit card loans are not classified 
as  nonperforming  but  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.  During  2020,  the 
Corporation  reversed  $512  million  of  interest  and  fee  income 
against the income statement line item in which it was originally 
recorded upon charge-off of the principal balance of the loan. 

For  the  outstanding  residential  mortgage,  home  equity, 
loan  balances 
direct/indirect  consumer  and  commercial 
classified  as  nonperforming  during  2020,  the  Corporation 
reversed $44 million of interest and fee income at the time the 
loans  were  classified  as  nonperforming  against  the  income 
statement line item in which it was originally recorded. For more 
information  on  the  Corporation's  nonperforming  loan  policies, 
see Note 1 – Summary of Significant Accounting Principles. 

Allowance for 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  ECL  inherent  in  the  Corporation’s  relevant 
financial assets. Upon adoption of the new accounting standard, 
the Corporation recorded a $3.3 billion, or 32 percent, increase 
in  the  allowance  for  credit  losses  on  January  1,  2020,  which 
was comprised of a net increase of $2.9 billion in the allowance 
for  loan  and  lease  losses  and  a  $310  million  increase  in  the 
reserve for unfunded lending commitments. The net increase in 
the allowance for loan and lease losses was primarily driven by 
a  $3.1  billion  increase  in  credit  card  as  the  Corporation  now 
reserves  for  the  life  of  these  receivables.  The  increase  in  the 
reserve  for  unfunded  lending  commitments  included  $119 
million  in  the  consumer  portfolio  for  the  undrawn  portion  of 
HELOCs and $191 million in the commercial portfolio. For more 
information on the Corporation's credit loss accounting policies 
including the allowance for credit losses see Note 1 – Summary 
of Significant Accounting Principles. 

The  allowance 

is  estimated  using 
quantitative  and  qualitative  methods  that  consider  a  variety  of 
factors,  such  as  historical  loss  experience,  the  current  credit 

for  credit 

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The changes in the allowance for credit losses, including net charge-offs and provision for loan and lease losses, are detailed in 

the table below. 

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

$

$

$

$

$

440  $
(98)
201
103
307
8
858
119
18
137
995  $

928  $
(522)
927
405
(680)
(107)
546
—
—
—

546  $

1,720  $

(690)
664
(26)
(492)
(274)
928
—
—
—

$

928  $

2020 
7,430  $
(3,646)
891
(2,755)
4,538
 —
9,213
—
—
—
9,213  $

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  $

4,488  $
(1,675)
206
(1,469)
5,720
(8)
8,731
1,004
737
1,741

10,472  $

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  $

12,358 
(5,419) 
1,298 
(4,121) 
10,565 

 —

18,802 
1,123 
755 
1,878 
20,680 

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 

(1)  Primarily represents write-offs of purchased credit-impaired loans in 2019, and the net impact of portfolio sales, transfers to held-for-sale and transfers to foreclosed properties. 

NOTE 6 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,  2020 
and  2019  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,  2020  and  2019  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 
liquidity  commitments  and  other  contractual 
unfunded 
arrangements. The Corporation’s maximum loss exposure does 
not include losses previously recognized through write-downs of 
assets. 

lending  arrangements 

The  Corporation  invests  in  ABS  issued  by  third-party  VIEs 
with  which  it  has  no  other  form  of  involvement  and  enters  into 
that  may  also 
certain  commercial 
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 and Allowance for Credit 
Losses. In addition, the Corporation has used VIEs in connection 
with its funding activities.

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The  Corporation  did  not  provide 

financial  support  to 
consolidated  or  unconsolidated  VIEs  during  2020,  2019  and 
2018 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  $929  million  and  $1.1  billion  at 
December 31, 2020 and 2019. 

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) 
residential  mortgage-backed  securities 
guaranteed  by  government-sponsored  enterprises,  FNMA  and 
FHLMC  (collectively  the  GSEs),  or  the  Government  National 
Mortgage  Association  (GNMA)  primarily  in  the  case  of  FHA-

(VA)-
insured  and  U.S.  Department  of  Veterans  Affairs 
guaranteed  mortgage  loans.  Securitization  usually  occurs  in 
conjunction with or shortly after origination or purchase, and the 
Corporation  may  also  securitize  loans  held  in  its  residential 
mortgage  portfolio.  In  addition,  the  Corporation  may,  from  time 
to  time,  securitize  commercial  mortgages  it  originates  or 
purchases from other entities. The Corporation typically services 
the  loans  it  securitizes.  Further,  the  Corporation  may  retain 
beneficial  interests  in  the  securitization  trusts  including  senior 
and  subordinate  securities  and  equity  tranches  issued  by  the 
trusts.  Except  as  described  in  Note  12  –  Commitments  and 
Contingencies,  the  Corporation  does  not  provide  guarantees  or 
recourse  to  the  securitization  trusts  other  than  standard 
representations and warranties. 

The  table  below  summarizes  select  information  related  to 

first-lien mortgage securitizations for 2020, 2019 and 2018. 

First-lien Mortgage Securitizations 

(Dollars in millions)
Proceeds from loan sales (1) 
Gains on securitizations (2) 
Repurchases from securitization trusts (3) 

Residential Mortgage - Agency
2019

2018

2020

Commercial Mortgage 
2019

2018 

2020

$

15,823  $
728
436

6,858  $
27
881

5,801  $
62
1,485

5,084  $
61
— 

8,661  $

103
—

6,991 
101 
 —

(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. 

Substantially all of these securities are classified as Level 2 within the fair value hierarchy and are typically 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 $160 million, $64 million and $71 million net of hedges, during 2020, 2019 and 2018, 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  $160.4 
billion  and  $192.1  billion  at  December  31,  2020  and  2019. 
Servicing  fee  and  ancillary  fee  income  on  serviced  loans  was 
$474 million, $585 million and $710 million during 2020, 2019 
and  2018,  respectively.  Servicing  advances  on  serviced  loans, 
including 
for 
investment, were $2.2 billion and $2.4 billion at December 31, 
2020 and 2019. For more information on MSRs, see Note 20 – 
Fair Value Measurements. 

for  others  and 

loans  serviced 

loans  held 

During  2020,  the  Corporation  completed  the  sale  of  $9.3 
billion  of  consumer  real  estate  loans  through  GNMA  loan 
securitizations.  As  part  of  the  securitizations,  the  Corporation 
retained  $8.4  billion  of  MBS,  which  are  classified  as  debt 
securities  carried  at  fair  value  on  the  Consolidated  Balance 
Sheet. Total gains on loan sales of $704 million were recorded 
in other income in the Consolidated Statement of Income. 

The following table summarizes select information related to 
first-lien mortgage securitization trusts in which the Corporation 
held a variable interest at December 31, 2020 and 2019.

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First-lien Mortgage VIEs 

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Agency

Prime

Residential Mortgage 

Non-agency 
Subprime

December 31 

Alt-A

Commercial Mortgage 

(Dollars in millions)

2020

2019

2020

2019

2020

2019

2020

2019

2020

2019 

Unconsolidated VIEs 
Maximum loss exposure (1) 

On-balance sheet assets 

Senior securities: 

$

13,477  $

12,554 

$

250 $

340

$

1,031  $

1,622

$

46 $

98

$

1,169  $

1,036

Trading account assets 

$

152 $

627

$

2 $

5

$

8 $

54

$

12 $

24

$

60 $

65

Debt securities carried at fair 

value

Held-to-maturity securities

All other assets

Total retained positions

$

7,588

5,737

—
13,477  $

6,392

5,535

—
12,554 

Principal balance outstanding (2) 

$  133,497  $ 

160,226 

103

—

6
111 $

193

—

2
200

6,081  $

7,268

$

$

Consolidated VIEs 
Maximum loss exposure (1) 

On-balance sheet assets 

Trading account assets

Loans and leases, net

All other assets

Total assets

Total liabilities

$

$

$

$

1,328  $

10,857 

$

66 $

5

1,328  $

780

$

350 $

—

—

9,917

161

1,328  $

10,858 

—  $

4

$

$

—

—

350 $

284 $

116

—

—

116

111

$

$

$

$

$

$

676

—

26
710 $

1,178

—

49
1,281

$

33

—

1
46 $

72

—

2
98

6,691  $

8,594

 $

16,554  $

19,878 

—

925

50
1,035  $

— 

809 

38 
912

59,268  $

60,129 

$

$

53 $

44

260 $

—

—

260 $

207 $

149

—

—

149

105

$

$

$

$

— $

— $

— $

— $

— $

— $

—

—

— $

— $

—

—

— $

— $

—

—

— $

— $

—

—

— 

— 

—

—

(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 12 – Commitments and Contingencies and Note 20 – 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. 

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, 2020 and 2019. 

Home Equity Loan, Credit Card and Other Asset-backed VIEs 

(Dollars in millions)

Unconsolidated VIEs 
Maximum loss exposure
On-balance sheet assets 

Securities (3) : 

Trading account assets 
Debt securities carried at fair value

Held-to-maturity securities

Total retained positions

Total assets of VIEs

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) 

Resecuritization Trusts

Municipal Bond Trusts 

December 31 

2020

2019

2020

2019

2020

2019

2020

2019 

206  $

412

$

— $

—

$

8,543  $

7,526

 $

3,507  $

3,701

— $
2

—
2  $
609  $

— $
11

—
11
1,023

$
$

— $
—

—
— $
— $

—
—

—
—
—

$

$
$

948  $

2,727

4,868
8,543  $
17,250  $

2,188
1,126

4,212
7,526
21,234 

58  $

64

$

14,606  $

17,915 

$

217  $

— $

218
14
4
236  $

— $

178
—
178  $

— $

122
(2)
3
123

$

— $
64
—
64

$

— $

21,310
(1,704)
1,289
20,895  $

— $

6,273
16
6,289  $

— $

26,985
(800)
119
26,304 

$

— $

8,372
17
8,389

$

217  $
—
—
—
217  $

— $
—
—
— $

54

73
—
—
—
73

—
19
—
19

$

$
$

$

$

$

$

$

— $
—

—
— $
4,042  $

—
— 

— 
—
4,395

1,030  $

2,656

990  $
—
—
40
1,030  $

432  $
—
—
432  $

2,480
— 
— 
176 
2,656

2,175
— 
— 
2,175

$

$

$
$

$

$

$

$

$

(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 12 – Commitments and Contingencies. 

(2)  At December 31, 2020 and 2019, loans and leases in the consolidated credit card trust included $7.6 billion and $10.5 billion of seller’s interest. 
(3)  The retained senior securities were valued using quoted market prices or observable market inputs (Level 2 of the fair value hierarchy). 

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

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to 

the 
in  market  making  and  similar  activities  prior 
resecuritization  and,  accordingly,  no  gain  or  loss  on  sale  was 
recorded. Securities received from the resecuritization VIEs were 
recognized  at  their  fair  value  of  $6.1  billion,  $5.2  billion  and 
$4.1 billion during 2020, 2019 and 2018, respectively. In 2019 
and  2018,  substantially  all  of  the  securities  were  classified  as 
trading  account  assets.  All  of  the  securities  received  as 
resecuritization proceeds during 2020 were classified as trading 
account  assets.  Of  the  securities  received  as  resecuritizations 
proceeds during 2020, $2.4 billion, $2.1 billion and $1.7 billion 
were  classified  as  trading  account  assets,  debt  securities 
carried  at 
respectively. 
fair  value  and  HTM  securities, 
Substantially  all  of  the  trading  account  securities  and  debt 
securities  carried  at  fair  value  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  $3.5  billion  and  $3.7  billion  at 
December 31, 2020 and 2019. The weighted-average remaining 
life of bonds held in the trusts at December 31, 2020 was 6.8 
years.  There  were  no  significant  write-downs  or  downgrades  of 
assets or issuers during 2020, 2019 and 2018. 

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, 2020 and 2019. 

events  depend  on  the  undrawn  portion  of  the  HELOCs, 
performance of the loans, the amount of subsequent draws and 
the timing of related cash flows. 

Credit Card Securitizations 
The Corporation securitizes originated and purchased credit card 
loans.  The  Corporation’s  continuing  involvement  with  the 
securitization  trust  includes  servicing  the  receivables,  retaining 
an  undivided  interest  (seller’s  interest)  in  the  receivables,  and 
holding certain retained interests including subordinate interests 
in accrued interest and fees on the securitized receivables and 
cash reserve accounts. 

During 2020, 2019 and 2018, the Corporation issued  new 
senior  debt  securities  to  third-party  investors  from  the  credit 
card  securitization  trust  of  $1.0  billion,  $1.3  billion  and  $4.0 
billion, respectively. 

At  December  31,  2020  and  2019,  the  Corporation  held 
subordinate  securities  issued  by  the  credit  card  securitization 
trust  with  a  notional  principal  amount  of  $6.8  billion  and  $7.4 
billion. These securities serve as a form of credit enhancement 
to the senior debt securities and have a stated interest rate of 
zero  percent.  During  2020,  2019  and  2018,  the  credit  card 
securitization trust issued $161 million, $202 million and $650 
million, respectively, of these subordinate securities. 

transfers  securities, 

Resecuritization Trusts 
into 
The  Corporation 
resecuritization  VIEs  generally  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. 

typically  MBS, 

The  Corporation  resecuritized  $39.0  billion,  $24.4  billion 
and  $22.8  billion  of  securities  during  2020,  2019  and  2018, 
respectively.  Securities  transferred  into  resecuritization  VIEs 
were measured at fair value with changes in fair value recorded 

Other VIEs 

(Dollars in millions)
Maximum loss exposure (1) 
On-balance sheet assets 

Trading account assets (1) 
Debt securities carried at fair value (1) 
Loans and leases (1) 
Allowance for loan and lease losses (1) 
All other assets (1) 

Total (1) 

On-balance sheet liabilities 
Short-term borrowings 
Long-term debt
All other liabilities (1) 

Total (1) 

Total assets of VIEs (1) 

Consolidated

Unconsolidated
December 31, 2020

Total

Consolidated

Unconsolidated
December 31, 2019 

Total 

4,106  $

23,870  $

27,976  $

4,055  $

21,069  $

25,124 

2,080  $
—
2,108
(3)
54
4,239  $

$

 22
111
—

133  $
4,239  $

623  $
 9
184
(3)
22,553
23,366  $

 — $
—
5,658
5,658  $
77,984  $

2,703  $
 9
2,292
(6)
22,607
27,605  $

$

 22
111
5,658
5,791  $
82,223  $

2,213  $
 —
1,810
(2)
81
4,102  $

 — $
46
2

48  $
4,102  $

549  $

 10
533
—
19,354
20,446  $

— $
—
4,896
4,896  $
70,120  $

2,762 
 10
2,343 
(2) 
19,435 
24,548 

—
46 
4,898 
4,944 
74,222 

$

$

$

$

$
$

(1)  Prior-period amounts have been revised to remove certain entities that are no longer considered VIEs. 

include 

Customer VIEs 
Customer  VIEs 
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 $2.3 billion and $2.2 
billion at December 31, 2020 and 2019, including the notional 
amount  of  derivatives 
is  a 
to  which 
counterparty,  net  of  losses  previously  recorded,  and  the 

the  Corporation 

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

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benefits from investments in affordable housing partnerships of 
$1.2  billion,  $1.0  billion  and  $981  million  and  reported  pretax 
losses  in  other  income  of  $1.0  billion,  $882  million  and  $798 
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. 

NOTE 7 Goodwill and Intangible Assets 

Goodwill 
The  table  below  presents  goodwill  balances  by  business 
segment  and  All  Other  at  December  31,  2020  and  2019.  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 

2020

2019 

30,123  $

9,677
23,923
5,182
46
68,951  $

30,123 
9,677 
23,923 
5,182 
46 
68,951 

$

$

During  2020,  the  Corporation  completed  its  annual  goodwill 
impairment  test  as  of  June  30,  2020  using  a  quantitative 
assessment  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 quantitative assessments, see Note 1 – Summary of 
Significant Accounting Principles. 

Intangible Assets 
At  December  31,  2020  and  2019,  the  net  carrying  value  of 
intangible  assets  was  $2.2  billion  and  $1.7  billion.  During 
2020,  the  Corporation  recognized  a  $585  million  intangible 
asset,  which  is  being  amortized  over  a  10-year  life,  related  to 
the merchant contracts that were distributed to the Corporation 
from its merchant servicing joint venture. For more information, 
see Note 12 – Commitments and Contingencies. 

At  both  December  31,  2020  and  2019,  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  $95  million,  $112  million  and  $538  million  for 
2020, 2019 and 2018.

counterparty  to  the  CDOs.  The  Corporation’s  maximum  loss 
exposure  to  consolidated  and  unconsolidated  CDOs  totaled 
$298  million  and  $304  million  at  December  31,  2020  and 
2019. 

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, 2020 and 2019, the Corporation’s consolidated 
investment  VIEs  had  total  assets  of  $494  million  and  $104 
million. 
in 
unconsolidated  VIEs  with  total  assets  of  $5.4  billion  and  $5.1 
billion  at  December  31,  2020  and  2019.  The  Corporation’s 
maximum loss exposure associated with both consolidated and 
unconsolidated  investment  VIEs  totaled  $1.5  billion  and  $1.6 
billion at December 31, 2020 and 2019 comprised primarily of 
on-balance sheet assets less non-recourse liabilities. 

The  Corporation 

investments 

held 

also 

Leveraged Lease Trusts 
The  Corporation’s  net  investment  in  consolidated  leveraged 
lease  trusts  totaled  $1.7  billion  at  both  December  31,  2020 
and  2019.  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 $22.0 billion and 
$18.9  billion  at  December  31,  2020  and  2019.  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  $11.2  billion  and  $10.0 
billion,  including  unfunded  commitments  to  provide  capital 
contributions  of  $5.0  billion  and  $4.3  billion  at  December  31, 
2020  and  2019.  The  unfunded  commitments  are  expected  to 
be paid over the next five years. During 2020, 2019 and 2018, 
the  Corporation  recognized 

tax  credits  and  other  tax 

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NOTE 8 Leases 
The  Corporation  enters 
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 and Allowance for Credit Losses. 

lessor  and 

into  both 

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. 

The following table presents the net investment in sales-type 

and direct financing leases at December 31, 2020 and 2019. 

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$

$

$

$

December 31 

2020

10,000
10,474

3.38 %
8.4

2,149
474
2,623

 $

$

$

2019 

9,735 
10,093 

3.68 % 
8.2 

2,085 
498 
2,583 

851

 $

931 

2,039

2,009 

Lessee Arrangements 

(Dollars in millions)
Right-of-use asset 
Lease liabilities
Weighted-average discount rate used to 

calculate present value of future minimum 
lease payments

Weighted-average lease term (in years)

Lease Cost and Supplemental Information: 
Operating lease cost
Variable lease cost (1) 
Total lease cost (2) 

Right-of-use assets obtained in exchange for 

new operating lease liabilities (3) 
Operating cash flows from operating 

leases (4) 

Net Investment (1) 

(Dollars in millions)
Lease receivables
Unguaranteed residuals

December 31 

2020

2019 

$  17,627  $  19,312 
2,550 

2,303

(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 

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 measurements of lease liabilities. 

Total net investment in sales-type and direct

financing leases

$  19,930  $  21,862 

(1)  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  $6.9  billion  and  $5.8  billion  at 
December 31, 2020 and 2019. 

Maturity Analysis 
The  maturities  of  lessor  and  lessee  arrangements  outstanding 
at December 31, 2020 are presented in the table below based 
on undiscounted cash flows. 

The following table presents lease income at December 31, 

2020 and 2019. 

Lease Income 

(Dollars in millions)
Sales-type and direct financing leases 
Operating leases

Total lease income

December 31 

2020

2019 

$

$

 $

707
931

1,638  $

797 
891 
1,688 

Lessee Arrangements 
The  Corporation's  lessee  arrangements  predominantly  consist 
the 
of  operating 
Corporation's financing leases are not significant. 

for  premises  and  equipment; 

leases 

Lease terms may contain renewal and extension options and 
early  termination  features.  Generally,  these  options  do  not 
impact  the 
is  not 
reasonably certain that it will exercise the options. 

lease  term  because  the  Corporation 

The  following  table  provides  information  on  the  right-of-use 
assets,  lease  liabilities  and  weighted-average  discount  rates 
and lease terms at December 31, 2020 and 2019. 

Maturities of Lessor and Lessee Arrangements 

Operating 
Leases 

Lessor

Sales-type and 
Direct Financing 
Leases (2) 
December 31, 2020 

Lessee (1) 

Operating 
Leases 

843  $
748
630
479
339
886

5,424  $
4,934
3,637
2,089
1,143
1,668

1,927 
1,715 
1,454 
1,308 
1,087 
4,609 

$

(Dollars in millions)
2021
2022
2023
2024
2025
Thereafter
Total undiscounted 

cash flows

$

3,925

18,895

12,100 

Less: Net present 
value adjustment

Total (3) 

$

1,268
17,627  $

1,626 
10,474 

(1)  Excludes  $885  million  in  commitments  under  lessee  arrangements  that  have  not  yet 

(2) 

commenced with lease terms that will begin in 2021. 
Includes  $12.7  billion  in  commercial  lease  financing  receivables  and  $4.9  billion  in  direct/ 
indirect consumer lease financing receivables. 

(3)  Represents  lease  receivables  for  lessor  arrangements  and  lease  liabilities  for  lessee 

arrangements. 

NOTE 9 Deposits 
The  table  below  presents  information  about  the  Corporation’s  time  deposits  of  $100,000  or  more  at  December  31,  2020  and 
2019. The Corporation also had aggregate time deposits of $10.7 billion and $15.8 billion in denominations that met or exceeded 
the Federal Deposit Insurance Corporation (FDIC) insurance limit at December 31, 2020 and 2019. 

Time Deposits of $100,000 or More 

(Dollars in millions) 
U.S. certificates of deposit and other time deposits
Non-U.S. certificates of deposit and other time deposits

December 31, 2020 

December 31 
2019 

Three Months 
or Less 

Over Three 
Months to 
Twelve Months

Thereafter

Total

Total 

$

12,485  $

10,668  $

8,568

1,925

1,445  $
1,432

24,598  $
11,925

39,739 
13,034

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The scheduled contractual maturities for total time deposits at December 31, 2020 are presented in the table below. 

Contractual Maturities of Total Time Deposits 

(Dollars in millions)
Due in 2021
Due in 2022
Due in 2023
Due in 2024
Due in 2025
Thereafter

Total time deposits

U.S.

Non-U.S.

Total 

$

$

40,052  $

2,604
431
222
186
276
43,771  $

10,609  $
167
4
5
13
1,287

12,085  $

50,661 
2,771 
435 
227 
199 
1,563 
55,856 

NOTE 10 Federal Funds Sold or Purchased, Securities Financing Agreements, Short-term Borrowings 
and Restricted Cash 
The  table  below  presents  federal  funds  sold  or  purchased,  securities  financing  agreements  (which  include  securities  borrowed  or 
purchased under agreements to resell and securities loaned or sold under agreements to repurchase) and short-term borrowings. 
The Corporation elects to account for certain securities financing agreements and short-term borrowings under the fair value option. 
For more information on the fair value option, see Note 21 – Fair Value Option. 

(Dollars in millions)
Federal funds sold and securities borrowed or purchased under agreements to resell 

Average during year
Maximum month-end balance during year

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

Average during year
Maximum month-end balance during year

Short-term borrowings 
Average during year
Maximum month-end balance during year

n/a = not applicable 

Amount

Rate

Amount

Rate 

2020

2019 

$

$

309,945
451,179

192,479
206,493

22,486
30,118

0.29 %  $
n/a

279,610
281,684

0.69 %  $
n/a

201,797
203,063

0.54

n/a

24,301
36,538

1.73 % 
n/a 

2.31 % 
n/a 

2.42 

n/a 

Bank of America, N.A. maintains a global program to offer up 
to a maximum of $75.0 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  $3.9  billion  and  $11.7 
billion at December 31, 2020 and 2019. 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 
legally 
enforceable master securities lending agreements that give the 
Corporation, in the event of default by the counterparty, the right 

repurchase  agreements  or 

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,  2020  and  2019.  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.

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Securities Financing Agreements 

(Dollars in millions)
Securities borrowed or purchased under agreements to resell (3) 
Securities loaned or sold under agreements to repurchase
Other (4) 
Total

Securities borrowed or purchased under agreements to resell (3) 
Securities loaned or sold under agreements to repurchase 
Other (4) 
Total

Gross Assets/ 
Liabilities (1) 

Amounts Offset 

Net Balance 
Sheet Amount 
December 31, 2020 

Financial 
Instruments (2) 

Net Assets/ 
Liabilities 

$
$

$

$
$

$

492,387  $
358,652  $

16,210

(188,329)  $
(188,329)  $

—

304,058  $
170,323  $

16,210

(272,351)  $
(158,867)  $

(16,210)

374,862  $

(188,329)  $

186,533  $

(175,077)  $

December 31, 2019 

434,257  $
324,769  $

15,346 

(159,660)  $
(159,660)  $

— 

274,597  $
165,109  $

15,346 

340,115  $

(159,660)  $

180,455  $

(244,486)  $
(141,482)  $
(15,346) 
(156,828)  $

31,707 
11,456 
— 
11,456 

30,111 
23,627 
— 
23,627 

(1) 

(2) 

Includes activity where uncertainty exists as to the enforceability of certain master netting agreements under bankruptcy laws in some countries or industries. 
Includes securities collateral received or pledged under repurchase or securities lending agreements where there is a legally enforceable master netting agreement. These amounts are not offset 
on the Consolidated Balance Sheet, but are shown as a reduction to derive a net asset or liability. Securities collateral received or pledged where the legal enforceability of the master netting 
agreements is uncertain is excluded from the table. 

(3)  Excludes repurchase activity of $14.7 billion and $12.9 billion reported in loans and leases on the Consolidated Balance Sheet at December 31, 2020 and 2019. 
(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 
December 31, 2020 

Greater than 
90 Days (1) 

Total 

$

$

$

$

158,400  $

19,140
16,210

193,750  $

129,455  $

18,766
15,346

163,567  $

122,448  $
271
—
122,719  $

32,149  $

1,029
—
33,178  $

December 31, 2019 

122,685  $
3,329
—
126,014  $

25,322  $

1,241
—
26,563  $

22,684  $

2,531
—
25,215  $

21,922  $

2,049
—
23,971  $

335,681 
22,971 
16,210 
374,862 

299,384 
25,385 
15,346 
340,115 

Securities Sold 
Under Agreements 
to Repurchase 

Securities 
Loaned

Other

Total 

$

$

$

$

195,167  $
8,633
14,752
113,142
3,987
335,681  $

173,533  $

10,467
14,933
96,576
3,875
299,384  $

December 31, 2020 
5  $

1,628
21,125
213
—
22,971  $

December 31, 2019 
1  $

2,014
20,026
3,344
—
25,385  $

—  $

1,217
14,931
62
—
16,210  $

—  $

258
15,024
64
—
15,346  $

195,172 
11,478 
50,808 
113,417 
3,987 
374,862 

173,534 
12,739 
49,983 
99,984 
3,875 
340,115

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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,  2020  and  2019,  the  Corporation  held 
restricted  cash  included  within  cash  and  cash  equivalents  on 
the  Consolidated  Balance  Sheet  of  $7.0  billion  and  $24.4 
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 11 Long-term Debt 
Long-term debt consists of borrowings having an original maturity of one year or more. The table below presents the balance of long-
term debt at December 31, 2020 and 2019, and the related contractual rates and maturity dates as of December 31, 2020. 

(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

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 (2) 
Other

Total notes issued by Bank of America, N.A.

Other debt 
Structured liabilities
Nonbank VIEs (2) 
Other

Weighted-
average Rate

Interest Rates

Maturity Dates 

2020

2019 

December 31 

3.05  %
0.74

0.25 - 8.05  %
0.09 - 4.96

2021 - 2051  $
2021 - 2044

4.89
1.15

6.71
1.03

3.34
0.33
6.00

2.94 - 8.57
0.88 - 1.41

6.45 - 8.05
1.03

2021 - 2045
2022 - 2026

2027 - 2066
2056

3.34
0.28 - 0.49
6.00

2023
2021 - 2041
2036

0.99

0.01 - 7.72

2021 - 2034

174,385  $

16,788
17,033

23,337
799

738
1
233,081

511
2,323
1,883

599
—
6,296
683
12,295

16,792
757
9
17,558

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 

$

262,934  $

Total notes issued by nonbank and other entities
Total long-term debt

Includes total loss-absorbing capacity compliant debt. 

(1) 
(2)  Represents liabilities of consolidated VIEs included in total long-term debt on the Consolidated Balance Sheet. 

During  2020,  the  Corporation  issued  $56.9  billion  of  long-
term debt consisting of $43.8 billion of notes issued by Bank of 
America  Corporation,  $4.8  billion  of  notes  issued  by  Bank  of 
America,  N.A.  and  $8.3  billion  of  other  debt.  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. 

During  2020,  the  Corporation  had  total  long-term  debt 
maturities  and  redemptions  in  the  aggregate  of  $47.1  billion 
consisting  of  $22.6  billion  for  Bank  of  America  Corporation, 
$11.5  billion  for  Bank  of  America,  N.A.  and  $13.0  billion  of 
other  debt.  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. 

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, 2020 and 
2019,  the  amount  of 
foreign  currency-denominated  debt 
translated into U.S. dollars included in total long-term debt was 
$54.6 billion and $49.6 billion. Foreign currency contracts may 
be  used  to  convert  certain  foreign  currency-denominated  debt 
into U.S. dollars. 

At December 31, 2020, long-term debt of consolidated VIEs 
in  the  table  above  included  debt  from  credit  card,  residential 
mortgage,  home  equity  and  other  VIEs  of  $6.3  billion,  $491 
million,  $178  million  and  $111  million,  respectively.  Long-term 
debt of VIEs is collateralized by the assets of the VIEs. For more 
information,  see  Note  6  –  Securitizations  and  Other  Variable 
Interest Entities.

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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  3.02  percent,  3.29 
percent and 0.71 percent, respectively, at December 31, 2020, 
and 3.26 percent, 3.55 percent and 1.92 percent, respectively, 
at  December  31,  2019.  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  caused  by  interest  rate  volatility.  The 
Corporation’s goal is to manage interest rate sensitivity so that 
movements in interest rates do not have a significantly adverse 
effect  on  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 $4.8 billion at December 31, 2020 was 
issued  by  BofA  Finance LLC, a consolidated finance subsidiary 

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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, 2020. 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 
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. 

repayment 

linked 

terms 

to 

Long-term Debt by Maturity 

(Dollars in millions)
Bank of America Corporation 

Senior notes
Senior structured notes
Subordinated notes
Junior subordinated notes 

Total Bank of America Corporation

Bank of America, N.A. 

Senior notes
Subordinated notes 
Advances from Federal Home Loan Banks
Securitizations and other Bank VIEs (1) 
Other

Total Bank of America, N.A.

Other debt 

Structured Liabilities
Nonbank VIEs (1) 
Other 

Total other debt
Total long-term debt

2021

2022

2023

2024

2025

Thereafter

Total 

$

8,888  $

15,380  $

469
371
—
9,728

1,340
—
502
4,056
112
6,010

2,034
393
 —
17,807

975
 —
3
1,241
16
2,235

23,872  $
597
—
 —
24,469

21,407  $
190
3,351
 —
24,948

15,723  $
549
5,537
 —
21,809

105,903  $

13,194
14,484
 739
134,320

511
 —
1
977
189
1,678

—
 —
—
—
—
—

—
 —
18
—
279
297

8
 1,883
75
22
87
2,075

4,613
1
—
4,614
20,352  $

2,414
 —
 —
2,414
22,456  $

2,221
 —
 —
2,221
28,368  $

655
 —
 —
655
25,603  $

859
 —
 —
859
22,965  $

6,030
 756
 9
6,795
143,190  $

$

191,173 
17,033 
24,136 
 739 
233,081 

2,834 
 1,883 
599 
6,296 
683 
12,295 

16,792 
 757 
  9
17,558 
262,934 

(1)  Represents liabilities of consolidated VIEs included in total long-term debt on the Consolidated Balance Sheet. 

NOTE 12 Commitments and Contingencies 
In the normal course of business, the Corporation enters into a 
number of off-balance sheet commitments. These commitments 
expose the Corporation to varying degrees of credit and market 
risk  and  are  subject  to  the  same  credit  and  market  risk 
limitation  reviews  as  those  instruments  recorded  on  the 
Consolidated Balance Sheet. 

Credit Extension Commitments 
The Corporation enters into commitments to extend credit such 
as  loan  commitments,  SBLCs  and  commercial  letters  of  credit 
to  meet  the  financing  needs  of  its  customers.  The  following 
table  includes  the  notional  amount  of  unfunded  legally  binding 
lending  commitments  net  of  amounts  distributed 
(i.e., 
syndicated  or  participated)  to  other  financial  institutions.  The 
distributed  amounts  were  $10.5  billion  and  $10.6  billion  at 
December  31,  2020  and  2019.  The  carrying  value  of  these 
commitments  at  December  31,  2020  and  2019,  excluding 
commitments  accounted  for  under  the  fair  value option, was 

$1.9  billion  and  $829  million,  which  primarily  related  to  the 
reserve  for  unfunded  lending  commitments.  The  carrying  value 
of  these  commitments  is  classified  in  accrued  expenses  and 
other liabilities on the Consolidated Balance Sheet. 

The 

includes 

table  below 

Legally binding commitments to extend credit generally have 
specified  rates  and  maturities.  Certain  of  these  commitments 
have  adverse  change  clauses  that  help  to  protect  the 
Corporation against deterioration in the borrower’s ability to pay. 
the  notional  amount  of 
commitments  of  $4.0  billion  and  $4.4  billion  at  December  31, 
2020  and  2019  that  are  accounted  for  under  the  fair  value 
option. However, the table excludes cumulative net fair value of 
$99  million  and  $90  million  at  December  31,  2020  and  2019 
on these commitments, which is classified in accrued expenses 
and  other  liabilities.  For  more  information  regarding  the 
Corporation’s  loan  commitments  accounted  for  under  the  fair 
value option, see Note 21 – Fair Value Option.

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Credit Extension Commitments 

(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

$

$

$

$

Expire in One 
Year or Less 

Expire After One 
Year Through 
Three Years 

Expire After Three 
Years Through 
Five Years 
December 31, 2020 

Expire After 
Five Years

Total 

109,406  $
710
19,962
886
130,964
384,955
515,919  $

97,454  $

1,137
21,311
1,156
121,058
376,067
497,125  $

171,887  $
2,992
12,038
197
187,114
—
187,114  $

139,508  $
8,738
2,397
25
150,668
—
150,668  $

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  $

16,091  $
29,892
1,257
27
47,267
—
47,267  $

24,487  $
34,134
408
25
59,054
—
59,054  $

436,892 
42,332 
35,654 
1,135 
516,013 
384,955 
900,968 

443,640 
43,570 
36,943 
1,500 
525,653 
376,067 
901,720 

(1)  At December 31, 2020 and 2019, $4.8 billion and $5.1 billion of these loan commitments were 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 $25.0 billion and $10.2 billion at December 31, 2020, and $27.9 billion and $8.6 billion at December 31, 2019. Amounts in the table include consumer SBLCs of $500 million 
and $413 million at December 31, 2020 and 2019. 

(3)  At December 31, 2020 and 2019, included are letters of credit of $1.8 billion and $1.4 billion related to certain liquidity commitments of VIEs. For more information, see Note 6 – Securitizations 

(4) 

and Other Variable Interest Entities. 
Includes business card unused lines of credit. 

Other Commitments 
At  December  31,  2020  and  2019,  the  Corporation  had 
commitments to purchase loans (e.g., residential mortgage and 
commercial  real  estate)  of  $93  million  and  $86  million,  which 
upon  settlement  will  be  included  in  trading  account  assets, 
loans or LHFS, and commitments to purchase commercial loans 
of $645 million and $1.1 billion, which upon settlement will be 
included in trading account assets. 

At  December  31,  2020  and  2019,  the  Corporation  had 
commitments  to  purchase  commodities,  primarily  liquefied 
natural  gas,  of  $582  million  and  $830  million,  which  upon 
settlement will be included in trading account assets. 

At  December  31,  2020  and  2019,  the  Corporation  had 
commitments to enter into resale and forward-dated resale and 
securities  borrowing  agreements  of  $66.5  billion  and  $97.2 
billion, and commitments to enter into forward-dated repurchase 
and  securities  lending  agreements  of  $32.1  billion  and  $24.9 
billion.  These  commitments  generally  expire  within  the  next  12 
months. 

At  December  31,  2020  and  2019,  the  Corporation  had  a 
commitment  to  originate  or  purchase  up  to  $3.9  billion  and 
$3.3  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 

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,  2020  and 
2019,  the  notional  amount  of  these  guarantees  totaled  $7.1 
billion and $7.3 billion. At both December 31, 2020 and 2019, 
the  Corporation’s  maximum  exposure 
these 
guarantees  totaled  $1.1  billion,  with  estimated  maturity  dates 
between 2033 and 2039. 

related 

to 

Indemnifications 
In  the  ordinary  course  of  business,  the  Corporation  enters  into 
various  agreements  that  contain  indemnifications,  such  as  tax 
indemnifications,  whereupon  payment  may  become  due  if 
certain external events occur, such as a change in tax law. The 
indemnification  clauses  are  often  standard  contractual  terms 
and were entered into in the normal course of business based 
on an assessment that the risk of loss would be remote. These 
agreements  typically  contain  an  early  termination  clause  that 
permits  the  Corporation  to  exit  the  agreement  upon  these 
events.  The  maximum  potential 
future  payment  under 
indemnification  agreements  is  difficult  to  assess  for  several 
reasons,  including  the  occurrence  of  an  external  event,  the 
inability  to  predict  future  changes  in  tax  and  other  laws,  the 
difficulty in determining how such laws would apply to parties in 
contracts, the absence of exposure limits contained in standard 
contract  language  and  the  timing  of  any  early  termination 
clauses.  Historically,  any  payments  made  under 
these 
guarantees  have  been  de  minimis.  The  Corporation  has 
assessed the probability of making such payments in the future 
as remote. 

Merchant Services 
Prior  to  July  1,  2020,  a  significant  portion  of  the  Corporation's 
merchant processing activity was performed by a joint venture in 
which the Corporation held a 49 percent ownership interest. 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 on  June  30, 2020. Effective  July 
1,  2020,  the  Corporation  received  its  share  of  the  joint 
venture's  merchant  contracts  and  began  performing  merchant 
processing services for these merchants. While merchants bear 
responsibility  for  any  credit  or  debit  card  charges  properly 
reversed  by  the  cardholder,  the  Corporation,  in  its  role  as 
merchant acquirer, may be held liable for any reversed charges 
that  cannot  be  collected  from  the  merchants  due  to,  among 
other things, merchant fraud or insolvency.

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162 Bank of America 2020

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The  Corporation,  as  a  card  network  member  bank,  also 
sponsors  other  merchant  acquirers,  principally  its  former  joint 
venture  partner  with  respect  to  merchant  contracts  distributed 
to  that  partner  upon  the  termination  of  the  joint  venture.  If 
charges  are  properly  reversed  after  a  purchase  and  cannot  be 
collected from either the merchants or merchant acquirers, the 
Corporation may be held liable for these reversed charges. The 
ability  to  reverse  a  charge  is  primarily  governed  by  the 
applicable regulatory and card network rules, which include, but 
are not limited to, the type of charge, type of payment used and 
time limits. For the six-months ended December 31, 2020, the 
Corporation  processed  an  aggregate  purchase  volume  of 
$339.2  billion.  The  Corporation’s  risk  in  this  area  primarily 
relates  to  circumstances  where  a  cardholder  has  purchased 
goods or services for future delivery. The Corporation mitigates 
this risk by requiring cash deposits, guarantees, letters of credit 
or  other  types  of  collateral  from  certain  merchants.  The 
Corporation’s  reserves  for  contingent  losses  and  the  losses 
incurred  related  to  the  merchant  processing  activity  were  not 
significant. The Corporation continues to monitor its exposure in 
this area due to the potential economic impacts of COVID-19. 

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. 

Fixed Income Clearing Corporation Sponsored Member 
Repo Program 
The  Corporation  acts  as  a  sponsoring  member  in  a  repo 
program  whereby  the  Corporation  clears  certain  eligible  resale 
and repurchase agreements through the Government Securities 
Division  of  the  Fixed  Income  Clearing  Corporation  on  behalf  of 
clients  that  are  sponsored  members  in  accordance  with  the 
Fixed  Income  Clearing  Corporation’s  rules.  As  part  of  this 
the  payment  and 
program, 
performance  of  its  sponsored  members  to  the  Fixed  Income 
Clearing  Corporation.  The  Corporation’s  guarantee  obligation  is 

the  Corporation  guarantees 

62539financials

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secured  by  a  security  interest  in  cash  or  high-quality  securities 
collateral placed by clients with the clearinghouse and therefore, 
the  potential  for  the  Corporation  to  incur  significant  losses 
under  this  arrangement  is  remote.  The  Corporation’s  maximum 
potential exposure, without taking into consideration the related 
collateral,  was  $22.5  billion  and  $9.3  billion  at  December  31, 
2020 and 2019. 

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 
these  agreements  are 
potential 
approximately  $8.8  billion  and  $8.7  billion  at  December  31, 
2020  and  2019.  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 6 – Securitizations and 
Other Variable Interest Entities. 

future  payments  under 

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, 
other 
transactions. 

agreements 

brokerage 

prime 

and 

the  parent  company, 

Guarantees of Certain Long-term Debt 
fully  and 
The  Corporation,  as 
unconditionally  guarantees  the  securities  issued  by  BofA 
Finance  LLC,  a  consolidated 
the 
Corporation,  and  effectively  provides 
full  and 
unconditional  guarantee  of  trust  securities  issued  by  certain 
statutory  trust  companies  that  are  100  percent  owned  finance 
subsidiaries of the Corporation. 

finance  subsidiary  of 

the 

for 

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  and  warranties. 
Breaches of 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). 

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

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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,  2020  and  2019  was  $8.5  billion  and  $10.7 
billion. These balances included $2.9 billion and $3.7 billion at 
December  31,  2020  and  2019  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. 

During  2020,  the  Corporation  received  $89  million  in  new 
repurchase  claims  that  were  not  time-barred.  During  2020, 
$2.4  billion  in  claims  were  resolved,  including  $168  million  of 
claims that were deemed time-barred. 

Reserve and Related Provision 
The  reserve  for  representations  and  warranties  obligations  and 
corporate  guarantees  was  $1.3  billion  and  $1.8  billion  at 
December  31,  2020  and  2019  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  its  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 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. 

As  a  matter  develops,  the  Corporation,  in  conjunction  with 
any  outside  counsel  handling  the  matter,  evaluates  whether 
such  matter  presents  a  loss  contingency  that  is  probable  and 
estimable, and, for the matters disclosed in this Note, whether 
a loss in excess of any accrued liability is reasonably possible in 
future periods. Once the loss contingency is deemed to be both 
probable  and  estimable,  the  Corporation  will  establish  an 
accrued liability and record a corresponding amount of litigation-
related  expense.  The  Corporation  continues  to  monitor  the 
matter for 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  $823  million  and  $681 
million was recognized in 2020 and 2019. 

For  the  matters  disclosed  in  this  Note  for  which  a  loss  in 
future periods is reasonably possible and estimable (whether in 
excess  of  an  accrued  liability  or  where  there  is  no  accrued 
liability)  and  for  representations  and  warranties  exposures,  the 
Corporation’s  estimated  range  of  possible  loss  is  $0  to  $1.3 

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billion in excess of the accrued liability, if any, as of December 
31, 2020. 

The  accrued  liability  and  estimated  range  of  possible  loss 
are  based  upon  currently  available  information  and  subject  to 
significant  judgment,  a  variety  of  assumptions  and  known  and 
unknown  uncertainties.  The  matters  underlying  the  accrued 
liability and estimated range of possible loss are unpredictable 
and may 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  representations  and  warranties 
regarding  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. 

Ambac v. Countrywide I 
The Corporation, and several 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. 

its 

fraudulent 

On May 16, 2017, the First Department issued its decisions 
on  the  parties'  cross-appeals  of  the  trial  court's  October  22, 
2015  summary  judgment  rulings.  Ambac  appealed  the  First 
Department's  rulings  requiring  Ambac  to  prove  all  of  the 
elements  of 
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 
for 
dismissing 
reimbursements of attorneys' fees. On June 27, 2018, the New 
York Court of Appeals affirmed the First Department rulings that 
Ambac appealed.

inducement  claim, 

Ambac's 

claim 

loan; 

and 

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On  December  4,  2020,  the  New  York  Supreme  Court 
inducement  claim.  Ambac 

fraudulent 

dismissed  Ambac’s 
appealed the dismissal. 

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 
the  Corporation.  Ambac  seeks 
damages in excess of $600 million, plus punitive damages. 

liability  against 

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. On 
December  8,  2020,  the  New  York  Supreme  Court  dismissed 
Ambac’s complaint. Ambac appealed the dismissal. 

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. 

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 
inquiries  and 
investigations, and responding to the proceedings. 

cooperating  with 

these 

is 

LIBOR 
The  Corporation,  BANA  and  certain  Merrill  Lynch  entities  have 
been named as defendants along with most of the other 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 
fraud  and  breach  of  contract  claims,  and  seek 
law 
compensatory,  treble  and  punitive  damages,  and  injunctive 
relief.  All  but  one  of  the  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  against  Bank  of  America 
entities based on alleged trader conduct. 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 against the 
Corporation, BANA and certain Merrill Lynch entities. 

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. 

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.

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NOTE 13 Shareholders’ Equity 

Common Stock 

Declared Quarterly Cash Dividends on Common Stock (1) 

Declaration Date
January 19, 2021
October 21, 2020
July 22, 2020
April 22, 2020
January 29, 2020

Record Date
March 5, 2021
December 4, 2020
September 4, 2020 
June 5, 2020
March 6, 2020

Payment Date 
March 26, 2021
December 24, 2020
September 25, 2020
June 26, 2020
March 27, 2020

(1) 

In 2020, and through February 24, 2021. 

Dividend 
Per Share 
0.18 
$
0.18 
0.18 
0.18 
0.18 

The cash dividends paid per share of common stock were $0.72 
$0.66 and $0.54 for 2020, 2019 and 2018, respectively. 

The  following  table  summarizes  common  stock  repurchases 

during 2020, 2019 and 2018. 

Common Stock Repurchase Summary 

(in millions)

2020

2019

2018 

Total share repurchases, including CCAR 

capital plan repurchases

227

956

676 

Purchase price of shares repurchased

 and retired 
CCAR capital plan repurchases 
Other authorized repurchases
Total shares repurchased 

$ 7,025   $ 25,644  $ 16,754 
3,340 
$ 7,025   $ 28,144  $ 20,094 

2,500

—

During 2020, the Board of Governors of the Federal Reserve 
System  (Federal  Reserve)  announced  that  due  to  economic 
uncertainty  resulting  from  COVID-19,  all  large  banks  would  be 
required to suspend share repurchase programs in the third and 
fourth quarters of 2020, except for repurchases to offset shares 
awarded  under  equity-based  compensation  plans,  and  to  limit 
dividends to existing rates that do not exceed the average of the 
last four quarters’ net income. 
Federal  Reserve’s 

share 
repurchases  aligned  with 
to 
voluntarily  suspend  repurchases  during  the  first  half  of  2020. 
The  suspension  of  the  Corporation's  repurchases  did  not 
include  repurchases  to  offset  shares  awarded  under  its  equity-
based compensation plans. 

the  Corporation's  decision 

directives 

regarding 

The 

During  2020,  the  Corporation  repurchased  and  retired  227 
million  shares  of  common  stock,  which  reduced  shareholders’ 
equity by  $7.0 billion. 

During  2020,  in  connection  with  employee  stock  plans,  the 
Corporation issued 66 million shares of its common stock and, 
to  satisfy  tax  withholding  obligations,  repurchased  26  million 
shares  of  its  common  stock.  At  December  31,  2020,  the 
Corporation  had  reserved  513  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, $1.4 billion and $1.5 billion for 2020, 2019 and 2018, 
respectively. 

On January 24, 2020, the Corporation issued 44,000 shares 
of Fixed-to-Floating Rate Non-Cumulative Preferred Stock, Series 
MM for $1.1 billion. Dividends are paid semi-annually during the 

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fixed-rate  period,  then  quarterly  during  the  floating-rate  period. 
The  Series  MM  preferred  stock  has  a  liquidation  preference  of 
$25,000  per  share  and  is  subject  to  certain  restrictions  in  the 
event the Corporation fails to declare and pay full dividends. 

On  October  29,  2020,  the  Corporation  issued  44,000 
shares  of  4.375%  Non-Cumulative  Preferred  Stock,  Series  NN 
for $1.1 billion, with quarterly dividend payments commencing in 
February 2021. The Series NN preferred stock has a liquidation 
preference  of  $25,000  per  share  and  is  subject  to  certain 
restrictions in the event the Corporation fails to declare and pay 
full dividends. 

On January 28, 2021, the Corporation issued 36,000 shares 
of  4.125%  Non-Cumulative  Preferred  Stock,  Series  PP  for 
$915  million,  with  quarterly  dividends  commencing  in  May 
2021.  The  Series  PP  preferred  stock  has  a  liquidation 
preference  of  $25,000  per  share  and  is  subject  to  certain 
restrictions in the event the Corporation fails to declare and pay 
full dividends. 

In  2020,  the  Corporation  fully  redeemed  Series  Y  preferred 
stock  for  $1.1  billion.  Additionally,  on  January  29,  2021,  the 
Corporation  fully  redeemed  Series  CC  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  of  30  consecutive  trading  days,  the  closing  price  of 
common  stock  exceeds  130  percent  of  the  then-applicable 
conversion price of the Series L Preferred Stock. If a conversion 
of  Series  L  Preferred  Stock  occurs  at  the  option  of  the  holder, 
subsequent  to  a  dividend  record  date  but  prior  to  the  dividend 
payment  date,  the  Corporation  will  still  pay  any  accrued 
dividends payable.

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The table below presents a summary of perpetual preferred stock outstanding at December 31, 2020. 

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) 

1
6
7

6
2
5
3
9

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Series B 

Series E (2) 

Series F 

Series G 

Series L 

7% Cumulative 
Redeemable 

June 
1997

Floating Rate Non-
Cumulative 

November 
2006

Floating Rate Non-
Cumulative 

Adjustable Rate Non-
Cumulative 

7.25% Non-Cumulative 
Perpetual Convertible 

March 
2012

March 
2012

January 
2008

September 
2011

Series T

6% Non-cumulative 

Series U (4) 

Series X (4) 

Series Z (4) 

Fixed-to-Floating Rate 
Non-Cumulative 

May 
2013

Fixed-to-Floating Rate 
Non-Cumulative 

September 
2014

Fixed-to-Floating Rate 
Non-Cumulative 

October 
2014

Series AA (4) 

Fixed-to-Floating Rate 
Non-Cumulative 

Series CC (2) 

6.200% Non-Cumulative 

Series DD (4) 

Fixed-to-Floating Rate 
Non-Cumulative 

Series EE (2) 

6.000% Non-Cumulative 

Series FF (4) 

Fixed-to-Floating Rate 
Non-Cumulative 

Series GG (2) 

6.000% Non-Cumulative 

Series HH (2) 

5.875% Non-Cumulative 

Series JJ (4) 

Fixed-to-Floating Rate 
Non-Cumulative 

Series KK (2) 

5.375% Non-Cumulative 

March 
2015

January 
2016

March 
2016

April 
2016

March 
2018

May 
2018

July 
2018

June 
2019

June 
2019

Series LL (2) 

5.000% Non-Cumulative 

Series MM (4) 

Fixed-to-Floating Rate 
Non-Cumulative 

Series NN (2) 

4.375% Non-Cumulative 

September 
2019

January 
2020
October 
2020

Series 1 (5) 

Series 2 (5) 

Series 4 (5) 

Series 5 (5) 

Floating Rate Non-
Cumulative 

November 
2004

Floating Rate Non-
Cumulative 

March 
2005

Floating Rate Non-
Cumulative 

November 
2005

Floating Rate Non-
Cumulative 

March 
2007

Issuance costs and certain adjustments

7,110  $

100  $

1

7.00 %  $

7  $

12,691

25,000

317

3-mo. LIBOR + 35 bps (3) 

1.02

1,409

100,000

141

3-mo. LIBOR + 40 bps (3) 

4,066.67

4,926

100,000

493

3-mo. LIBOR + 40 bps (3) 

4,066.67

—

13 

6 

20 

n/a 

On or after 
November 15, 2011 

On or after 
March 15, 2012 

On or after 
March 15, 2012 

3,080,182

1,000

3,080

7.25 %

72.50

223

n/a 

354

100,000

35

6.00 %

6,000.00

2

After May 7, 2019 

40,000

25,000

1,000 

80,000

25,000

2,000 

56,000

25,000

1,400 

76,000

25,000

1,900 

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

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

52.00

52 

On or after 
June 1, 2023 

62.50

125 

On or after 
September 5, 2024 

65.00

91 

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 

58.75

138 

94,000

25,000

2,350 

54,000

25,000

1,350

34,160

25,000

854

40,000

25,000

1,000 

5.875% to, but excluding, 
3/15/28; 3-mo. LIBOR + 
293.1 bps thereafter

6.000 %

5.875 %

5.125% to, but excluding, 
6/20/24; 3-mo. LIBOR + 
329.2 bps thereafter

55,900

25,000

1,398

52,400

25,000

1,310

5.375 %

5.000 %

1.50

1.47

51.25

1.34

1.25

44,000

25,000

1,100

4.300 %

43.48

44,000

25,000

1,100

4.375 %

3,275

30,000

98

3-mo. LIBOR + 75 bps (6) 

9,967

30,000

299

3-mo. LIBOR + 65 bps (6) 

7,010

30,000

210

3-mo. LIBOR + 75 bps (3) 

14,056

30,000

3-mo. LIBOR + 50 bps (3) 

422

(348) 

0.29

0.75

0.76

1.02

1.02

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 
January 28, 2025 
On or after 
November 3, 2025 

On or after 
November 28, 2009 

On or after 
November 28, 2009 

On or after 
November 28, 2010 

On or after 
May 21, 2012 

81 

50 

51 

75 

66 

48 

13 

3 

10 

9 

17 

Total

3,931,440

$  24,510 

(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

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NOTE 14 Accumulated Other Comprehensive Income (Loss) 
The table below presents the changes in accumulated OCI after-tax for 2020, 2019 and 2018. 

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(Dollars in millions)
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

Net change

Balance, December 31, 2020

Debt Securities 
$

Debit Valuation 
Adjustments

Derivatives 

Employee 
Benefit Plans 

Foreign 
Currency

(1,206)  $
(393)
—
(3,953)
(5,552)  $
5,875

323  $

4,799
5,122  $

(1,060)  $
(220)
—
749
(531)  $
(963)
(1,494)  $
(498)
(1,992)  $

(831)  $
(189)
57
(53)
(1,016)  $
616
(400)  $
826
426  $

(3,192)  $
(707)
—
(405)
(4,304)  $
136
(4,168)  $
(98)
(4,266)  $

(793)  $
239
—
(254)
(808)  $ 

(86)

(894)  $
(52)

(946)  $

Total 

(7,082) 
(1,270) 
57 
(3,916) 
(12,211) 
5,578 
(6,633) 
4,977 
(1,656) 

$

$

$

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 2020, 2019 and 2018. 

(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 (gains) 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) reclassified into earnings (1) 

Net change

Total other comprehensive income (loss)

Pretax 

Tax 
effect 
2020

After-
tax

Pretax 

Tax 
effect 
2019

After-
tax

Pretax 

Tax 
effect 
2018 

After-
tax 

$  6,819  $  (1,712)  $  5,107  $  8,020  $ (2,000)  $  6,020  $ (5,189)  $  1,329  $ (3,860) 
(93) 
(3,953) 

48
(1,952)

(123)
(5,312)

(193)
7,827

(145)
5,875

103
(1,609)

(411)
6,408

(308)
4,799

30
1,359

(669)
19
(650)

156
(4)
152

(513)
15
(498)

(1,276)
18
(1,258)

289
6
295

(987)
24
(963)

952
26
978

(224)
(5)
(229)

728 
21 
749 

1,098

(268)

830

692

(156)

536

(232)

74

(158) 

6
(12)
(6)
1,092

(381)
261
5
(115)

 (1)
3
2
(266)

80
(63)
 —
17

 5
(9) 
(4)
826

(301)
198
  5
(98)

 104
2
106
798

41
150
3
194

(26)
  —
(26)
(182)

(21)
(36)
(1)
(58)

78
  2
80
616

20
114
2
136

165
 (27)
138
(94)

(703)
171
11
(521)

(40)
  7
(33)
41

164
(46)
(2)
116

125 
 (20)
105 
(53) 

(539) 
125 
9 
(405) 

(251)
(1)
(252)

(203) 
(51) 
(254) 
$  6,483  $  (1,506)  $  4,977  $  7,438  $ (1,860)  $  5,578  $ (5,106)  $  1,190  $ (3,916) 

(13)
(110)
(123)

(8)
(149)
(157)

(195)
98
(97)

(65)
(21)
(86)

(52)
89
37

(52)
—
(52)

199
1
200

(1)  Reclassifications of pretax debt securities, DVA and foreign currency (gains) losses are recorded in other income in the Consolidated Statement of Income. 
(2)  Reclassifications of pretax employee benefit plan costs are recorded in other general operating expense in the Consolidated Statement of Income. 

NOTE 15 Earnings Per Common Share 
The calculation of EPS and diluted EPS for 2020, 2019 and 2018 is presented below. For more information on the calculation of 
EPS, see Note 1 – Summary of Significant Accounting Principles. 

(In millions, except per share information)
Earnings per common share 
Net income
Preferred stock dividends

Net income applicable to common shareholders

Average common shares issued and outstanding
Earnings per common share

Diluted earnings per common share 
Net income applicable to common shareholders
Average common shares issued and outstanding
Dilutive potential common shares (1) 

Total diluted average common shares issued and outstanding

Diluted earnings per common share

(1) 

Includes incremental dilutive shares from RSUs, restricted stock and warrants.

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2020

2019

2018 

17,894
(1,421)
16,473
8,753.2

 $

 $

27,430  $
(1,432)
25,998  $
9,390.5

1.88  $

2.77  $

28,147 
(1,451) 
26,696 
10,096.5 
2.64 

16,473
8,753.2
43.7
8,796.9

 $

25,998  $
9,390.5
52.4
9,442.9

1.87  $

2.75  $

26,696 
10,096.5 
140.4 
10,236.9 
2.61 

$

$

$

$

$

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For  2020,  2019  and  2018,  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,  average  options  to  purchase  four  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  2019  and 
2018,  average  warrants  to  purchase  three  million  and  136 
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 16 Regulatory Requirements and 
Restrictions 
The  Federal  Reserve,  Office  of  the  Comptroller  of  the  Currency 
(OCC)  and  FDIC  (collectively,  U.S.  banking  regulators)  jointly 
establish  regulatory  capital  adequacy  rules,  including  Basel  3, 
for U.S. banking organizations. As a financial holding company, 
the  Corporation  is  subject  to  capital  adequacy  rules  issued  by 

the  Federal  Reserve.  The  Corporation’s  banking  entity  affiliates 
are subject to capital adequacy rules issued by the OCC. 

The  Corporation  and  its  primary  banking  entity  affiliate, 
BANA, are Advanced approaches institutions under Basel 3. As 
Advanced  approaches  institutions,  the  Corporation  and  its 
banking  entity  affiliates  are  required  to  report  regulatory  risk-
based  capital  ratios  and  risk-weighted  assets  under  both  the 
Standardized  and  Advanced  approaches.  The  approach  that 
yields  the  lower  ratio  is  used  to  assess  capital  adequacy, 
including under the Prompt Corrective Action (PCA) framework. 

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, 2020 and 
2019 for the Corporation and BANA. 

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 (5) 
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) (6) 
Tier 1 leverage ratio

Supplementary leverage exposure (in billions) (7) 
Supplementary leverage ratio

Risk-based capital metrics: 

Common equity tier 1 capital
Tier 1 capital
Total capital (5) 
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) (6) 
Tier 1 leverage ratio

Supplementary leverage exposure (in billions)
Supplementary leverage ratio

Bank of America Corporation

Bank of America, N.A. 

Standardized 
Approach (1, 2) 

Advanced 
Approaches (1) 

Regulatory 
Minimum (3) 

Standardized 
Approach (1, 2) 

Advanced 
Approaches (1) 

Regulatory 
Minimum (4) 

December 31, 2020 

$  176,660
200,096
237,936
1,480

$  176,660
200,096
227,685
1,371

$  164,593
164,593
181,370
1,221

$  164,593 
164,593 
170,922 
1,014 

11.9 %
13.5
16.1

12.9 %
14.6
16.6

9.5 %

11.0
13.0

13.5 %
13.5
14.9

16.2 %
16.2
16.9

7.0 % 
8.5 
10.5 

$

2,719

  $

2,719

$

2,143

  $

2,143

7.4 %

7.4 %

$

2,786

7.2 %

4.0

5.0

7.7 %

7.7 %

5.0 

$

2,525

6.5 %

6.0 

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

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

December 31, 2019 

$ 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 

(1 ) As of December 31, 2020, capital ratios are calculated using the regulatory capital rule that allows a five-year transition period related to the adoption of CECL. 
(2 ) Derivative exposure amounts are calculated using the standardized approach for measuring counterparty credit risk at December 31, 2020 and the current exposure method at December 31, 

2019. 

(3 ) The capital conservation buffer and global systemically important bank surcharge were 2.5 percent at both December 31, 2020 and 2019. At December 31, 2020, the Corporation's stress capital 
buffer  of 2.5  percent  was  applied  in  place  of  the  capital  conservation  buffer  under  the  Standardized  approach.  The  countercyclical  capital  buffer  for  both  periods  was zero.  The  SLR  minimum 
includes a leverage buffer of 2.0 percent. 

(4 ) Risk-based capital regulatory minimums at December 31, 2020 and 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 are the percent required to be considered well capitalized under the PCA framework. 

(5 ) 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. 

(6 ) Reflects total average assets adjusted for certain Tier 1 capital deductions. 
(7 ) Supplementary leverage exposure for the Corporation at December 31, 2020 reflects the temporary exclusion of U.S. Treasury securities and deposits at Federal Reserve Banks.

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require 

to  meet 

institutions 

The  capital  adequacy  rules  issued  by  the  U.S.  banking 
regulators 
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, 2020 and 2019, the Corporation and its banking 
entity affiliates were well capitalized. 

In  response  to  the  uncertainty  arising  from  the  pandemic, 
the  Federal  Reserve  required  all  large  banks  to  suspend  share 
repurchase programs during the second half of 2020, except for 
repurchases  to  offset  shares  awarded  under  equity-based 
compensation  plans,  and  to  limit  common  stock  dividends  to 
existing  rates  that  did  not  exceed  the  average  of  the  last  four 
quarters’  net  income.  In  December  2020,  the  Federal  Reserve 
announced  that  beginning  in  the  first  quarter  of  2021,  large 
banks  would  be  permitted  to  pay  common  stock  dividends  at 
existing  rates  and  to  repurchase  shares  in  an  amount  that, 
when  combined  with  dividends  paid,  does  not  exceed  the 
average  of  net  income  over  the  last  four  quarters.  For  more 
information, see Note 13 – Shareholders’ Equity. 

requires 

Other Regulatory Matters 
The  Federal  Reserve 
the  Corporation’s  bank 
subsidiaries  to  maintain  reserve  requirements  based  on  a 
percentage  of  certain  deposit  liabilities.  The  average  daily 
in  excess  of  vault  cash, 
reserve  balance  requirements, 
maintained  by  the  Corporation  with  the  Federal  Reserve  Bank 
were  $3.8  billion  for  2020,  reflecting  the  Federal  Reserve's 
reduction of the reserve requirement to zero in the first quarter 
due to COVID-19, and $14.6 billion for 2019. At December 31, 
the  Corporation  had  cash  and  cash 
2020  and  2019, 
equivalents  in  the  amount  of  $4.9  billion  and  $6.3  billion,  and 
securities  with  a  fair  value  of  $16.8  billion  and  $14.7  billion 
that were segregated in compliance with securities regulations. 
Cash  held  on  deposit  with  the  Federal  Reserve  Bank  to  meet 
requirements  and  cash  and  cash  equivalents 
reserve 
segregated  in  compliance  with  securities  regulations  are 
components of restricted cash. For more information, see Note 
10  –  Federal  Funds  Sold  or  Purchased,  Securities  Financing 
Agreements,  Short-term  Borrowings  and  Restricted  Cash .
addition, at December 31, 2020 and 2019, the Corporation had 
cash deposited with clearing organizations of $10.9 billion and 
$7.6  billion  primarily 
the 
Consolidated Balance Sheet. 

in  other  assets  on 

recorded 

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  2020,  the  Corporation  received  dividends  of 
$10.3 billion from BANA and $62 million from Bank of America 
California, N.A. 

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  2021,  BANA  can  declare  and  pay  dividends  of 
approximately $10.3 billion to the Corporation plus an additional 
amount equal to its retained net profits for 2021 up to the date 

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of  any  such  dividend  declaration.  Bank  of  America  California, 
N.A.  can  pay  dividends  of  $198  million  in  2021  plus  an 
additional amount equal to its retained net profits for 2021 up 
to the date of any such dividend declaration. 

NOTE 17 Employee Benefit Plans 

Pension and Postretirement Plans 
The  Corporation  sponsors  a  qualified  noncontributory  trusteed 
pension  plan 
(Qualified  Pension  Plan),  a  number  of 
noncontributory nonqualified  pension plans, and  postretirement 
health  and  life  plans  that  cover  eligible  employees.  Non-U.S. 
pension plans sponsored by the Corporation vary based on the 
country and local practices. 

The Qualified Pension Plan has a balance guarantee feature 
for  account  balances  with  participant-selected  investments, 
applied  at  the  time  a  benefit  payment  is  made  from  the  plan 
that  effectively  provides  principal  protection  for  participant 
balances  transferred  and  certain  compensation  credits.  The 
Corporation  is  responsible  for  funding  any  shortfall  on  the 
guarantee feature. 

Benefits earned under the Qualified Pension Plan have been 
frozen. Thereafter, the cash balance accounts continue to earn 
investment  credits  or  interest  credits  in  accordance  with  the 
terms of the plan document. 

The Corporation has an annuity contract that guarantees the 
payment  of  benefits  vested  under  a  terminated  U.S.  pension 
plan 
(Other  Pension  Plan).  The  Corporation,  under  a 
supplemental agreement, may be responsible for or benefit from 
actual  experience  and  investment  performance  of  the  annuity 
assets.  The  Corporation  made  no  contribution  under  this 
agreement  in  2020  or  2019.  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. 

In  

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,  2020  and  2019.  The  estimate  of 
the 
Corporation’s  PBO  associated  with  these  plans  considers 
various  actuarial  assumptions, 
for 
mortality 
rate 
rates  and  discount 
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  2020  and  2019  resulted  in  increases  to  the  PBO  of 
approximately  $1.9  billion  and  $2.2  billion  at  December  31, 
2020  and  2019.  Significant  gains  and  losses  related  to 
changes in the PBO for 2020 and 2019 primarily resulted from 
changes in the discount rate.

including  assumptions 
rates.  The  discount 

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Pension and Postretirement Plans (1) 

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(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
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 

2020
$  20,275 
2,468
—
—
—
(967)

 n/a
 n/a

2019
$ 18,178
3,187
—
—
—
(1,090)
n/a
n/a

$  21,776 

$ 20,275

$  15,361 
—
500
—
—
—
1,533
(967)

 n/a
 n/a

$ 14,144
—
593
—
—
—
1,714
(1,090)
n/a
n/a

$  16,427 

$ 15,361

$

$

5,349 
—
5,349 

$

$

4,914
—
4,914

$  16,427 
5,349
—
16,427

$ 15,361
4,914
—
15,361

2.57 %
n/a
5.02 %

3.32 %
n/a
5.06 %

(1)  The measurement date for all of the above plans was December 31 of each year reported. 
n/a = not applicable 

The  Corporation’s  estimate  of  its  contributions  to  be  made 
to the Non-U.S. Pension Plans, Nonqualified and Other Pension 
Plans, and Postretirement Health and Life Plans in 2021 is $29 
million,  $93  million  and  $14  million, 
respectively.  The 
Corporation  does  not  expect  to  make  a  contribution  to  the 
Qualified  Pension  Plan 
in  2021.  It  is  the  policy  of  the 
Corporation  to  fund  no  less  than  the  minimum  funding  amount 

Plans with ABO and PBO in Excess of Plan Assets 

(Dollars in millions)
PBO
ABO
Fair value of plan assets

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Non-U.S. 
Pension Plans 

Nonqualified and Other 
Pension Plans 

2020

2019

2020

2019

Postretirement 
Health and Life Plans 
2019 
2020

2,696 
379
23
1
(61)
(57)
 n/a
97
3,078 

2,887 
20
49
1
3
(61)
396
(57)
 n/a
102
3,340 

$

$

$

$

$

428
(690)
(262)  $

$

3,253 
(175)
87
3,340

1.37 %
4.11
1.58

  $

$

  $

$

 $

 $

$

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

1.81 %
4.10
1.53

2,666 
285
86
—
—
(248)
 n/a
 n/a
2,789 

2,919 
1
90
—
—
—
243
(248)
 n/a
 n/a
3,005 

812 
(1,028)

$

$

$

$

$

(216)  $

$

3,005 
(216)
—
3,005

2.33 %
4.00
4.49

  $

  $

  $

$

$

 $

$

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

3.20 %
4.00
4.52

199
1
6
110
—
(174)
1
 n/a
143

989
5
32
110
—
—
43
(173)
1
—
1,007 

$

$

$

$

— $

(864)
(864)  $

 n/a
 n/a
 n/a
1,007 

2.48 %
 n/a
 n/a

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

3.27 % 
n/a 
n/a 

required  by  the  Employee  Retirement  Income  Security  Act  of 
1974 (ERISA). 

Pension Plans with ABO and PBO in excess of plan assets as 
of  December  31,  2020  and  2019  are  presented  in  the  table 
below.  For  these  plans,  funding  strategies  vary  due  to  legal 
requirements and local practices. 

Non-U.S. 
Pension Plans 

Nonqualified 
and Other 
Pension Plans 

2020

2019

2020

2019 

$

$

900
841
211

744  $
720
191

1,028  $
1,028
1

988 
988 
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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)

Qualified Pension Plan
2019

2018

2020

$

— $

500
(1,154) 
173
— 
(481)  $ 

—
593
(1,088)
135
—
(360) 

 $

—
563
(1,136)
147
 —
(426) 

$ 

$

$

$

3.32 %
6.00
 n/a

4.32 %
6.00

n/a

3.68 %
6.00

n/a

Nonqualified and 
Other Pension Plans 
2019

2018

2020

$

1
90
(71)
50
— 
70  $

1
113
(95)
34
—
53

 $

$

1
105
(84)
43
 —
65

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Non-U.S. Pension Plans 
2019

2018 

2020

20
49
(66)
9
  8
20

 $

 $

17
65
(99)
6
 4
(7) 

$

$ 

19 
65 
(126) 
 10
 12
(20) 

1.81 %
2.57
4.10

2.60 %
4.13
4.49

2.39 % 
4.37 
4.31 

Postretirement Health 
and Life Plans 
2019

2018 

2020

5
32
(4)
29
(2)
60

$

$

5
38
(5)
(24)
(2)
12

 $

 $

6
36 
(6) 
(27) 
(3) 
  6

$

$

$

$

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 

3.20 %
2.77
4.00

4.26 %
3.73
4.00

3.58 %
3.19
4.00

3.27 %
2.00
n/a

4.25 %
2.00

n/a

3.58 % 
2.00 

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. 

Pretax Amounts included in Accumulated OCI and OCI 

trend 

rates  affect 

Assumed  health  care  cost 

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 
6.25  percent  for  2021,  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 
2020. 

(Dollars in millions)
Net actuarial loss (gain)
Prior service cost (credits)

Amounts recognized in accumulated OCI

$ 3,912  $ 3,865  $ 646  $  577  $ 987  $ 1,008  $

$ 3,912  $ 3,865  $ 628  $  559  $ 987  $ 1,008  $

—

—

18

18

—

—

66
(4)
62

Qualified 
Pension Plan 
2019

2020

Non-U.S. 
Pension Plans 
2019

2020

Nonqualified 
and Other 
Pension Plans 
2019

2020

Postretirement 
Health and 
Life Plans

Total 

2020

2019

2020

2019 

Current year actuarial loss (gain)
Amortization of actuarial gain (loss) and 

prior service cost

Current year prior service cost (credit)

Amounts recognized in OCI

$ 219  $  (385)  $

79

$  110  $

29

 $  130  $

47

(173)
—
46  $ (520) $

(135)
—

$ 

(12)
3
70

(7)
2

$  105  $

(50)
—
(21) $

(34)
—
96

$

(27)
—
20

172
Bank of America 2020
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$

$

$

48
(6)
42

 $ 5,593  $ 5,480 
12 
$ 5,607  $ 5,492 

14

99

 $ 374  $ 

(46) 

26
—

(150) 
2 
 $  125  $ 115  $ (194)

(262)
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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 
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. 

levels  and 

funding 

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 

2021 Target Allocation 

Asset Category 
Equity securities
Debt securities
Real estate
Other

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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 
returns, 
through  analysis  of  historical  market 
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  2021  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 
$274  million  (1.26  percent  of  total  plan  assets)  and  $315 
million  (1.55  percent  of  total  plan  assets)  at  December  31, 
2020 and 2019. 

Percentage 

Qualified 
Pension Plan 
15 - 50%
45 - 80%
0 - 10%
0 - 5%

Non-U.S. 
Pension Plans 
0 - 25%
40 - 70%
0 - 15%
10 - 40%

Nonqualified 
and Other 
Pension Plans 
0 - 5% 
95 - 100% 
0 - 5% 
0 - 5%  

Fair Value Measurements 
For  more  information  on  fair  value  measurements,  including  descriptions  of  Level  1,  2  and  3  of  the  fair  value  hierarchy  and  the 
valuation methods employed by the Corporation, see Note 1 – Summary of Significant Accounting Principles and Note 20 – Fair Value 
Measurements. Combined plan investment assets measured at fair value by level and in total at December 31, 2020 and 2019 are 
summarized in the Fair Value Measurements table.

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Fair Value Measurements 

(Dollars in millions)
Cash and short-term investments 

Level 1

Level 2
Level 3
December 31, 2020

Total

Level 1

Level 2
Level 3
December 31, 2019 

Total 

Money market and interest-bearing cash
Cash and cash equivalent commingled/mutual funds 

$ 

1,380  $
—

—  $

—  $ 

1,380  $ 

 383

  —

 383

1,426  $
—

—  $

250

—  $ 
—

1,426 
250 

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 

Real estate commingled/mutual funds

Limited partnerships
Other investments (1) 

4,590
—
—
1,021
1,224

4,438
134
73

—
—
5

1,238
 5,021
 1,967
1,122
1,319

—
1,542
—

20
184
401

7
  —
  —
—
—

—
—
—

943
83
691

5,835
 5,021
 1,967
2,143
2,543

4,438
1,676
73

963
267
1,097

4,403
—
  —
748
804

4,655
147
91

—
—
11

890
3,676
2,684
1,015
1,439

—
1,355
—

18
173
390

Total plan investment assets, at fair value

$  12,865  $  13,197  $ 

1,724  $  27,786  $  12,285  $  11,890  $ 

8
—
—
—
—

—
—
—

5,301 
3,676 
2,684 
1,763 
2,243 

4,655 
1,502 
91 

927
90
636

945 
263 
1,037 
1,661  $  25,836 

(1)  Other investments include commodity and balanced funds of $246 million and $233 million, insurance annuity contracts of $664 million and $614 million and other various investments of $187 

million and $190 million at December 31, 2020 and 2019. 

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 2020, 2019 and 2018. 

Level 3 Fair Value Measurements 

(Dollars in millions)
Fixed income 

U.S. government and agency securities

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 

8

$

927
90
636

1,661  $

9  $

5
885
82
588

2020 

 — $

(4)
2
6
4  $

2019 

—  $

—
33
—
6

1,569  $

39  $

9  $

93
831
85
74
1,092  $

2018 

—  $

(7)
52
(12)
—
33  $

$

$

$

$

$

$

 (1) $

20
(9)
49
59  $

(1)  $

(5)
9
8
42
53  $

7

943 
83 
691 
1,724 

8 

— 
927 
90 
636 
1,661 

—  $

9 

(81)
2
9
514
444  $

5 
885 
82 
588 
1,569 

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.

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(Dollars in millions) 
2021
2022
2023
2024
2025
2026 - 2030

Qualified 
Pension Plan (1) 

Non-U.S. 
Pension Plans (2) 

Nonqualified 
and Other 
Pension Plans (2) 

Postretirement 
Health and 
Life Plans (3) 

$

856  $
943
939
943
934
4,474

127  $
134
143
135
140
675

244  $
245
229
224
221
977

79 
76 
74 
70 
67 
290 

(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. 

Defined Contribution Plans 
The  Corporation  maintains  qualified  and  non-qualified  defined 
contribution retirement plans. The Corporation recorded expense 
of $1.2 billion, $1.0 billion and $1.0 billion in 2020, 2019 and 
2018 related to the qualified defined contribution plans. At both 
December  31,  2020  and  2019,  189  million  shares  of  the 
Corporation’s  common  stock  were  held  by  these  plans. 
Payments  to  the  plans  for  dividends  on  common  stock  were 
$138 million, $133 million and $115 million in 2020, 2019 and 
2018, respectively. 

Certain  non-U.S.  employees  are  covered  under  defined 
contribution  pension  plans  that  are  separately  administered  in 
accordance with local laws. 

NOTE 18 Stock-based Compensation Plans 
The  Corporation  administers  a  number  of  equity  compensation 
plans,  with  awards  being  granted  predominantly  from  the  Bank 
of  America  Key  Employee  Equity  Plan  (KEEP).  Under  this  plan, 
600  million  shares  of  the  Corporation’s  common  stock  are 
authorized to be used for grants of awards. 

During  2020  and  2019,  the  Corporation  granted  86  million 
and  94  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  2020  and  2019,  61  million  and 
71  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,  25  million 
and 23 million of the RSUs granted in 2020 and 2019 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, $2.1 billion and $1.8 billion, and the related income tax 
benefit  was  $505  million,  $511  million  and  $433  million  for 

2020,  2019  and  2018,  respectively.  At  December  31,  2020, 
there  was  an  estimated  $2.0  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. 

Restricted Stock and Restricted Stock Units 
The total fair value of restricted stock and restricted stock units 
vested  in  2020,  2019  and  2018  was  $2.3  billion,  $2.6  billion 
and  $2.3  billion,  respectively.  The  table  below  presents  the 
status  at  December  31,  2020  of  the  share-settled  restricted 
stock and restricted stock units and changes during 2020. 

Stock-settled Restricted Stock and Restricted Stock 
Units 

Outstanding at January 1, 2020
Granted
Vested
Canceled

Outstanding at December 31, 2020

Shares/Units 
157,909,315  $

83,604,782
(68,578,284)
(4,982,584)
167,953,229

Weighted-
average Grant 
Date Fair Value 
27.93 
33.01 
27.38 
30.88 
30.60 

Cash-settled Restricted Units 
At  December  31,  2020,  approximately  two  million  cash-settled 
restricted  units  remain  outstanding.  In  2020,  2019  and  2018, 
the  amount  of  cash  paid  to  settle  the  RSUs  that  vested  was 
$81 million, $84 million and $1.3 billion, respectively. 

NOTE 19 Income Taxes 
The  components  of  income  tax  expense  for  2020,  2019  and 
2018 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

2020

2019

2018 

$

$

1,092  $
1,076
670
2,838

(799)
(233)
(705)
(1,737)
1,101  $

1,136  $

901
852
2,889

2,001
223
211
2,435
5,324  $

816 
1,377 
1,203 
3,396 

2,579 
240 
222 
3,041 
6,437 

Total income tax expense does not reflect the tax effects of 
items  that  are  included  in  OCI  each  period.  For  more

Bank of America 2020 175
Bank of America 2020 175

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information,  see  Note  14  –  Accumulated  Other  Comprehensive 
Income  (Loss).  Other  tax  effects  included  in  OCI  each  period 
resulted in an expense of $1.5 billion and $1.9 billion in 2020 
and 2019 and a benefit of $1.2 billion in 2018. 

Income  tax  expense  for  2020,  2019  and  2018  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 2020, 2019 and 2018. 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  2020,  2019  and  2018  are  presented  in  the  table 
below. 

Reconciliation of Income Tax Expense 

(Dollars in millions)
Expected U.S. federal income tax expense
Increase (decrease) in taxes resulting from: 
State tax expense, net of federal benefit
Affordable housing/energy/other credits
Tax law changes
Tax-exempt income, including dividends
Share-based compensation
Changes in prior-period UTBs, including interest
Nondeductible expenses
Rate differential on non-U.S. earnings
Other

Total income tax expense (benefit)

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

2020

2019

2018 

$ 

1,175  $ 

2,197  $ 

1,773 

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) 

Settlements
Expiration of statute of limitations

Balance, December 31

$ 

238

99

238

401

395 

406 

(172)
—
—
1,340  $ 

(1,102)
(541)
(18)
1,175  $ 

(371) 
(6) 
— 
2,197 

(1)  The  sum  of  the  positions  taken  during  prior  years  differs  from  the  $(41)  million,  $(613) 
million and $144 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. 

At December 31, 2020, 2019 and 2018, the balance of the 
Corporation’s  UTBs  which  would,  if  recognized,  affect  the 
Corporation’s effective tax rate was $976 million, $814 million 
and  $1.6  billion,  respectively.  Included  in  the  UTB  balance  are 
some  items  the  recognition  of  which  would  not  affect  the 
effective  tax  rate,  such  as  the  tax  effect  of  certain  temporary 
differences, the portion of gross state UTBs that would be offset 
by  the  tax  benefit  of  the  associated  federal  deduction  and  the 
portion  of  gross  non-U.S.  UTBs  that  would  be  offset  by  tax 
reductions in other jurisdictions. 

Amount

Percent

Amount

Percent

Amount

Percent 

2020

2019

2018 

$ 

3,989

21.0 %  $ 

6,878

21.0 %  $ 

7,263

21.0 % 

728
(2,869)
(699)
(346)
(129)
(41)
324
218
(74)
1,101

$ 

3.8
(15.1)
(3.7) 
(1.8)
(0.7)
(0.2)
1.7
1.1
(0.3)
5.8 %  $ 

1,283
(2,365)
—
(433)
(225)
(613)
290
504
5
5,324

3.9
(7.2)
 —
(1.3)
(0.7)
(1.9)
0.9
1.5
0.1

16.3 %  $ 

1,367
(1,888)
  —
(413)
(257)
144
302
98
(179)
6,437

4.0 
(5.5) 
 —
(1.2) 
(0.7) 
0.4 
0.9 
0.3 
(0.6) 
18.6 % 

It is reasonably possible that the UTB balance may decrease 
by  as  much  as  $166  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 interest expense of $9 million in 
2020,  an  interest  benefit  of  $19  million  in  2019  and  interest 
expense  of  $43  million  in  2018.  At  December  31,  2020  and 
2019,  the  Corporation’s  accrual  for  interest  and  penalties  that 
related  to  income  taxes,  net  of  taxes  and  remittances,  was 
$130 million and $147 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  significant  business  operations  examine  tax  returns 
periodically  (continuously  in  some  jurisdictions).  The  following 
table  summarizes  the  status  of  examinations  by  major 
jurisdiction  for  the  Corporation  and  various  subsidiaries  at 
December 31, 2020. 

Tax Examination Status 

United States
California
New York
United Kingdom (2) 

Years under 
Examination (1) 

2017-2020 
2012-2017 
2016-2018 
2018 

Status at 
December 31 
2020 
Field Examination 
Field Examination 
Field Examination 
Field Examination 

(1)  All tax years subsequent to the years shown remain subject to examination. 
(2)  Field examination for tax year 2019 to begin in 2021. 

Significant components of the Corporation’s net deferred tax 
assets  and  liabilities  at  December  31,  2020  and  2019  are 
presented in the following table.

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Deferred Tax Assets and Liabilities 

(Dollars in millions)
Deferred tax assets 

Net operating loss carryforwards
Allowance for credit losses
Security, loan and debt valuations
Lease liability
Employee compensation and retirement benefits
Accrued expenses
Credit carryforwards
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
Fixed assets
ESG-related tax credit investments
Available-for-sale securities
Other

Gross deferred tax liabilities
Net deferred tax assets

December 31 

2020

2019 

$ 

7,717  $ 
4,701
2,571
2,400
1,582
1,481
484
1,412
22,348
(2,346)

7,417 
2,354 
1,860 
2,321 
1,622 
1,719 
183 
1,203 
18,679 
(1,989) 

20,002

16,690 

3,101
2,296
1,957
1,930
1,701
1,570
12,555

$ 

7,447  $ 

2,933 
2,246 
1,505 
1,577 
100 
1,885 
10,246 
6,444 

On  January  1,  2020,  the  Corporation  adopted  the  CECL 
accounting  standard.  The  transition  adjustment  included  a  tax 
benefit  of  $760  million  in  retained  earnings,  which  increased 
deferred tax assets by a corresponding amount. 

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, 2020. 

Net Operating Loss and Tax Credit Carryforward Deferred 
Tax Assets 

(Dollars in millions) 
Net operating losses -

Deferred 
Tax Asset 

Valuation 
Allowance 

Net 
Deferred 
Tax Asset 

First Year 
Expiring 

U.S.

$

36  $

—  $

36

 After 2028 

Net operating losses -

U.K. (1) 

Net operating losses -

other non-U.S.

Net operating losses -

U.S. states (2) 
Foreign tax credits

5,896

506

1,279
484

—

5,896

None 

(441)

(579)
(484)

65

Various 

700
— 

Various 
After 2028 

(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 

the benefit of federal deductions were $1.6 billion and $733 million. 

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,  2020,  U.S.  federal  income  taxes  had  not 
been  provided  on  approximately  $5.0  billion  of  temporary 

associated  with 

non-U.S. 
differences 
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. 

investments 

in 

NOTE 20 Fair Value Measurements 
Under applicable accounting standards, fair value is defined as 
the exchange price that would be received for an asset or paid 
to  transfer  a  liability  (an  exit  price)  in  the  principal  or  most 
advantageous  market  for  the  asset  or  liability  in  an  orderly 
transaction  between  market  participants  on  the  measurement 
date. The Corporation determines the fair values of its financial 
instruments under applicable accounting standards that require 
an entity to maximize the use of observable inputs and minimize 
the use of unobservable inputs. The Corporation categorizes its 
financial instruments into three levels based on the established 
fair value hierarchy 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 21 – Fair Value 
Option. 

Valuation Techniques 
The  following  sections  outline  the  valuation  methodologies  for 
the  Corporation’s  assets  and  liabilities.  While  the  Corporation 
believes  its  valuation  methods  are  appropriate  and  consistent 
with  other  market  participants, 
the  use  of  different 
methodologies  or  assumptions  to  determine  the  fair  value  of 
certain financial instruments could result in a different estimate 
of fair value at the reporting date. 

During 2020, 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

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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 
is 
inherent  credit 
embedded  within  the  quoted  market  prices  or  is  implied  by 
considering loan performance when selecting comparables. 

risk.  The  borrower-specific  credit 

risk 

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 

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 
factors, 
principally from reviewing the issuer’s financial statements and 
changes in credit ratings made by one or more rating agencies. 

information  and  other 

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, 
in  which  case,  quantitative-based 
or  are  unobservable, 
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.  In  addition,  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. 

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. 

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Recurring Fair Value 
Assets and liabilities carried at fair value on a recurring basis at December 31, 2020 and 2019, 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
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) 

Fair Value Measurements 

December 31, 2020 

Level 1

Level 2

Level 3 

Netting 
Adjustments (1) 

Assets/Liabilities 
at Fair Value 

1,649  $

—  $

—  $

—  $

1,649 

—

108,856

45,219
—
36,372
5,753

—
—

87,344
15,624

115,266

—
—
—
—
—
—
—
115,266

93
—
2,619
2,712
—
—
9,898

3,051
22,817
31,372
20,884

21,566
8,440

108,130
416,175

1,114

61,849
5,260
631
16,491
13,999
2,640
16,598
118,582

—
506
8,625
9,131
5,964
1,349
3,850

—

—
1,359
227
354

75
1,365

3,380
2,751

—

—
—
378
—
18
71
176
643

—
267
—
267
717
236
1,970

—

—
—
—
—

—
—

—
(387,371)

—

—
—
—
—
—
—
—
—

—
—
—
—
—
—
—

108,856 

48,270 
24,176 
67,971 
26,991 

21,641 
9,805 

198,854 
47,179 

116,380 

61,849 
5,260 
1,009 
16,491 
14,017 
2,711 
16,774 
234,491 

93 
773 
11,244 
12,110 
6,681 
1,585 
15,718 

Total assets (5) 

Liabilities 

Interest-bearing deposits in U.S. offices 
Federal funds purchased and securities loaned or sold under 

$

$

232,493  $

772,037  $

9,964  $

(387,371)  $

627,123 

— $

 481

$

— $

— $

 481

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

Total liabilities (5) 

—

135,391

9,425
38,189
5,853
—
53,467
14,907
—
12,297
—

139
4,235
8,043
5,420
17,837
412,881
5,874
4,014
31,036

—

—
—
—
16
16
6,219
—
—
1,164

—

135,391 

—
—
—
—
—
(388,481)
—
—
—

9,564 
42,424 
13,896 
5,436 
71,320 
45,526 
5,874 
16,311 
32,200 

$

80,671  $

607,514  $

7,399  $

(388,481)  $

307,103 

(3) 

(1)  Amounts represent the impact of legally enforceable master netting agreements and also cash collateral held or placed with the same counterparties. 
(2) 

Includes $22.2 billion of GSE obligations. 
Includes  securities  with  a  fair  value  of  $16.8  billion  that  were  segregated  in  compliance  with  securities  regulations  or  deposited  with  clearing  organizations.  This  amount  is  included  in  the 
parenthetical disclosure on the Consolidated Balance Sheet. Trading account assets also includes precious metal inventories of $576 million that are accounted for at the lower of cost or net 
realizable value, which is the current selling price less any costs to sell. 
Includes MSRs of $1.0 billion which are classified as Level 3 assets. 

(4) 
(5)  Total recurring Level 3 assets were 0.35 percent of total consolidated assets, and total recurring Level 3 liabilities were 0.29 percent of total consolidated liabilities.

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(Dollars in millions)
Assets 

Fair Value Measurements 

December 31, 2019 

Level 1

Level 2

Level 3 

Time deposits placed and other short-term investments
Federal funds sold and securities borrowed or purchased under 

$

1,000

$

—

$

agreements to resell
Trading account assets: 

U.S. Treasury and agency securities
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

Total liabilities (5) 

$

$

$

—

49,517
—
53,597
3,965

—
—

107,079
14,079

67,332

—
—
—
—
—
—
—
67,332

3
—
—
400
403
—
—
11,782

201,675

—

—

13,140
38,148
10,751
—
62,039
11,904
—
13,927
—

87,870

50,364

4,157
25,226
32,619
23,854

24,324
8,786

118,966
328,442

1,196

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

16,008

282
4,144
11,310
5,478
21,214
320,479
3,941
1,507
33,826

$

$

$

$

$

397,483

$

—

—

—
1,507
239
482

—
1,553

3,781
2,226

—

—
—
424
—
2
65
108
599

—
—
299
—
299
693
375
2,360

10,333

—

—

—
2
—
15
17
4,764
—
—
1,149

5,930

Netting 
Adjustments (1) 

Assets/Liabilities 
at Fair Value 

$

—  $

1,000 

—

—
—
—
—

—
—

—
(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 

$

$

(304,262)  $

605,704 

—  $

508 

—

—
—
—
—
—
(298,918)
—
—
—

16,008 

13,422 
42,294 
22,061 
5,493 
83,270 
38,229 
3,941 
15,434 
34,975 

$

(298,918)  $

192,365 

(3) 

(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. 
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.

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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 2020, 2019 and 
2018,  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) 

Gross 

Purchases  Sales 

Issuances  Settlements 

Gross 
Transfers 
into 
Level 3 

Gross 
Transfers 
out of 
Level 3 

Balance 
December 31 

Change in 
Unrealized 
Gains 
(Losses) in 
Net Income 
Related to 
Financial 
Instruments 
Still Held (2) 

(Dollars in millions) 
Year Ended December 31, 2020 
Trading account assets: 

Corporate securities, trading loans and other  $  1,507  $
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

Other debt securities carried at fair value – Non-

agency residential MBS

Loans and leases (5,6) 
Loans held-for-sale (5,6) 
Other assets (6,7) 
Trading account liabilities – Equity securities
Trading account liabilities – Corporate securities 

and other

Long-term debt (5) 

Year Ended December 31, 2019 
Trading account assets: 

Total trading account assets
Net derivative assets (liabilities) (4,8) 
AFS debt securities: 

Non-agency residential MBS
Non-U.S. securities
Other taxable securities
Tax-exempt securities
Total AFS debt securities
Other debt securities carried at fair value – Non-

agency residential MBS

Loans and leases (5,6) 
Loans held-for-sale (5,6) 
Other assets (6,7) 
Trading account liabilities – Equity securities
Trading account liabilities – Corporate securities 

and other

Long-term debt (5,8) 

Corporate securities, trading loans and other  $  1,558  $
Equity securities
Non-U.S. sovereign debt
Mortgage trading loans, ABS and other MBS

239
482
1,553
3,781
(2,538)

424
2
65
108
599

299
693
375
2,360
(2)

(15)
(1,149)

276
465
1,635
3,934
(935)

(138)  $
(43)
45
(120)
(256)
(235)

(1)  $
—
(46)
(3)
(50)
—

(2)
1
—
(21)
(22)

26
(4)
26
(288)
1

8
(46)

3
—
—
3
6

—
—
(28)
3
—

—
2

105  $
(12)
46
99
238
(37)

—  $
—
(12)
(2)
(14)
—

430  $(242)  $

78
76
577 

(53)
(61)
(746)
1,161  (1,102)
(646)

120 

23
—
9
—
32

(54)
(1)
(4)
—
(59)

— 
145
— 
178
—

(180)
(76)
(489)
(4)
—

(7)
(104)

(3)
—

534  $(390)  $

38
1
662 

(87)
—
(899)
1,235  (1,376)
(837)

298 

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)

—

10  $
—
—
11
21
—

(282)  $ 
(3)
(39)
(96)
(420)
(112)

639  $ 

58
150
757
1,604
(235)

(564)  $
(49)
(253)
(493)
(1,359)
178

1,359  $
227
354
1,440
3,380
(3,468)

—
—
—
—
—

—
22
691
224
—

—
(47)

18  $
—
—
—
18
—

—
—
—
—
—

—
217
36
179
—

(1)

(40)

(44)
(1)
—
(169)
(214)

(24)
(161)
(119)
(506)
—

1
218

158
17
1
265
441

190
98
93
5
—

—
(52)

(130)
—
—
(10)
(140)

(44)
—
(313)
(2)
1

—
14

(578)  $  699  $ 

(9)
(51)
(175)
(813) 
(97)

79
39
738
1,555
147 

(40)
—
(5)
—
(45)

(17)
(57)
(245)
(683)
—

—

180

206
—
61
108
375

155
—
59
5
—

—

(350)

(439)  $
(46)
(6)
(505)
(996)
(1,077)

(343)
—
—
—
(343)

(47)
—
—
(1)
—

—

1

378
18
71
176
643

267
717
236
1,970
—

(16)
(1,164)

1,507  $
239
482
1,553
3,781
(2,538)

424
2
65
108
599

299
693
375
2,360
(2)

(15)

(1,149)

(102) 
(31) 
47 
(92) 
(178) 
(953) 

(2) 
1 
— 
(20) 
(21) 

3 
9 
(5) 
(374) 
— 

— 
(5) 

29 
(18) 
47 
26 
84 
228 

— 
— 
— 
— 
— 

38 
(1) 
22 
(267) 
(2) 

— 

(55) 

(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; AFS debt securities - predominantly other income; Other debt securities carried at fair value - other income; Loans and 
leases - market making and similar activities and other income; Loans held-for-sale - other income; Other assets - primarily other income related to MSRs; Long-term debt - market making and 
similar activities. 
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  $(41) million  and  $3 million  related  to  financial instruments still held at December 31, 2020 
and 2019. 

(3 )

(4 ) Net derivative assets (liabilities) include derivative assets of $2.8 billion and $2.2 billion and derivative liabilities of $6.2 billion and $4.8 billion at December 31, 2020 and 2019. 
(5 ) Amounts represent instruments that are accounted for under the fair value option. 
(6 )
(7 ) Settlements primarily represent the net change in fair value of the MSR asset due to the recognition of modeled cash flows and the passage of time. 
(8 ) 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 

Issuances represent loan originations and MSRs recognized following securitizations or whole-loan sales. 

instruments.

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Level 3 – Fair Value Measurements (1) 

Total 
Realized/ 
Unrealized 
Gains 
(Losses) in 
Net
 Income (2) 

Gains 
(Losses) 
in OCI (3) 

Balance 
January 1 

Gross 

Purchases  Sales 

Issuances  Settlements 

Gross 
Transfers 
into 
Level 3 

Gross 
Transfers 
out of 
Level 3 

Balance 
December 31 

Change in 
Unrealized 
Gains 
(Losses) in 
Net Income 
Related to 
Financial 
Instruments 
Still Held (2) 

$  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 

(11)
(57)
(910)
1,078  (1,381)
531  (1,179)

—
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)

—

—

5  $
—
—
—
5

—

—
—
—
—
—

—

—

1

96

(2)

—

(568)  $  804  $ 

(4)
(30)
(158)
(760) 

778

78
117
705
1,704

39

(547)  $
(49)
(137)
(236)
(969)

504

1,558  $
276
465
1,635
3,934

(935)

(25)
(15)
(11)
(1)
(52)

(34)

(83)

(201)

(792)

—

8

774
3
60
1
838 

365

—

23

929

—

—

(75)
—
(526)
(469)
(1,070)

(133)

—

(60)

(35)

—

—

597
2
7
—
606

172

338

542

2,932

(18)

—

(817)

(141)

486

(262)

847

(117) 
(22) 
48 
97 
6 

(116) 

— 
— 
— 
— 
— 

(18) 

(9) 

31 

149 

(7) 

— 

95 

(Dollars in millions) 
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 (5) 
Other debt securities carried at fair value - Non-

agency residential MBS

Loans and leases (6,7) 
Loans held-for-sale (6) 
Other assets (5,7,8) 
Trading account liabilities – Corporate securities 

and other

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. 
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 losses of $105 million related to financial instruments still held at December 31, 2018. 

(3 )

(4 ) Net derivative assets (liabilities) include derivative assets of $3.5 billion and derivative liabilities of $4.4 billion. 
(5 ) Transfers out of AFS debt securities and into other assets primarily relate to the reclassifcation of certain securities. 
(6 ) Amounts represent instruments that are accounted for under the fair value option. 
(7 )
(8 ) Settlements primarily represent the net change in fair value of the MSR asset due to the recognition of modeled cash flows and the passage of time.

Issuances represent loan originations and MSRs recognized following securitizations or whole-loan sales. 

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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, 2020 and 2019. 

Quantitative Information about Level 3 Fair Value Measurements at December 31, 2020 

(Dollars in millions)

Inputs 

Loans and Securities (2) 

Financial Instrument 

Fair 
Value 

Valuation 
Technique 

Significant Unobservable 
Inputs 

Ranges of 
Inputs 

Weighted 
Average (1) 

(3)% to 25% 

6% 

1% to 56% CPR 

20% CPR 

0% to 3% CDR 

1% CDR 

$0 to $168 

$110 

0% to 47% 

0% to 25% 

$0 to $100 

0% to 26% 

10% to 20% 

3% to 4% 

35% to 40% 

$0 to $142 

77% 

$10 to $97 

8% 

18% 

4% 

$52 

9% 

14% 

4% 

38% 

$66 

n/a 

$91 

n/a 

0 to 13 years 

0 to 10 years 

4 years 

3 years 

7% to 14% 

9% to 15% 

0% to 11% 

2% to 100% 

7% to 64% 

$0 to $124 

9% 

12% 

9% 

64% 

32% 

$86 

5% 

n/a 

0 to 100 points 

75 points 

15% to 100% CPR 

22% CPR 

2% CDR 

21% to 64% 

$0 to $122 

2% to 100% 

7% to 64% 

n/a 

57% 

$69 

64% 

32% 

Instruments backed by residential real estate assets 

$  1,543 

Trading account assets – Mortgage trading loans, ABS and other MBS 

Loans and leases 

AFS debt securities – 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 

AFS debt securities, primarily other taxable securities 

Loans held-for-sale 

Discounted cash 
flow, Market 
comparables 

Discounted cash 
flow 

467 

431 

378 

267 

407 

262 

43 

89 

13 

Yield 

Prepayment speed 

Default rate 

Price 

Loss severity 

Yield 

Price 

Commercial loans, debt securities and other 

$  3,066 

Yield 

Trading account assets – Corporate securities, trading loans and other 

1,097 

Prepayment speed 

Trading account assets – Non-U.S. sovereign debt 

Trading account assets – Mortgage trading loans, ABS and other MBS 

AFS debt securities – Tax-exempt securities 

Loans and leases 

Loans held-for-sale 

Other assets, primarily auction rate securities

$

354 

930 

176 

286 

223 

937

MSRs

$  1,033 

Discounted cash 
flow, Market 
comparables 

Default rate 

Loss severity 

Price 

Long-dated equity volatilities 

Discounted cash 
flow, Market 
comparables 

Price 

Discount rate 

Discounted cash 
flow 

Weighted-average life, fixed rate (5) 
Weighted-average life, variable rate (5) 

Option-adjusted spread, fixed rate 

Option-adjusted spread, variable rate 

Structured liabilities 

Long-term debt

$ 

(1,164) 

Discounted cash 
flow, Market 
comparables, 
Industry standard 
derivative pricing (3) 

Yield 

Equity correlation 

Long-dated equity volatilities 

Price 

Net derivative assets (liabilities) 

Credit derivatives

$

(112) 

Yield 

Natural gas forward price 

$1/MMBtu to $4/MMBtu  $3 /MMBtu 

Equity derivatives

Commodity derivatives

Interest rate derivatives

Discounted cash 
flow, Stochastic 
recovery correlation 
model 

$ 

(1,904) 

$ 

(1,426) 

$

(26) 

Industry standard 
derivative pricing (3) 

Discounted cash 
flow, Industry 
standard derivative 
pricing (3) 

Industry standard 
derivative pricing (4) 

Total net derivative assets (liabilities)

$ 

(3,468) 

Upfront points 

Prepayment speed 

Default rate 

Credit correlation 

Price 

Equity correlation 

Long-dated equity volatilities 

Natural gas forward price 

$1/MMBtu to $4/MMBtu  $3 /MMBtu 

Correlation 

Volatilities 

Correlation (IR/IR) 

Correlation (FX/IR) 

Long-dated inflation rates 

Long-dated inflation volatilities 

Interest rate volatilities 

39% to 85% 

23% to 70% 

15% to 96% 

0% to 46% 

(7)% to 84% 

0% to 1% 

0% to 2% 

73% 

39% 

34% 

3% 

14% 

1% 

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 179: Trading 
account assets – Corporate securities, trading loans and other of $1.4 billion, Trading account assets – Non-U.S. sovereign debt of $354 million, Trading account assets – Mortgage trading loans, 
ABS and other MBS of $1.4 billion, AFS debt securities of $643 million, Other debt securities carried at fair value - Non-agency residential of $267 million, Other assets, including MSRs, of $2.0 
billion, Loans and leases of $717 million and LHFS of $236 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

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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) 

1
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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 – Tax-exempt securities 

Loans and leases 

Loans held-for-sale 

Other assets, primarily auction rate securities

$

1,306 

482 

1,136 

108 

412 

354 

815

MSRs

$  1,545 

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 

Discounted cash flow 

Weighted-average life, fixed rate (5) 
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 

5 years 

0 to 9 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

Commodity derivatives

Interest rate derivatives

$ 

(1,149) 

Discounted cash 
flow, Market 
comparables, 
Industry standard 
derivative pricing (3) 

$

13 

Discounted cash 
flow, Stochastic 
recovery correlation 
model 

$ 

(1,081) 

$ 

(1,357) 

$

(113) 

Industry standard 
derivative pricing (3) 

Discounted cash 
flow, Industry 
standard derivative 
pricing (3) 

Industry standard 
derivative pricing (4) 

Total net derivative assets (liabilities)

$ 

(2,538) 

Yield 

Equity correlation 

Long-dated equity volatilities 

Price 

Natural gas forward price 

$1/MMBtu to $5/MMBtu  $3/MMBtu 

Yield 

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% 

Natural gas forward price 

$1/MMBtu to $5/MMBtu  $3/MMBtu 

Correlation 

Volatilities 

Correlation (IR/IR) 

Correlation (FX/IR) 

Long-dated inflation rates 

Long-dated inflation volatilities 

30% to 69% 

14% to 54% 

15% to 94% 

0% to 46% 

G(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 180: 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

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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 
the 
unobservable inputs and then these inputs are incorporated into 
a  discounted  cash 
flow  model.  Therefore,  the  balances 
disclosed encompass both of these techniques. 

to  estimate  some  of 

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 

Assets Measured at Fair Value on a Nonrecurring Basis 

protection  buyer  at  inception),  credit  spreads,  default  rates  or 
loss  severities  would  have  resulted  in  a  significantly  lower  fair 
value  for  protection  sellers  and  higher  fair  value  for  protection 
buyers.  The  impact  of  changes  in  prepayment  speeds  would 
have resulted in differing impacts depending on the seniority of 
the instrument. 

Structured  credit  derivatives  are 

impacted  by  credit 
correlation. Default correlation is a parameter that describes the 
degree of dependence among credit default rates within a credit 
portfolio  that  underlies  a  credit  derivative  instrument.  The 
sensitivity of this input on the fair value varies depending on the 
level  of  subordination  of  the  tranche.  For  senior  tranches  that 
are net purchases of protection, a significant increase in default 
correlation  would  have  resulted  in  a  significantly  higher  fair 
value. Net short protection positions would have been impacted 
in a directionally opposite way. 

For  equity  derivatives,  commodity  derivatives,  interest  rate 
derivatives  and  structured  liabilities,  a  significant  change  in 
long-dated rates and volatilities and correlation inputs (i.e., the 
degree  of  correlation  between  an  equity  security  and  an  index, 
between  two  different  commodities,  between  two  different 
interest  rates,  or  between  interest  rates  and  foreign  exchange 
rates)  would  have  resulted  in  a  significant  impact  to  the  fair 
value;  however,  the  magnitude  and  direction  of  the  impact 
depend  on  whether  the  Corporation  is  long  or  short  the 
exposure. For structured liabilities, a significant increase in yield 
or decrease in price would have resulted in a significantly lower 
fair value. 

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 2020, 2019 and 2018. 

(Dollars in millions)
Assets 

Loans held-for-sale
Loans and leases (1) 
Foreclosed properties (2, 3) 
Other assets

Assets 

Loans held-for-sale
Loans and leases (1) 
Foreclosed properties
Other assets

December 31, 2020

December 31, 2019 

Level 2

Level 3

Level 2

Level 3 

$

1,020  $
—
—
323

792  $
 301
 17
576

53  $
 —
 —
178

102 
257 
 17
646 

2020

Gains (Losses) 
2019

2018 

$

$

(79)
(73)
(6)
(98)

(14)  $
(81)
(9)
(2,145)

(18) 
(202) 
(24) 
(64) 

Includes $30 million, $36 million and $83 million of losses on loans that were written down to a collateral value of zero during 2020, 2019 and 2018, respectively. 

(1 )
(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 $119 million and $260 million of properties acquired upon foreclosure of certain government-guaranteed loans (principally FHA-insured loans) at December 31, 2020 and 2019.

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The table below presents information about significant unobservable inputs utilized in the Corporation's nonrecurring Level 3 fair 

value measurements during 2020 and 2019. 

Quantitative Information about Nonrecurring Level 3 Fair Value Measurements 

(Dollars in millions)
Loans held-for-sale
Loans and leases (2) 

Other assets (3) 

Loans held-for-sale
Loans and leases (2) 

Other assets (4) 

Financial Instrument 

Fair 
Value 

Valuation 
Technique 

Significant 
Unobservable 
Inputs 
2020 

Inputs 

Ranges of 
Inputs 

Weighted 
Average (1) 

$

 Discounted cash flow  Price

792
301  Market comparables  OREO discount

576  Discounted cash flow  Revenue attrition

Costs to sell

Discount rate
2019 

$ 

102  Discounted cash flow  Price
257  Market comparables  OREO discount

640  Discounted cash flow  Customer attrition

Cost to service

Costs to sell

$8 to $99
13% to 59%
8% to 26%
2% to 19%
11% to 14%

$85 to $97
13% to 59%
8% to 26%
0% to 19%
11% to 19%

$95 
24% 
9% 
7% 
12% 

$88 
24% 
9% 
5% 
15% 

(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 intangible asset related to the merchant contracts received from the merchant services joint venture was measured using a discounted cash flow method for which the two 

key assumptions were the revenue attrition rate and the discount rate. For more information, see Note 7 – Goodwill and Intangible Assets. 

(4)  Reflects the measurement of the Corporation’s merchant services equity method investment on which the Corporation recorded an impairment charge in 2019. The fair value of the merchant 

services joint venture was measured using a discounted cash flow method for which the two key assumptions were the customer attrition rate and the cost-to-service rate. 

NOTE 21 Fair Value Option 

Loans and Loan Commitments 
The  Corporation  elects  to  account  for  certain  loans  and  loan 
commitments  that  exceed  the  Corporation’s  single-name  credit 
risk  concentration  guidelines  under  the  fair  value  option. 
Lending  commitments  are  actively  managed  and,  as 
appropriate,  credit  risk  for  these  lending  relationships  may  be 
mitigated  through  the  use  of  credit  derivatives,  with  the 
Corporation’s  public  side  credit  view  and  market  perspectives 
determining  the  size  and  timing  of  the  hedging  activity.  These 
credit derivatives do not meet the requirements for designation 
as  accounting  hedges  and  therefore  are  carried  at  fair  value. 
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 
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 

through 

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, 
repurchase 
including 
agreements, under the fair value option. These elections include 
certain  agreements  collateralized  by  the  U.S.  government  and 
its agencies, which are generally short-dated and have minimal 
interest rate risk.

resale  and 

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that  would  otherwise  result  from  the  asymmetry  created  by 
accounting for the asset-backed secured financings at historical 
cost  and  the  corresponding  mortgage  LHFS  securing  these 
financings at fair value. 

Long-term Debt 
The  Corporation  elects  to  account  for  certain  long-term  debt, 
primarily  structured  liabilities,  under  the  fair  value  option.  This 
long-term  debt  is  either  risk-managed  on  a  fair  value  basis  or 
the related hedges do not qualify for hedge accounting. 

Fair Value Option Elections 
The  following  tables  provide  information  about  the  fair  value 
carrying  amount  and  the  contractual  principal  outstanding  of 
assets  and  liabilities  accounted  for  under  the  fair  value  option 
at December 31, 2020 and 2019, 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 2020, 2019 and 2018. 

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. Election of the fair value option 
allows  the  Corporation  to  reduce  the  accounting  volatility  that 
the  asymmetry  created  by 
would  otherwise 
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. 

result 

from 

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 

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 

December 31, 2020

December 31, 2019 

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 

108,856  $
7,967
22,790
6,681
1,585
200
481

108,811  $

45  $

50,364  $

17,372
n/a
6,778
2,521
n/a
448

(9,405)
n/a
(97)
(936)
n/a
33

6,989
19,574
8,335
3,709
4
508

50,318  $
14,703
n/a
8,372
4,879
n/a
496

46 
(7,714) 
n/a 
(37) 
(1,170) 
n/a 
12 

sold under agreements to repurchase

(21) 
Short-term borrowings
11 
Unfunded loan commitments
n/a 
Long-term debt
(755) 
(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 

135,390
5,178
n/a
33,470

135,391
5,874
99
32,200

16,029
3,930
n/a
35,730

16,008
3,941
90
34,975

1
696
n/a
(1,270)

near contractual principal outstanding. 

n/a = not applicable

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Gains (Losses) Relating to Assets and Liabilities Accounted for Under the Fair Value Option 

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(Dollars in millions)
Loans reported as trading account assets 
Trading inventory – other (1) 
Consumer and commercial loans
Loans held-for-sale (2) 
Short-term borrowings
Unfunded loan commitments
Long-term debt (3) 
Other (4) 
Total

Loans reported as trading account assets
Trading inventory – other (1) 
Consumer and commercial loans
Loans held-for-sale (2) 
Short-term borrowings
Unfunded loan commitments
Long-term debt (3) 
Other (4) 
Total

Loans reported as trading account assets
Trading inventory – other (1) 
Consumer and commercial loans
Loans held-for-sale (2) 
Short-term borrowings
Unfunded loan commitments
Long-term debt (3) 
Other (4) 
Total

Market making 
and similar 
activities 

Other 
Income
2020 

Total 

$

$

$

$

$

$

$

 107
3,216
22
—
(170)
—
(2,175)
35
1,035  $

203  $

5,795
92
—
(24)
—
(1,098)
9
4,977  $

8  $

1,750
(422)
1
2
—
2,157
6
3,502  $

  — $

—
(3)
103
—
(65)
(53)
(22)
(40)  $

—  $
—
12
98
—
79
(78)
(27)
84  $

—  $
—
(53)
24
—
(49)
(93)
18

(153)  $

2019 

2018 

 107
3,216 
19 
103 
(170) 
(65) 
(2,228) 
13 
995 

203 
5,795 
104 
98 
(24) 
79 
(1,176) 
(18) 
5,061 

8 
1,750 
(475) 
25 
2 
(49) 
2,064 
24 
3,349 

Includes the value of IRLCs on funded loans, including those sold during the period. 

(1)  The gains in market making and similar activities are primarily offset by losses on trading liabilities that hedge these assets. 
(2) 
(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  14  –  Accumulated  Other 
Comprehensive Income (Loss). For more information on how the Corporation’s own credit spread is determined, see Note 20 – Fair Value Measurements. 
Includes gains (losses) on federal funds sold and securities borrowed or purchased under agreements to resell, long-term deposits and federal funds purchased and securities loaned or sold 
under agreements to repurchase. 

(4) 

Gains (Losses) Related to Borrower-specific Credit Risk for Assets and Liabilities Accounted for Under the Fair Value 
Option 

(Dollars in millions)
Loans reported as trading account assets 
Consumer and commercial loans
Loans held-for-sale
Unfunded loan commitments

2020

2019

2018 

$

(172) $

(19)
(105)
(65)

$

43
15
57
79

  6
(56) 
(4) 
(94) 

NOTE 22 Fair Value of Financial Instruments 
Financial  instruments  are  classified  within  the  fair  value 
hierarchy  using  the  methodologies  described  in  Note 20 – Fair  
Value  Measurements.  Certain  loans,  deposits,  long-term  debt, 
unfunded lending commitments and other financial instruments 
are  accounted  for  under  the  fair  value  option.  For  more 
information,  see  Note  21  –  Fair  Value  Option.  The  following 
disclosures include financial instruments that are not carried at 
fair  value  or  only  a  portion  of  the  ending  balance  is  carried  at 
fair value on the Consolidated Balance Sheet. 

Short-term Financial Instruments 
The carrying value of short-term financial instruments, including 
cash  and  cash  equivalents,  certain  time  deposits  placed  and 
other short-term investments, federal funds sold and purchased, 

certain  resale  and  repurchase  agreements  and  short-term 
borrowings,  approximates  the  fair  value  of  these  instruments. 
These financial instruments generally expose the Corporation to 
limited credit risk and have no stated maturities or have short-
term  maturities  and  carry  interest  rates  that  approximate 
market.  The  Corporation  accounts  for  certain  resale  and 
repurchase agreements under the fair value option. 

Under  the  fair  value  hierarchy,  cash  and  cash  equivalents 
are classified as Level 1. Time deposits placed and other short-
term  investments,  such  as  U.S.  government  securities  and 
short-term commercial paper, are classified as Level 1 or Level 
2. Federal funds sold and purchased are classified as Level 2. 
Resale  and  repurchase  agreements  are  classified  as  Level  2 
because  they  are  generally  short-dated  and/or  variable-rate 
instruments  collateralized  by  U.S.  government  or  agency 
securities. Short-term borrowings are classified as Level 2.

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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,  2020  and 
2019 are presented in the following table. 

Fair Value of Financial Instruments 

Fair Value 

Carrying 
Value

Level 3
Level 2
December 31, 2020 

Total 

$  887,289  $  49,372  $  877,682  $  927,054 
9,243 

1,379

9,243

7,864

1,795,480
262,934

1,795,545
271,315

— 1,795,545 
272,479 

1,164

1,977

99

5,159

5,258 

December 31, 2019 

$  950,093  $  63,633  $  914,597  $  978,230 
9,158 

9,158

8,439

719

1,434,803 
240,856

1,434,809
247,376

— 
1,149

1,434,809 
248,525 

903

90

4,777

4,867 

(Dollars in millions)
Financial assets 

Loans
Loans held-for-sale

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) 

Includes demand deposits of $799.0 billion and $545.5 billion with no stated maturities at 
December 31, 2020 and 2019. 

(2)  The  carrying  value  of  commercial  unfunded  lending  commitments  is  included  in  accrued 
expenses and other liabilities on the Consolidated Balance Sheet. The Corporation does not 
estimate  the  fair  value  of  consumer  unfunded  lending  commitments  because,  in  many 
instances,  the  Corporation  can  reduce  or  cancel  these  commitments  by  providing  notice  to 
the  borrower.  For  more  information  on  commitments,  see  Note  12  –  Commitments  and 
Contingencies. 

NOTE 23 Business Segment Information 
The  Corporation  reports  its  results  of  operations  through  the 
following  four  business  segments:  Consumer  Banking,  GWIM, 
Global  Banking  and  Global  Markets,  with 
remaining 
operations recorded in All Other. 

the 

Consumer Banking 
Consumer  Banking  offers  a  diversified  range  of  credit,  banking 
and investment products and services to consumers and small 
include 
businesses.  Consumer  Banking  product  offerings 
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. 

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Global Banking 
Global Banking provides a wide range of lending-related products 
and  services,  integrated  working  capital  management  and 
treasury  solutions,  and  underwriting  and  advisory  services 
through  the  Corporation’s  network  of  offices  and  client 
relationship  teams.  Global  Banking  also  provides  investment 
banking  products 
to  clients.  The  economics  of  certain 
investment  banking  and  underwriting  activities  are  shared 
primarily  between  Global  Banking  and  Global  Markets  under  an 
internal  revenue-sharing  arrangement.  Global  Banking  clients 
generally  include  middle-market  companies,  commercial  real 
estate firms, not-for-profit companies, large global corporations, 
financial  institutions,  leasing  clients,  and  mid-sized  U.S.-based 
businesses requiring customized and integrated financial advice 
and solutions. 

financing, 

securities 

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 
clearing, 
provides  market-making, 
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. 

loans  and  servicing  activities, 

All Other 
All  Other  consists  of  ALM  activities,  equity  investments,  non-
core  mortgage 
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. 

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

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net  interest  income  generated  by  certain  of  the  Corporation’s 
ALM activities. 

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instruments 

The  Corporation’s  ALM  activities  include  an  overall  interest 
rate  risk  management  strategy  that  incorporates  the  use  of 
various  derivatives  and  cash 
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 
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 

in 

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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  2020,  2019  and  2018,  and  total  assets  at  December  31, 
2020  and  2019  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.

Total Corporation (1) 
2019

2020

2018

2020

Consumer Banking 
2019

2018 

$

43,859  $
42,168
86,027
11,320
55,213
19,494
1,600

49,486  $ 
42,353
91,839
3,590
54,900
33,349
5,919

17,894  $

$
$  2,819,627  $  2,434,079

27,430  $ 

48,772  $
42,858
91,630
3,282
53,154
35,194
7,047

28,147  $
$

24,698  $

8,564
33,262
5,765
18,878
8,619
2,112
6,507  $
988,580  $ 

28,158  $ 
10,429
38,587
3,772
17,646
17,169
4,207

12,962  $ 

804,093 

27,025 
10,593 
37,618 
3,664 
17,672 
16,282 
4,150 
12,132 

Global Wealth & Investment Management
2018
2019

2020

2020

Global Banking 
2019

2018 

$

5,468  $

6,504  $

6,265  $

13,116
18,584
357
14,154
4,073
998

3,075  $
369,736  $ 

13,034
19,538
82
13,825
5,631
1,380
4,251  $

299,770

13,188
19,453
86
14,015
5,352
1,364
3,988  $
$

9,013  $
9,974
18,987
4,897
9,337
4,753
1,283
3,470  $
580,561  $ 

10,675  $ 

9,808
20,483
414
9,011
11,058
2,985
8,073  $

464,032 

10,993 
9,008 
20,001 
8 
8,745 
11,248 
2,923 
8,325 

2020

Global Markets
2019

 $

4,646
14,120
18,766
251
11,422
7,093
1,844
5,249  $
616,609  $ 

3,915  $

11,699
15,614
(9)
10,728
4,895
1,395
3,500  $

641,809

2018

2020

All Other 
2019

3,857  $

12,326
16,183
—
10,835
5,348
1,390
3,958  $
$

$

 34
(3,606)
(3,572)
50
1,422
(5,044)
(4,637)

(407)  $
264,141  $ 

234  $

(2,617)
(2,383)
(669)
3,690
(5,404)
(4,048)
(1,356)  $

224,375 

2018 

632 
(2,257) 
(1,625) 
(476) 
1,887 
(3,036) 
(2,780) 
(256) 

$
$

$

$
$

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The  table  below  presents  noninterest  income  and  the  associated  components  for  2020,  2019  and  2018  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 (loss)

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 (loss) 

Total Corporation
2019

2020

2018

2020

Consumer Banking 
2019

2018

Global Wealth & 
Investment Management 
2019

2018 

2020

$  3,954  $  3,834  $  3,866  $  3,027  $  3,174  $  3,196  $

1,702
5,656

5,991
1,150
7,141

1,963
5,797

6,588
1,086
7,674

1,958
5,824

6,667
1,100
7,767

10,708
3,866
14,574

10,241
3,661
13,902

10,189
3,971
14,160

1,646
4,673

3,417
— 
3,417

146
127
273

1,910
5,084

4,218
—
4,218

144
149
293

1,907
5,103

4,300
 —
4,300

147
172
319

$

36
42
78

67
 —
67

$

59
42
101

68
 —
68

 81
46 
127 

73 
 —
73 

10,578
1,692
12,270

10,130
1,740
11,870

10,042 
1,917 
11,959 

4,698
861
1,621
7,180
34,551
8,355
(738)

335 
 —
 2
337 
12,496 
112 
580 
$  42,168  $  42,353  $  42,858  $  8,564  $  10,429  $  10,593  $  13,116  $  13,034  $  13,188 

401
 —
 —
401
12,440
113
481

2,722
1,347
1,258
5,327
33,078
9,008
772

2,998
1,184
1,460
5,642
33,015
9,034
304

 391
 —
 —
 391
12,806
 63
247

— 
— 
— 
— 
8,363
2 
199

 —
 —
 —
 —
9,722
 8
863

—
—
—
—
9,595
6
828

Global Banking
2019

2020

2018

2020

Global Markets
2019

2018

2020

All Other (1) 
2019

2018 

$

499
14
513

2,298
940
3,238

— 
74
74

2,070
482
1,458
4,010
7,835
103 
2,036 

 $

519  $

13
532

2,121
894
3,015

—
34
34

1,227
574
1,336
3,137
6,718
235 
2,855 

503  $
8
511

2,111
916
3,027

 —
94
94

1,090
648
1,153
2,891
6,523
260 
2,225 

391
—
391

177
210
387

 —
1,973
1,973

2,449
379
163
2,991
5,742
8,471 
(93) 

$

$

81
(1)
80

$

86
(2)
84

156
192
348

 —
1,738
1,738

1,555
610
123
2,288
4,454
7,065 
180 

161
184
345

 —
1,780
1,780

1,495
698
103
2,296
4,505
7,260 
561 

$

1
—
1 

32
— 
32

 (16)
— 
(16)

$

1
(1)
—

25
—
25

(33)
—
(33)

 —
(1) 
 (1)

22 
 —
22 

— 
 8
8 

(212)
— 
— 
(212)
(195)
(284) 
(3,127) 
(3,606)  $ 

(185)
—
1
(184)
(192)
1,615 
(4,040) 
(2,617)  $ 

(198) 
 1
 —
(197) 
(168) 
1,368 
(3,457) 
(2,257) 

Total noninterest income

$  9,974  $  9,808  $  9,008  $  14,120  $  11,699  $  12,326  $ 

(1)  All Other includes eliminations of intercompany transactions.

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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

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2020

2019

2018 

89,599  $

94,222  $

93,255 

375
(3,947)
(499)
85,528  $
18,301

279
(686)
17,894  $

241
(2,624)
(595)
91,244  $
28,786

202
(1,558)
27,430  $

(325) 
(1,300) 
(610) 
91,020 
28,403 

(222) 
(34) 
28,147 

$

$

$

December 31 

2020

2,555,486  $ 

2019 
2,209,704 

1,176,071
(977,685)
65,755
2,819,627  $ 

721,806 
(565,378) 
67,947 
2,434,079 

$

$

(1)  Adjustments include consolidated income, expense and asset amounts not specifically allocated to individual business segments. 

NOTE 24 Parent Company Information 
The following tables present the Parent Company-only financial information. 

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

2020

2019

2018 

$

10,352
— 
8,825
(138)
19,039

136
4,119
1,651
5,906
13,133
649
12,484

5,372
38
5,410

$

17,894  $

 $

27,820  $
—
9,502
74
37,396

451
5,899
1,641
7,991
29,405
341
29,064

(1,717)
83
(1,634)
27,430  $

28,575 
 91
8,425 
(1,025) 
36,066 

235 
6,425 
1,600 
8,260 
27,806 
(281) 
28,087 

306 
(246) 
60 
28,147

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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 $7 million and $4 million at December 31, 2020 and 2019. 

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 provided by (used in) financing activities

Net increase in cash held at bank subsidiaries
Cash held at bank subsidiaries at January 1

Cash held at bank subsidiaries at December 31

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December 31 

2020

2019 

$

5,893  $

701

206,566
213
410

305,818
3,715
9,850
533,166  $

5,695 
656 

173,301 
51 
391 

297,465 
3,663 
9,438 
490,660 

15,965  $

13,381 

129
11,067
233,081
260,242
272,924
533,166  $

458 
12,102 
199,909 
225,850 
264,810 
490,660 

$

$

$

2020

2019

2018 

$

17,894  $

27,430  $

28,147 

(5,410)
14,303
26,787

(4)
(33,111)
(7) 
(33,122)

(422)
43,766
(23,168)
2,181
(1,072)
(7,025)
(7,727)
6,533
198
5,695
5,893  $

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

$

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NOTE 25 Performance by Geographical Area 
The  Corporation’s  operations  are  highly 
integrated  with 
operations  in  both  U.S.  and  non-U.S.  markets.  The  non-U.S. 
business  activities  are  largely  conducted  in  Europe,  the  Middle 
East  and  Africa  and  in  Asia.  The  Corporation  identifies  its 
geographic  performance  based  on  the  business  unit  structure 
used  to  manage  the  capital  or  expense  deployed  in  the  region 

as  applicable.  This  requires  certain  judgments  related  to  the 
allocation  of  revenue  so  that  revenue  can  be  appropriately 
matched  with  the  related  capital  or  expense  deployed  in  the 
region.  Certain  asset,  liability,  income  and  expense  amounts 
have been allocated to arrive at total assets, total revenue, net 
of  interest  expense,  income  before  income  taxes  and  net 
income by geographic area as presented below. 

(Dollars in millions) 
U.S. (3) 

Asia

Europe, Middle East and Africa

Latin America and the Caribbean

Total Non-U.S.

Total Consolidated

Total Assets at 
Year End (1) 

Total Revenue, 
Net of Interest 
Expense (2) 

Income Before 
Income Taxes

Net Income 

2020
2019
2018
2020
2019
2018
2020
2019
2018
2020
2019
2018
2020
2019
2018
2020
2019
2018

$ 

2,490,247  $
2,122,734

99,283
102,440

202,701
178,889

27,396
30,016

329,380
311,345

$ 

2,819,627  $
2,434,079

75,576  $
81,236
80,777
4,232
3,491
3,507
4,491
5,310
5,632
1,229
1,207
1,104
9,952
10,008
10,243
85,528  $
91,244
91,020

18,247  $
30,699
31,904
1,051
765
865
(596)
921
1,543
293
369
272
748
2,055
2,680
18,995  $
32,754
34,584

16,692 
25,937 
26,407 
788 
570 
520 
264 
672 
1,126 
150 
251 
94 
1,202 
1,493 
1,740 
17,894 
27,430 
28,147 

(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.

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Glossary 

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Alt-A  Mortgage  –  A  type  of  U.S.  mortgage  that  is  considered 
riskier than A-paper, or “prime,” and less risky than “subprime,” 
Typically,  Alt-A  mortgages  are 
the 
characterized  by  borrowers  with  less  than  full  documentation, 
lower credit scores and higher LTVs. 

category. 

riskiest 

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.

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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) 
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. 

– The  right

 to service a  

Nonperforming  Loans  and  Leases  –  Includes  loans  and  leases 
including 
that  have  been  placed  on  nonaccrual  status, 
nonaccruing 
terms  have  been 
restructured in a manner that grants a concession to a borrower 
experiencing financial difficulties. 

loans  whose  contractual 

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,” 
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. 

undercapitalized” 

“significantly 

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. 

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Key Metrics 

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Active  Digital  Banking  Users  –  Mobile  and/or  online  users  with 
activity at period end. 

Operating Margin – Income before income taxes divided by total 
revenue, net of interest expense. 

Active  Mobile  Banking  Users  –  Mobile  users  with  activity  at 
period end. 

Book  Value  –  Ending  common  shareholders'  equity  divided  by 
ending common shares outstanding. 

Deposit  Spread  –  Annualized  net  interest  income  divided  by 
average deposits. 

Efficiency Ratio – Noninterest expense divided by total revenue, 
net of interest expense. 

Financial  advisor  productivity  –  Adjusted  MLGWM  annualized 
revenue divided by average financial advisors. 

Gross Interest Yield – Effective annual percentage rate divided by 
average loans. 

Net Interest Yield – Net interest income divided by average total 
interest-earning assets.

Risk-adjusted Margin – Difference between total revenue, net of 
interest  expense,  and  net  credit  losses  divided  by  average 
loans. 

Return  on  Average  Allocated  Capital  –  Adjusted  net  income 
divided by allocated capital. 

Return on Average Assets – Net income divided by total average 
assets. 

Return  on  Average  Common  Shareholders'  Equity  – Net income  
applicable to common shareholders divided by average common 
shareholders' equity. 

Return on Average Shareholders' Equity – Net income divided by 
average shareholders' equity. 

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Acronyms

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ABS
AFS
AI
ALM
ARR
AUM
AVM
BANA
BHC
BofAS
BofASE 
bps
CAE
CAO
CCAR
CDO
CDS
CECL
CET1
CFPB
CFTC
CLO
CLTV
CRO
CVA
DIF
DVA
ECL
EMRC
EPS
ERC
ESG
EU
FCA
FDIC
FDICIA

FHA
FHLB
FHLMC 
FICC
FICO
FLUs
FNMA
FTE
FVA
GAAP

GDPR
GLS
GNMA

Asset-backed securities 
Available-for-sale 
Artificial intelligence 
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 
Current expected credit losses 
Common equity tier 1 
Consumer Financial Protection Bureau 
Commodity Futures Trading Commission 
Collateralized loan obligation 
Combined loan-to-value 
Chief Risk Officer 
Credit valuation adjustment 
Deposit Insurance Fund 
Debit valuation adjustment 
Expected credit losses 
Enterprise Model Risk Committee 
Earnings per common share 
Enterprise Risk Committee 
Environmental, social and governance 
European Union 
Financial Conduct Authority 
Federal Deposit Insurance Corporation 
Federal Deposit Insurance Corporation 
Improvement Act of 1991 
Federal Housing Administration 
Federal Home Loan Bank 
Freddie Mac 
Fixed income, currencies and commodities 
Fair Isaac Corporation (credit score) 
Front line units 
Fannie Mae 
Fully taxable-equivalent 
Funding valuation adjustment 
Accounting principles generally accepted in the 
United States of America 
General Data Protection Regulation 
Global Liquidity Sources 
Government National Mortgage Association 

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G-SIB
GSE
GWIM
HELOC
HQLA
HTM
IBOR
ICAAP
IRLC
IRM
ISDA

LCR
LHFS
LIBOR 
LTV
MBS
MD&A

Global systemically important bank 
Government-sponsored enterprise 
Global Wealth & Investment Management 
Home equity line of credit 
High Quality Liquid Assets 
Held-to-maturity 
Interbank Offered Rates 
Internal Capital Adequacy Assessment Process 
Interest rate lock commitment 
Independent Risk Management 
International Swaps and Derivatives Association, 

Inc. 

Liquidity Coverage Ratio 
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 International 

MLGWM  Merrill Lynch Global Wealth Management 
MLI
MLPCC  Merrill Lynch Professional Clearing Corp 
MLPF&S  Merrill Lynch, Pierce, Fenner & Smith Incorporated 
MRC
MSA
MSR
NOL
NSFR
OCC
OCI
OREO
OTC
PCA
PPP
RMBS
RSU
RWA
SBA
SBLC
SCB
SCCL
SEC
SLR
SOFR
SONIA
TDR
TLAC
VA
VaR
VIE

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 
Prompt Corrective Action 
Paycheck Protection Program 
Residential mortgage-backed securities 
Restricted stock unit 
Risk -weighted assets 
Small Business Administration 
Standby letter of credit 
Stress capital buffer 
Single-counterparty credit limits 
Securities and Exchange Commission 
Supplementary leverage ratio 
Secured Overnight Financing Rate 
Sterling Overnight Index Average 
Troubled debt restructurings 
Total loss-absorbing capacity 
U.S. Department of Veterans Affairs 
Value-at-Risk 
Variable interest entity

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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.

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Executive Management Team and Management Committee 
Bank of America Corporation 

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 and 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 of Asia Pacific, and 
Co-Head of Asia Pacific Fixed Income, 
Currencies & Commodities 

David C. Tyrie 
Head of Digital 

Anne Walker 
Global Real Estate and Strategic 
Initiatives Executive 

Executive Management Team 
Brian T. Moynihan* 
Chairman of the Board and 
Chief Executive Officer 

Raul A. Anaya 
President, Business Banking 

Dean C. Athanasia* 
President, Retail and Preferred 
& Small Business Banking 

Catherine P. Bessant* 
Chief Operations and 
Technology Officer 

D. Steve Boland 
President, Retail 

Alastair M. Borthwick 
President, Global Commercial Banking 

Sheri B. Bronstein* 
Chief Human Resources Officer 

James P. DeMare 
President, Global Markets 

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 

Matthew M. Koder 
President, Global Corporate & 
Investment Banking 

David G. Leitch* 
Global General Counsel 

Aron D. Levine 
President, Preferred and Consumer 
Banking & Investments 

Bernard A. Mensah 
President, International 

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, Bank of America 

Sanaz Zaimi 
Head of Global Fixed Income, 
Currencies and Commodities Sales; 
CEO of BofA Securities Europe SA, and 
Country Executive for France 

Management Committee** 
Michael C. Ankrom, Jr. 
Global Banking Chief Risk Officer, 
Enterprise Credit Risk and Enterprise 
Risk Appetite 

Keith T. Banks 
Vice Chairman, 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 

Candace E. Browning-Platt 
Head of Global Research 

Sharon L. Miller 
Head of Small Business 

Andrei Magasiner 
Treasurer 

E. Lee McEntire 
Head of Investor Relations 

  * Executive Officer 

**  All members of the Executive Management Team are also members of the Management Committee

200   |   BANK OF AMERICA 2020

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 

Susan S. Bies 
Former Member, Federal Reserve  
Board of Governors  

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 

Arnold W. Donald 
President and Chief Executive Officer, 
Carnival 

Linda P. Hudson 
Former Chairman and  
Chief Executive Officer,  
The Cardea Group, LLC; 
Former President and Chief Executive 
Officer, BAE 

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 
Lead Independent Director Successor, 
Bank of America; Former Senior Vice 
President and Treasurer, PepsiCo, Inc. 

Denise L. Ramos 
Former Chief Executive Officer and 
President, ITT Inc. 

Clayton S. Rose 
President, Bowdoin College 

Michael D. White 
Former Chairman, President, and 
Chief Executive Officer, DIRECTV; Lead 
Director, Kimberly-Clark Corporation 

Thomas D. Woods 
Former Vice Chairman and Senior 
Executive Vice President of CIBC; 
Former Chairman, Hydro One Limited 

R. David Yost 
Former Chief Executive Officer, 
AmerisourceBergen Corporation 

Maria T. Zuber 
Vice President for Research and 
E.A. Griswold Professor of  
Geophysics, MIT 

* Not standing for reelection at the 2021 Annual Meeting of Shareholders

BANK OF AMERICA 2020   |   201

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. 

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, 2020, there were 157,293 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@bofa.com. For additional 
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@bofa.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. 

202   |   BANK OF AMERICA 2020

Annual Report on Form 10-K 
The Corporation’s 2020 Annual Report on Form 10-K 
is available at http://investor.bankofamerica.com. The 
Corporation also will provide a copy of the 2020 Annual 
Report on Form 10-K (without exhibits) upon written request 
addressed to: 

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. Hearing impaired 1.888.403.9700 or 
outside the United States 1.781.575.4592. 

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.

Bank of America Corporation (“Bank of America”) is a financial holding 
company that, through its subsidiaries and affiliated companies, provides 
banking and non-banking financial services. 

“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. 

Banking products are provided by Bank of America, N.A., and affiliated banks, Members FDIC, and wholly owned 
subsidiaries of BofA Corp. 

Bank of America Private Bank is a division of Bank of America, N.A.,  
Member FDIC, and a wholly owned subsidiary of Bank of America Corporation. 

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. 

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 https://newsroom.bankofamerica.com/ 
awards. 

Investment products: 

Are Not FDIC Insured

May Lose Value

Are Not Bank Guaranteed 

© 2021 Bank of America Corporation. All rights reserved. 

Printed on 10% 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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2020 BAC Annual Report

 
 
 
 
 
 
 
 
 
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