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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION


Washington, D.C. 20549
FORM 10-K
(Mark One)
ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES
EXCHANGE ACT OF 1934
For the Fiscal Year Ended December 31, 2020

or

☐ TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES
[Ÿ
ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934
For the fiscal year ended December 31, 2017
or
[  ] TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934
For the transition period from      to


Commission file number:
1-6523
Exact name of registrant as specified in its charter:
Bank of America Corporation


State or other jurisdiction of incorporation or organization:
Delaware
IRS Employer Identification No.:
56-0906609
Address of principal executive offices:
Bank of America Corporate Center
100 N. Tryon Street
Charlotte, North Carolina 28255
Registrant’s telephone number, including area code:
(704) 386-5681
Securities registered pursuant to section 12(b) of the Act:
Title of each classTrading Symbol(s)Name of each exchange on which registered
Common Stock, par value $0.01 per shareBACNew York Stock Exchange
Warrants to purchase Common Stock (expiring October 28, 2018)New York Stock Exchange
Warrants to purchase Common Stock (expiring January 16, 2019)New York Stock Exchange
Depositary Shares, each representing a 1/1,000th interest in a share of 6.204% Non-Cumulative
Preferred Stock, Series D
BAC PrENew York Stock Exchange
 of Floating Rate Non-Cumulative Preferred Stock, Series E
Depositary Shares, each representing a 1/1,000th interest in a share of Floating Rate Non-Cumulative
Preferred Stock, Series E
BAC PrANew York Stock Exchange
of 6.000% Non-Cumulative Preferred Stock, Series EE
Depositary Shares, each representing a 1/1,000th interest in a share of 6.625% Non-Cumulative
Preferred Stock, Series I
BAC PrBNew York Stock Exchange
 of 6.000% Non-Cumulative Preferred Stock, Series GG
Depositary Shares, each representing a 1/1,000th interest in a share of 6.625% Non-Cumulative
Preferred Stock, Series W
BAC PrKNew York Stock Exchange
 of 5.875% Non-Cumulative Preferred Stock, Series HH
7.25% Non-Cumulative Perpetual Convertible Preferred Stock, Series LBAC PrLNew York Stock Exchange
Depositary Shares, each representing a 1/1,200th interest in a shareBML PrGNew York Stock Exchange
of Bank of America Corporation Floating Rate
Non-Cumulative Preferred Stock, Series 1

1 Bank of America



Title of each classTrading Symbol(s)Name of each exchange on which registered
Depositary Shares, each representing a 1/1,200th interest in a shareBML PrHNew York Stock Exchange
 of Bank of America Corporation Floating Rate
Non-Cumulative Preferred Stock, Series 2
Depositary Shares, each representing a 1/1,200th interest in a shareBML PrJNew York Stock Exchange
 of Bank of America Corporation Floating Rate
Non-Cumulative Preferred Stock, Series 4
Depositary Shares, each representing a 1/1,200th interest in a shareBML PrLNew York Stock Exchange
 of Bank of America Corporation Floating Rate
Non-Cumulative Preferred Stock, Series 5
Floating Rate Preferred Hybrid Income Term Securities of BAC CapitalBAC/PFNew York Stock Exchange
 Trust XIII (and the guarantee related thereto)
5.63% Fixed to Floating Rate Preferred Hybrid Income Term SecuritiesBAC/PGNew York Stock Exchange
 of BAC Capital Trust XIV (and the guarantee related thereto)
Income Capital Obligation Notes initially due December 15, 2066 ofMER PrKNew York Stock Exchange
Bank of America Corporation
Senior Medium-Term Notes, Series A, Step Up Callable Notes, dueBAC/31BNew York Stock Exchange
 November 28, 2031 of BofA Finance LLC (and the guarantee
of the Registrant with respect thereto)
Depositary Shares, each representing a 1/1,000th interest in a share of 6.500% Non-Cumulative
Preferred Stock, Series Y
BAC PrMNew York Stock Exchange
 of 5.375% Non-Cumulative Preferred Stock, Series KK
Depositary Shares, each representing a 1/1,000th interest in a share of 6.200% Non-Cumulative
Preferred Stock, Series CC
BAC PrNNew York Stock Exchange
of 5.000% Non-Cumulative Preferred Stock, Series LL
Depositary Shares, each representing a 1/1,000th interest in a shareBAC PrONew York Stock Exchange
of 6.000%4.375% Non-Cumulative Preferred Stock, Series EENew York Stock Exchange




NN
Title of each className of each exchange on which registered
7.25% Non-Cumulative Perpetual Convertible Preferred Stock, Series LNew York Stock Exchange
Depositary Shares, each representing a 1/1,200th1,000th interest in a shareBAC PrPNew York Stock Exchange
of Bank of America Corporation Floating Rate4.125% Non-Cumulative Preferred Stock, Series 1New York Stock Exchange
Depositary Shares, each representing a 1/1,200th interest in a share of Bank of America Corporation Floating Rate Non-Cumulative Preferred Stock, Series 2New York Stock Exchange
Depositary Shares, each representing a 1/1,200th interest in a share of Bank of America Corporation 6.375% Non-Cumulative Preferred Stock, Series 3New York Stock Exchange
Depositary Shares, each representing a 1/1,200th interest in a share of Bank of America Corporation Floating Rate Non-Cumulative Preferred Stock, Series 4New York Stock Exchange
Depositary Shares, each representing a 1/1,200th interest in a share of Bank of America Corporation Floating Rate Non-Cumulative Preferred Stock, Series 5New York Stock Exchange
7.00% Capital Securities of Countrywide Capital V (and the guarantees related thereto)New York Stock Exchange
Floating Rate Preferred Hybrid Income Term Securities of BAC Capital Trust XIII (and the guarantee related thereto)New York Stock Exchange
5.63% Fixed to Floating Rate Preferred Hybrid Income Term Securities of BAC Capital Trust XIV (and the guarantee related thereto)New York Stock Exchange
MBNA Capital B Floating Rate Capital Securities, Series B (and the guarantee related thereto)New York Stock Exchange
Trust Preferred Securities of Merrill Lynch Capital Trust I (and the guarantee of the Registrant with respect thereto)New York Stock Exchange
Trust Preferred Securities of Merrill Lynch Capital Trust III (and the guarantee of the Registrant with respect thereto)New York Stock Exchange
Senior Medium-Term Notes, Series A, Step Up Callable Notes, due November 28, 2031 of BofA Finance LLC (and the guarantee of the Registrant with respect thereto)New York Stock ExchangePP


Securities registered pursuant to Section 12(g) of the Act: None
Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act. Yes oNo
Indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or Section 15(d) of the Act. Yes oNo
Indicate by check mark whether the registrant: (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90 days.  Yes No o
Indicate by check mark whether the registrant has submitted electronically and posted on its corporate Web site, if any, every Interactive Data File required to be submitted and posted pursuant to Rule 405 of Regulation S-T (§ 232.405 of this chapter) during the preceding 12 months (or for such shorter period that the registrant was required to submit and post such files).  Yes  No o
Indicate by check mark if disclosure of delinquent filers pursuant to Item 405 of Regulation S-K is not contained herein, and will not be contained, to the best of registrant’s knowledge, in definitive proxy or information statements incorporated by reference in Part III of this Form 10-K or any amendment to this Form 10-K.
Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, a smaller reporting company or an emerging growth company. See the definitions of “large accelerated filer,” “accelerated filer,” “smaller reporting company” and “emerging growth company” in Rule 12b-2 of the Exchange Act. (Check one):
Large accelerated filer
Accelerated filero
Non-accelerated filero
Smaller reporting companyo
Emerging growth company o
(do not check if a smaller reporting company)
Emerging growth company
If an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition period for complying with any new or revised financial accounting standards provided pursuant to Section 13(a) of the Exchange Act. o
Indicate by check mark whether the registrant has filed a report on and attestation to its management's assessment of the effectiveness of its internal control over financial reporting under Section 404(b) of the Sarbanes-Oxley Act (15 U.S.C. 7262(b)) by the registered public accounting firm that prepared or issued its audit report.  
Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Act). Yes o No 
TheAs of June 30, 2020, the aggregate market value of the registrant’s common stock (“Common Stock”) held on June 30, 2017 by non-affiliates was approximately $239,643,149,085 (based on the June 30, 2017 closing price of Common Stock of $24.26 per share as reported on the New York Stock Exchange).$205,771,938,594. At February 21, 2018,23, 2021, there were 10,243,688,8968,633,185,862 shares of Common Stock outstanding.
Documents incorporated by reference: Portions of the definitive proxy statement relating to the registrant’s 2021 annual meeting of stockholders scheduled to be held on April 25, 2018 are incorporated by reference in this Form 10-K in response to Items 10, 11, 12, 13 and 14 of Part III.


2 Bank of America






Table of Contents
Bank of America Corporation and Subsidiaries
Page
Page


1 Bank of America


Part I
Bank of America Corporation and Subsidiaries
Item 1. Business
Bank of America Corporation is a Delaware corporation, a bank holding company (BHC) and a financial holding company. When used in this report, “the Corporation”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. As part of our efforts to streamline the Corporation’s organizational structure and reduce complexity and costs, the Corporation has reduced and intends to continue to reduce the number of its corporate subsidiaries, including through intercompany mergers.
Bank of America is one of the world’s largest financial institutions, serving individual consumers, small- and middle-market businesses, institutional investors, large corporations and governments with a full range of banking, investing, asset management and other financial and risk management products and services. Our principal executive offices are located in the
Bank of America Corporate Center, 100 North Tryon Street, Charlotte, North Carolina 28255.
Bank of America’s website is www.bankofamerica.com, and the Investor Relations portion of our website is http://investor.bankofamerica.com. We use our website to distribute company information, including as a means of disclosing material, non-public information and for complying with our disclosure obligations under Regulation FD. We routinely post and make accessible financial and other information, including environmental, social and governance (ESG) information, regarding usthe Corporation on our website. Accordingly, investorsInvestors should monitor the Investor Relations portion of our website, in addition to following our press releases, SECU.S. Securities and Exchange Commission (SEC) filings, public conference calls and webcasts. Our Annual Reports on Form 10-K, Quarterly Reports on Form 10-Q, Current Reports on Form 8-K and amendments to those reports filed or furnished pursuant to Section 13(a) or 15(d) of the Securities Exchange Act of 1934 (Exchange Act) are available on the Investor Relations portion of our website under the heading

1Bank of America 2017



Financial Information SEC Filings as soon as reasonably practicable after we electronically file such reports with, or furnish them to, the U.S. SecuritiesSEC and Exchange Commission (SEC).at the SEC’s website, www.sec.gov. Notwithstanding the foregoing, the information contained on our website as referenced in this paragraph is not incorporated by reference into this Annual Report on Form 10-K. Also, we make available on the Investor Relations portion of our website under the heading Corporate Governance:website: (i) our Code of Conduct (including our insider trading policy);Conduct; (ii) our Corporate Governance Guidelines (accessible by clicking on the Governance Highlights link);Guidelines; and (iii) the charter of each active committee of our Board of Directors (the Board) (accessible by clicking on the committee names under the Committee Composition link). We also intend to disclose any amendments to our Code of Conduct orand waivers of our Code of Conduct on behalfrequired to be disclosed by the rules of our Chief Executive Officer, Chief Financial Officer or Chief Accounting Officer,the SEC and the New York Stock Exchange on the Investor Relations portion of our website. All of these corporate governance materials are also available free of charge in print to shareholders who request them in writing to: Bank of America Corporation, Attention: Office of the Corporate Secretary, Hearst Tower, 214Bank of America Corporate Center, 100 North Tryon Street, NC1-027-18-05,NC1-007-56-06, Charlotte, North Carolina 28255.
Coronavirus Disease
The Corporation has been, and continues to be, impacted by the Coronavirus Disease 2019 (COVID-19) pandemic (the 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 have
been 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 resulted in, among other things, higher rates of unemployment and underemployment and caused volatility and disruptions in the global financial markets during 2020, including the energy and commodity markets.
In response to the pandemic, the Corporation has been taking a proactive role in addressing the impact of the pandemic on its employees, its operations, its clients and the community, including the implementation of 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 the Corporation’s enterprise-wide response.
Although some restrictive measures have been eased in certain areas, many restrictive measures remain in place or have been reinstated, and in some cases additional restrictive measures are being or may need to be implemented in light of the increase in COVID-19 cases in recent months in the U.S. and in many other regions of the world. Businesses, market participants, our counterparties and clients, and the U.S. and global economies have been negatively impacted and are likely to remain so for an extended period of time, as there remains significant uncertainty about the magnitude and duration of the pandemic and the timing and strength of an economic recovery. For more information regarding COVID-19, see Item 1A. Risk Factors – Coronavirus Disease on page 7 and Executive Summary – Recent Developments – COVID-19 Pandemic in the MD&A on page 25.
Segments
Through our bankingvarious bank and various nonbank subsidiaries throughout the U.S. and in international markets, we provide a diversified range of banking and nonbank financial services and products through four business segments: Consumer Banking, Global Wealth & Investment Management (GWIM), Global Banking and Global Markets, with the remaining operations recorded in All Other. Additional information related to our business segments and the products and services they provide is included in the information set forth on pages 3036 through 3946 of Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations (MD&A) and Note 23 – Business Segment Informationto the Consolidated Financial Statements in Item 8. Financial Statements and Supplementary Data (Consolidated Financial Statements).Statements.
Competition
We operate in a highly competitive environment. Our competitors include banks, thrifts, credit unions, investment banking firms, investment advisory firms, brokerage firms, investment companies, insurance companies, mortgage banking companies, credit card issuers, mutual fund companies, hedge funds, private equity firms, and e-commerce and other internet-based companies. We compete with some of these competitors globally and with others on a regional or product specific basis.
Competition is based on a number of factors including, among others, customer service, quality and range of products and services offered, price, reputation, interest rates on loans and deposits, lending limits and customer convenience. Our ability to continue to compete effectively also depends in large part on our ability to attract new employees and retain and
Bank of America 2


motivate our existing employees, while managing compensation and other costs.
EmployeesHuman Capital Resources
We strive to make Bank of America a great place to work for our employees. We value our employees and seek to establish and maintain human resource policies that are consistent with our core values and that help realize the power of our people. Our Board and its committees, including the Compensation and Human Capital, Audit, Enterprise Risk, and Corporate Governance, ESG and Sustainability Committees, provide oversight of our human capital management strategies, programs and practices. The Corporation’s senior management provides regular briefings on human capital matters to the Board and its Committees to facilitate the Board’s oversight.
At December 31, 2017, we had2020 and 2019, the Corporation employed approximately 209,000 employees.213,000 and 208,000 employees, of which 82 percent were located in the U.S. at both dates. None of our domesticU.S. employees are subject to a collective bargaining agreement. Management considersAdditionally, in 2020 and 2019, the Corporation’s compensation and benefits expense was $32.7 billion and $32.0 billion, or 59 percent and 58 percent, of total noninterest expense.
Diversity and Inclusion
The Corporation’s commitment to diversity and inclusion starts at the top of the Corporation with oversight from our Board and CEO. The Corporation’s senior management sets the diversity and inclusion goals of the Corporation, and the Chief Human Resources Officer and Chief Diversity & Inclusion Officer partner with our CEO and senior management to drive our diversity and inclusion strategy, programs, initiatives and policies. The Global Diversity and Inclusion Council, which consists of senior executives from every line of business and is chaired by our CEO, has been in place for over 20 years. The Council sponsors and supports business, operating unit and regional diversity and inclusion councils to ensure alignment to enterprise diversity strategies and goals.
Our practices and policies have resulted in strong representation across the Corporation where our broad employee population mirrors the clients and communities we serve. We have a Board and senior management team that are 47 percent and 50 percent racially, ethnically and gender diverse. As of December 31, 2020, over 50 percent of employees were women, and, among U.S.-based employees, nearly 48 percent were people of color, 14 percent were Black/African American and 19 percent were Hispanic/Latino. As of December 31, 2020, the Corporation’s top three management levels in relation to the CEO were composed of more than 42 percent women and nearly 20 percent people of color. These workforce diversity metrics are reported regularly to the senior management team and to the Board and are publicly disclosed on our website.
We invest in our leadership by offering a range of development programs and resources that allow employees to develop and progress in their careers. We reinforce our commitment to diversity and inclusion by investing internally in our employee relationsnetworks and by facilitating conversations with employees about racial, social and economic issues. Further, we partner with various external organizations, which focus on advancing diverse talent. We also have practices in place for attracting and retaining diverse talent, including campus recruitment. For example, in 2020, approximately 45 percent of our campus hires were women, and, in the U.S., approximately 54 percent were people of color.
Employee Engagement and Talent Retention
As part of our ongoing efforts to be good.
make the Corporation a great place to work, we have conducted a confidential annual Employee Engagement Survey (Survey) for nearly two decades. The Survey results are reviewed by the Board and senior management and used to assist in reviewing the Corporation’s human capital strategies, programs and practices. In 2020, more than 90 percent of the Corporation’s employees participated in the Survey, and our Employee Engagement Index, an overall measure of employee satisfaction with the Corporation, was 91 percent. In 2020, we also had historically low turnover among our employees of seven percent.
Fair and Equitable Compensation
The Corporation is committed to racial and gender pay equity by striving to fairly and equitably compensate all of our employees. We maintain robust policies and practices that reinforce our commitment, including reviews with oversight from our Board and senior management. In 2020, our review covered our regional hubs (U.S., U.K., France, Ireland, Hong Kong, and Singapore) and India and showed that compensation received by women, on average, was greater than 99 percent of that received by men in comparable positions and, in the U.S., compensation received by people of color was, on average, greater than 99 percent of that received by teammates who are not people of color in comparable positions.
We also strive to pay our employees fairly based on market rates for their roles, experience and how they perform, and we regularly benchmark against other companies both within and outside our industry to help ensure our pay is competitive. In the first quarter of 2020, we raised our minimum hourly wage for U.S. employees to $20 per hour, which is above all governmental minimum wage levels in all jurisdictions in which we operate in the U.S.
Health and Wellness – 2020 Focus
The Corporation also is committed to supporting employees’ physical, emotional and financial wellness by offering flexible and competitive benefits, including comprehensive health and insurance benefits and wellness resources. In 2020, we took steps to support our employees during the ongoing health crisis resulting from the pandemic, including monitoring guidance from the U.S. Centers for Disease Control and Prevention, medical boards and health authorities and sharing such guidance with our employees. In addition, as a result of the pandemic we transitioned to a work-from-home posture for the substantial majority of our employees and provided various benefits and resources related to the pandemic, including the implementation of child and adult care solutions, offering no-cost COVID-19 testing and mental health resources and additional support for teammates who work in the office, such as transportation and meal subsidies. We continue to engage with state and national governments to understand their vaccination plans for essential workers, including the extent to which that may include some of our employees, and with our employees to educate them about vaccines and the importance of being vaccinated. For more information on our response to the pandemic, including with respect to human capital measures, see Executive Summary – Recent Developments – COVID-19 Pandemic on page 25.
Government Supervision and Regulation
The following discussion describes, among other things, elements of an extensive regulatory framework applicable to BHCs, financial holding companies, banks and broker-dealers, including specific information about Bank of America.
3 Bank of America


We are subject to an extensive regulatory framework applicable to BHCs, financial holding companies and banks and other financial services entities. U.S. federal regulation of banks, BHCs and financial holding companies is intended primarily for the protection of depositors and the Deposit Insurance Fund (DIF) rather than for the protection of shareholders and creditors.
As a registered financial holding company and BHC, the Corporation is subject to the supervision of, and regular inspection by, the Board of Governors of the Federal Reserve System (Federal Reserve). Our U.S. bank subsidiaries (the Banks), organized as national banking associations, are subject to regulation, supervision and examination by the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC) and the Federal Reserve. In addition, the Federal Reserve and the OCC have adopted guidelines that establish minimum standards for the design, implementation and board oversight of BHCs’ and national banks’ risk governance frameworks. U.S. financial holding companies, and the companies under their control, are permitted to engage in activities considered “financial in nature” as defined by the Gramm-Leach-Bliley Act and related Federal Reserve interpretations. Unless otherwise limited by the Federal Reserve,The Corporation's status as a financial holding company may engage directly or indirectlyis conditioned upon maintaining certain eligibility requirements for both the Corporation and its U.S. depository institution subsidiaries, including minimum capital ratios, supervisory ratings and, in activities considered financial in nature provided the case of the depository institutions, at least satisfactory Community Reinvestment Act ratings. Failure to be an eligible financial holding company givescould result in the Federal Reserve after-the-fact noticelimiting Bank of the new activities. The Gramm-Leach-Bliley Act also permits national banks to engage inAmerica's activities, considered financial in nature through a financial subsidiary, subject to certain conditions and limitations and with the approval of the OCC.including potential acquisitions.
The scope of the laws and regulations and the intensity of the supervision to which we are subject have increased in recentover the past several years, inbeginning with the response to the financial crisis, as well as other factors such as technological and market changes. In addition, the banking and financial services sector is subject to substantial regulatory enforcement and fines. Many of these changes have occurred as a result of the 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act (the Financial Reform Act). We cannot assess whether there will be any additional major changes in the regulatory environment and expect that our business will remain subject to continuing and extensive regulation and supervision.
We are also subject to various other laws and regulations, as well as supervision and examination by other regulatory agencies, all of which directly or indirectly affect our operationsentities and management and our ability to make distributions to shareholders. For instance, our broker-dealer subsidiaries are subject to both U.S. and international regulation, including supervision by the SEC, theFinancial Industry Regulatory Authority and New York Stock Exchange, and the Financial Industry Regulatory Authority, among others; our futures commission merchant subsidiaries supporting commodities and derivatives businesses in the U.S. are subject to regulation by and supervision of the U.S. Commodity Futures Trading Commission (CFTC); our U.S. derivatives activity is subject to regulation and supervision of the CFTC and, National Futures Association, or the SEC,Chicago Mercantile Exchange and in the case of the Banks, certain banking regulators; our insurance activities are subject to licensing and regulation by state insurance regulatory agencies; and our consumer financial products and services are regulated by the Consumer Financial Protection Bureau (CFPB).
Our non-U.S. businesses are also subject to extensive regulation by various non-U.S. regulators, including governments, securities exchanges, prudential regulators, central banks and other regulatory bodies, in the jurisdictions in which those businesses operate. For example, our financial
services operationsentities in the United Kingdom (U.K.), Ireland and France are subject to regulation

Bank of America 20172


by and supervision of the Prudential Regulatory Authority for prudential matters, and the Financial Conduct Authority, (FCA) for the conductEuropean Central Bank and Central Bank of business matters.Ireland, and the Autorité de Contrôle Prudentiel et de Résolution and Autorité des Marchés Financiers, respectively.
Source of Strength
Under the Financial Reform Act and Federal Reserve policy, BHCs are expected to act as a source of financial strength to each subsidiary bank and to commit resources to support each such subsidiary. Similarly, under the cross-guarantee provisions of the Federal Deposit Insurance Corporation Improvement Act of 1991 (FDICIA), in the event of a loss suffered or anticipated by the FDIC, either as a result of default of a bank subsidiary or related to FDIC assistance provided to such a subsidiary in danger of default, the affiliate banks of such a subsidiary may be assessed for the FDIC’s loss, subject to certain exceptions.
Transactions with Affiliates
Pursuant to Section 23A and 23B of the Federal Reserve Act, as implemented by the Federal Reserve’s Regulation W, the Banks are subject to restrictions that limit certain types of transactions between the Banks and their nonbank affiliates. In general, U.S. banks are subject to quantitative and qualitative limits on extensions of credit, purchases of assets and certain other transactions involving itstheir nonbank affiliates. Additionally, transactions between U.S. banks and their nonbank affiliates are required to be on arm’s length terms and must be consistent with standards of safety and soundness.
Deposit Insurance
Deposits placed at U.S. domiciled banks (U.S. banks) are insured by the FDIC, subject to limits and conditions of applicable law and the FDIC’s regulations. Pursuant to the Financial Reform Act, FDIC insurance coverage limits are $250,000 per customer. All insured depository institutions are required to pay assessments to the FDIC in order to fund the DIF.
The FDIC is required to maintain at least a designated minimum ratio of the DIF to insured deposits in the U.S. The Financial Reform Act requires the FDIC to assess insured depository institutions to achieve a DIF ratio of at least 1.35 percent by September 30, 2020. The FDIC has adopted regulations that establish a long-term target DIF ratio of greater than two percent. TheAs of the date of this report, the DIF ratio is currently below thethis required targetstarget, and the FDIC has adopted a restoration plan that may result in increased deposit insurance assessments. In 2016, the FDIC implemented a surcharge to accelerate compliance with the 1.35 percentage requirement. Deposit insurance assessment rates are subject to change by the FDIC and will be impacted by the overall economy and the stability of the banking industry as a whole. For more information regarding deposit insurance, see Item 1A. Risk Factors – Regulatory, Compliance and Legal on page 12.16.
Capital, Liquidity and Operational Requirements
As a financial holding company, we and our bank subsidiaries are subject to the regulatory capital and liquidity guidelinesrules issued by the Federal Reserve and other U.S. banking regulators, including the FDICOCC and the OCC.FDIC. These rules are complex and are evolving as U.S. and international regulatory authorities propose and enact enhanced capital and liquidityamendments to these rules. The Corporation seeks to manage its capital position to maintain sufficient capital to meetsatisfy these regulatory guidelinesrules and to support our business activities. These continually evolving rules are likely to influence our planning processes for, and may require additional regulatory capital and liquidity, as well as impose additional operational and compliance costs on the Corporation. In addition, the Federal Reserve and the OCC have adopted guidelines that establish minimum standards for the design, implementation and board oversight of BHCs’ and
national banks’ risk governance frameworks. The Federal Reserve has also issued a final rule requiring us to maintain minimum amounts of long-term debt meeting specified eligibility requirements.
For more information on regulatory capital rules, capital composition and pending or proposed regulatory capital
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changes, see Capital Management – Regulatory Capital in the MD&A on page 45,50, and Note 16 – Regulatory Requirements and Restrictions to the Consolidated Financial Statements, which are incorporated by reference in this Item 1.
Distributions
We are subject to various regulatory policies and requirements relating to capital actions, including payment of dividends and common stock repurchases. For instance, Federal Reserve regulations require major U.S. BHCs to submit a capital plan as part of an annual Comprehensive Capital Analysis and Review (CCAR). The purpose of the CCAR for the Federal Reserve is to assess the capital planning process of the BHC, including any planned capital actions, such as payment of dividends and common stock repurchases.
Our ability to pay dividends is also affected by the variousand make common stock repurchases depends in part on our ability to maintain regulatory capital levels above minimum capital requirements and the capitalplus buffers and non-capital standards established under the FDICIA. The rightTo the extent that the Federal Reserve increases our stress capital buffer (SCB), global systemically important bank (G-SIB) surcharge or countercyclical capital buffer, our returns of capital to shareholders could decrease. As part of its CCAR, the Federal Reserve conducts stress testing on parts of our business using hypothetical economic scenarios prepared by the Federal Reserve. Those scenarios may affect our CCAR stress test results, which may impact the level of our SCB. Additionally, the Federal Reserve may impose limitations or prohibitions on taking capital actions such as paying or increasing common stock dividends or repurchasing common stock. For example, as a result of the economic uncertainty resulting from the pandemic, the Federal Reserve required that during the second half of 2020, all large banks, including the Corporation, our shareholderssuspend share repurchase programs, except for repurchases to offset shares awarded under equity-based compensation plans, and our creditorslimit common stock dividends to participate in any distributionexisting rates that did not exceed the average of the assets or earningslast four quarters' net income. In the first quarter of our subsidiaries is further subject2021, the Federal Reserve lifted the suspension of share repurchase programs and permitted large banks to pay common stock dividends and to repurchase shares in an amount that, when combined with dividends paid, does not exceed the prior claimsaverage of creditors ofnet income over the respective subsidiaries.last four quarters.
If the Federal Reserve finds that any of our Banks are not “well-capitalized” or “well-managed,” we would be required to enter into an agreement with the Federal Reserve to comply with all applicable capital and management requirements, which may contain additional limitations or conditions relating to our activities. Additionally, the applicable federal regulatory authority is authorized to determine, under certain circumstances relating to the financial condition of a bank or BHC, that the payment of dividends would be an unsafe or unsound practice and to prohibit payment thereof.
For more information regarding the requirements relating to the payment of dividends, including the minimum capital requirements, see Note 13 – Shareholders’ Equity and Note 16 – Regulatory Requirements and Restrictionsto the Consolidated Financial Statements.Statements.
Many of our subsidiaries, including our bank and broker-dealer subsidiaries, are subject to laws that restrict dividend payments, or authorize regulatory bodies to block or reduce the flow of funds from those subsidiaries to the parent company or other subsidiaries. The rights of the Corporation, our shareholders and our creditors to participate in any distribution of the assets or earnings of our subsidiaries is further subject to the prior claims of creditors of the respective subsidiaries.

Resolution Planning
As a BHC with greater than $50$250 billion of assets, the Corporation is required by the Federal Reserve and the FDIC to periodically submit a plan for a rapid and orderly resolution in the event of material financial distress or failure.
Such resolution plan is intended to be a detailed roadmap for the orderly resolution of athe BHC, andincluding the continued operations or solvent wind down of its material entities, pursuant to the U.S. Bankruptcy Code and other applicable resolution regimes under one or more hypothetical scenarios assuming no extraordinary government assistance.
If both the Federal Reserve and the FDIC determine that the BHC’s plan is not credible, the Federal Reserve and the FDIC may jointly impose more stringent capital, leverage or liquidity requirements or restrictions on growth, activities or operations. A descriptionsummary of our plan is available on the Federal Reserve and FDIC websites.

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The FDIC also requires the submission of a resolution plan for Bank of America, N.A.National Association (BANA), which must describe how the insured depository institution would be resolved under the bank resolution provisions of the Federal Deposit Insurance Act. A description of this plan is available on the FDIC’s website.
We continue to make substantial progress to enhance our resolvability, including simplifying our legal entity structure and business operations, and increasing our preparedness to implement our resolution plan, both from a financial and operational standpoint.
Similarly,Across international jurisdictions, resolution planning is the responsibility of national resolution authorities (RA). Among those, the jurisdictions of most impact to the Corporation are the requirements associated with subsidiaries in the U.K., Ireland and France, where rules have been issued requiring the submission of significant information about certain U.K.-incorporatedlocally-incorporated subsidiaries and other financial institutions, as well as branches of non-U.K. banks located in the U.K. (including information on intra-group dependencies, legal entity separation and barriers to resolution) as well as the Corporation’s banking branches located in those jurisdictions that are deemed to allow the Bank of England to developbe material for resolution plans.planning purposes. As a result of the Bank of England’sRA's review of the submitted information, we could be required to take certain actions over the next several years whichthat could increase operating costs and potentially result in the restructuring of certain businesses and subsidiaries.
For more information regarding our resolution plan, see Item 1A. Risk Factors – Liquidity on page 6.9.
Insolvency and the Orderly Liquidation Authority
Under the Federal Deposit Insurance Act, the FDIC may be appointed receiver of an insured depository institution if it is insolvent or in certain other circumstances. In addition, under the Financial Reform Act, when a systemically important financial institution (SIFI) such as the Corporation is in default or danger of default, the FDIC may be appointed receiver in order to conduct an orderly liquidation of such institution. In the event of such appointment, the FDIC could, among other things, invoke the orderly liquidation authority, instead of the U.S. Bankruptcy Code, if the Secretary of the Treasury makes certain financial distress and systemic risk determinations. The orderly liquidation authority is modeled in part on the Federal Deposit Insurance Act, but also adopts certain concepts from the U.S. Bankruptcy Code.
The orderly liquidation authority contains certain differences from the U.S. Bankruptcy Code. For example, in certain circumstances, the FDIC could permit payment of obligations it determines to be systemically significant (e.g., short-term
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creditors or operating creditors) in lieu of paying other obligations (e.g., long-term creditors) without the need to obtain creditors’ consent or prior court review. The insolvency and resolution process could also lead to a large reduction or total elimination of the value of a BHC’s outstanding equity, as well as impairment or elimination of certain debt.
Under the FDIC’s “single point of entry” strategy for resolving SIFIs, the FDIC could replace a distressed BHC with a bridge holding company, which could continue operations and result in an orderly resolution of the underlying bank, but whose equity is held solely for the benefit of creditors of the original BHC.
Furthermore, the Federal Reserve Board has finalized regulations regarding therequires that BHCs maintain minimum levels of long-term debt required for BHCs to provide adequate loss absorbing capacity in the event of a resolution.
For more information regarding our resolution, see Item 1A. Risk Factors – Liquidity on page 6.9.
Limitations on Acquisitions
The Riegle-Neal Interstate Banking and Branching Efficiency Act of 1994 permits a BHC to acquire banks located in states other than its home state without regard to state law, subject to certain conditions, including the condition that the BHC, after and as a
result of the acquisition, controls no more than 10 percent of the total amount of deposits of insured depository institutions in the U.S. and no more than 30 percent or such lesser or greater amount set by state law of such deposits in that state. At June 30, 2017,2020, we held greater than 10 percent of the total amount of deposits of insured depository institutions in the U.S.
In addition, the Financial Reform Act restricts acquisitions by a financial institution if, as a result of the acquisition, the total liabilities of the financial institution would exceed 10 percent of the total liabilities of all financial institutions in the U.S. At June 30, 2017,2020, our liabilities did not exceed 10 percent of the total liabilities of all financial institutions in the U.S.
The Volcker Rule
The Volcker Rule prohibits insured depository institutions and companies affiliated with insured depository institutions (collectively, banking entities) from engaging in short-term proprietary trading of certain securities, derivatives, commodity futures and options for their own account. The Volcker Rule also imposes limits on banking entities’ investments in, and other relationships with, hedge funds and private equity funds. The Volcker Rule provides exemptions for certain activities, including market-making,market making, underwriting, hedging, trading in government obligations, insurance company activities and organizing and offering hedge funds and private equity funds. The Volcker Rule also clarifies that certain activities are not prohibited, including acting as agent, broker or custodian. A banking entity with significant trading operations, such as the Corporation, is required to maintain a detailed compliance program to comply with the restrictions of the Volcker Rule.
Derivatives
Our derivatives operations are subject to extensive regulation globally. These operations are subject to regulation under the Financial Reform Act, the EUEuropean Union (EU) Markets in Financial Instruments Directive and Regulation, the European Market Infrastructure Regulation, analogous U.K. regulatory regimesand similar regulatory regimes in other jurisdictions, that regulate or will regulate the derivatives markets in which we operate by, among other things: requiring clearing and exchange trading of certain derivatives; imposing new capital, margin, reporting, registration and business conduct requirements for certain market participants; imposing position limits on certain
over-the-counter (OTC) derivatives; and imposing derivatives trading transparency requirements; and requiring registration as swap dealers, major swap participants or analogous regulated entities. Most regulationsrequirements. Regulations of derivatives are already in effect in many markets in which we operate are already in effect.operate.
In addition, many G-20 jurisdictions, including the U.S., U.K., Germany and Japan, have adopted resolution stay regulations to address concerns that the close-out of derivatives and other financial contracts in resolution could impede orderly resolution of global systemically important banks (G-SIBs),G-SIBs, and additional jurisdictions are expected to follow suit. We and 24 other G-SIBs have adhered to a protocol amendingGenerally, these resolution stay regulations require amendment of certain financial contracts to provide for contractual recognition of stays of termination rights under various statutory resolution regimes and a stay on the exercise of cross-default rights based on an affiliate’s entry into U.S. bankruptcyinsolvency proceedings. As resolution stay regulations of a particular jurisdiction applicable to us go into effect, we amend impacted financial contracts in compliance with such regulations.regulations either as a regulated entity or as a counterparty facing a regulated entity in such jurisdiction.
Consumer Regulations
Our consumer businesses are subject to extensive regulation and oversight by federal and state regulators. Certain federal consumer finance laws to which we are subject, including but not limited to, the Equal Credit Opportunity Act, the Home Mortgage Disclosure

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Act, the Electronic Fund Transfer Act, the Fair Credit Reporting Act, the Real Estate Settlement Procedures Act, the Truth in Lending Act and Truth in Savings Act, are enforced by the CFPB. Other federal consumer finance laws, such as the Servicemembers Civil Relief Act, are enforced by the OCC.
Privacy and Information Security
We are subject to many U.S. federal, state and international laws and regulations governing requirements for maintaining policies and procedures to protectregarding the disclosure, use and protection of the non-public confidential information of our customers and employees. The Gramm-Leach-Bliley Act requires us to periodically disclose Bank of America’s privacy policies and practices relating to sharing such information and enables retail customers to opt out of our ability to share information with unaffiliated third parties, under certain circumstances. The Gramm-Leach-Bliley Act and other laws also require us to implement a comprehensive information security program that includes administrative, technical and physical safeguards to provide the security and confidentiality of customer records and information. Security and privacy policies and procedures for the protection of personal and confidential information are in effect across all businesses and geographic locations.
Other laws and regulations, at the international, federal and state level, impact our ability to share certain information with affiliates and non-affiliates for marketing and/or non-marketing purposes, or to contact customers with marketing offers. The Gramm-Leach-Blileyoffers and establish certain rights of consumers in connection with their personal information. For example, California’s Consumer Privacy Act also requires us(CCPA), which went into effect in January 2020, as modified by the California Privacy Rights Act (CPRA), provides consumers with the right to implement a comprehensive information security program that includes administrative, technicalknow what personal data is being collected, know whether their personal data is sold or disclosed and physical safeguards to providewhom and opt out of the security and confidentialitysale of customer records and information. These security and privacy policies and procedures fortheir personal data, among other rights. In addition, in the protection of personal and confidential information are in effect across all businesses and geographic locations. The European Union (EU) has adoptedEU, the General Data Protection Regulation (GDPR) which replacesreplaced the Data Protection Directive and related implementing national laws in its member states. The CCPA's, CPRA's and GDPR’s impact on the Member States. TheCorporation was assessed and addressed through comprehensive compliance date forimplementation programs. These existing and evolving legal requirements in the GDPR is May 25, 2018. It will have impacts across the enterpriseU.S. and impact assessments are underway. Meanwhile other legislation, regulatory activity (the proposed e-Privacy Regulation, elements of the Fourth Money Laundering Directive) andabroad,
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as well as court proceedings and any impact of bilateral U.S. and EU political developments onchanging guidance from regulatory bodies with respect to the validity of cross-border data transfer mechanisms from the EU, continue to lend uncertainty to privacy compliance in the EU.globally.
Item 1A. Risk Factors
In the course of conducting our business operations, we are exposed to a variety of risks, some of which are inherent in the financial services industry and others of which are more specific to our own businesses. The discussion below addresses the most significantmaterial factors of which we are currently aware that could affect our businesses, results of operations and financial condition. Additional factors that could affect our businesses, results of operations and financial condition are discussed in Forward-looking Statements in the MD&A on page 19. However, other factors not discussed belowcurrently known to us or elsewhere in this Annual Report on Form 10-Kthat we currently deem immaterial could also adversely affect our businesses, results of operations and financial condition. Therefore, the risk factors below should not be considered a complete listall of the potential risks that we may face. For more information on how we manage risks, see Managing Risk in the MD&A on page 41.47. For more information about the risks contained in the Risk Factors section, see Item 1. Business on page 2, MD&A on page 24 and Notes to Consolidated Financial Statements on page 101.
Any risk factor described in this Annual Report on Form 10-K or in anyCoronavirus Disease
The effects of our other SEC filings could by itself, or together with other factors, materiallythe pandemic have adversely affected, and are expected to continue to adversely affect, our liquidity, competitive position, business, reputation,businesses and results of operations, capital position orand its duration and future impacts on the economy and our businesses, results of operations and financial condition remain uncertain.
The negative economic conditions arising from the pandemic negatively impacted our financial results during 2020 in various respects, including contributing to increases in our allowance and provision for credit losses and noninterest expense. These negative economic conditions may have a continued adverse effect on our businesses and results of operations, which could include: decreased demand for and use of our products and services; protracted periods of historically low interest rates; lower fees, including asset management fees; lower sales and trading revenue due to decreased market liquidity resulting from heightened volatility; higher levels of uncollectible reversed charges in our merchant services business; increased noninterest expense, including operational losses; and increased credit losses due to our customers' and clients' inability to fulfill contractual obligations and deterioration in the financial condition of our consumer and commercial borrowers, which may vary by materially increasingregion, sector or industry, that may increase our expenses provision for credit losses and net charge-offs. Our provision for credit losses and net charge-offs may also continue to be impacted by volatility in the energy and commodity markets. Additionally, our liquidity and/or decreasingregulatory capital could be adversely impacted by customers’ withdrawal of deposits, volatility and disruptions in the capital and credit markets, volatility in foreign exchange rates and customer draws on lines of credit. Continued adverse macroeconomic conditions could also result in potential downgrades to our revenues,credit ratings, negative impacts to regulatory capital and liquidity and further restrictions on dividends and/or common stock repurchases.
If we become unable to operate our businesses from remote locations including, for example, because of an internal or external failure of our information technology infrastructure, we experience increased rates of employee illness or unavailability, or governmental restrictions are placed on our employees or operations, this could adversely affect our business continuity status and result in disruption to our businesses. Additionally, we rely on third parties who could experience adverse effects on their business continuity and business interruptions, which could increase our risks and adversely impact our businesses.
There can be no assurance that current or future governmental fiscal and monetary relief programs will stimulate
the global economy or avert negative economic or market conditions. Our participation in such programs could result in reputational harm and government actions and proceedings, and has resulted in, and may continue to result in, litigation, including class actions. Such actions may result in judgments, settlements, penalties, and fines. Our participation in such programs has also resulted and may continue to result in operational losses, including from the Paycheck Protection Program (PPP) and processing unemployment insurance.
We continue to closely monitor the pandemic and related risks as they evolve globally and in the U.S. The magnitude and duration of the pandemic and its future direct and indirect effects on the global economy and our businesses, results of operations and financial condition are highly uncertain and depend on future developments that cannot be predicted, including the likelihood of further surges of COVID-19 cases and the spread of more easily communicable variants of COVID-19, the timing and availability of effective medical treatments and vaccines, future actions taken by governmental authorities, including additional stimulus legislation, and/or other third parties in response to the pandemic. The pandemic may cause prolonged global or national negative economic conditions or longer lasting effects on economic conditions than currently exist, which could have a material losses.
adverse effect on our businesses, results of operations and financial condition.
Market
Our business and results of operations may be adversely affected by the U.S. and international financial markets, U.S.fiscal, monetary, and non-U.S. fiscal and monetaryregulatory policies, and economic conditions generally.
Financial markets and generalGeneral economic, political, social and socialhealth conditions in the U.S. and in one or more countries abroad includingaffect markets in the U.S. and abroad and our business. In particular, markets in the U.S. or abroad may be affected by the level and volatility of interest rates, availability and market conditions of financing, unexpected changes in market financing conditions, gross domestic product (GDP), economic growth or its sustainability, inflation, consumer spending, employment levels, wage stagnation, federal government shutdowns, developments related to the federal debt ceiling, energy prices, home prices, bankruptcies, a default by a significant market participant, fluctuations or other significant changes in both debt and equity capital markets and currencies, liquidity of the global financial markets, the growth of global trade and commerce, trade policies, the availability and cost of capital and credit, disruption of communication, transportation or energy infrastructure and investor sentiment and confidence,confidence. Additionally, global markets, including energy and commodity markets, may be adversely affected by the sustainabilitycurrent or anticipated impact of economic growth allclimate change, extreme weather events or natural disasters, the emergence of widespread health emergencies or pandemics, cyber attacks or campaigns, military conflict, terrorism or other geopolitical events. Market fluctuations may impact our margin requirements and affect our business.
Inbusiness liquidity. Also, any sudden or prolonged market downturn in the U.S. or abroad, as a result of the above factors or otherwise, could result in a decline in net interest income and abroad, uncertainties surrounding fiscalnoninterest income and monetary policies presentadversely affect our results of operations and financial condition, including capital and liquidity levels. For example, the global markets, including the energy and commodity markets, experienced significant volatility and disruption as a result of the uncertainty and economic challenges. impact of the pandemic. Further uncertainty and ongoing developments in connection with the pandemic, including its further spread, changing consumer and business behaviors, government restrictions in an effort to control the virus and timing and availability of effective medical treatments and vaccines, could
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result in further market volatility and disruptions globally and continue to adversely impact macroeconomic conditions.
Actions taken by the Federal Reserve, including the planned reductionchanges in its target funds rate, balance sheet management, and lending facilities, and other central banks are beyond our control and difficult to predict andpredict. These actions can affect interest rates and the value of financial instruments and other assets such as debt securities and mortgage servicing rights (MSRs),liabilities, and impact our borrowers, potentially increasing delinquency rates.borrowers. The continued protracted period of lower interest rates has resulted in lower revenue through lower net interest income, which has adversely affected our results of operations. Additional periods of lower interest rates or a move to negative interest rates in the U.S., could have a further adverse impact on our net interest income and results of operations. Uncertainty or ongoing developments in connection with the U.K.’s exit from the EU, and the resulting impact on the financial markets and regulations in relevant jurisdictions, could negatively impact our revenues and ongoing operations in Europe and other jurisdictions.
Changes to existing U.S. laws and regulatory policies, including those related to financial regulation, taxation, international trade, fiscal policy and healthcare, may adversely impact us.U.S. or global economic activity and our customers', our counterparties' and our earnings and operations. For example, significantadditional fiscal stimulus and rising debt levels, in the U.S. and abroad, in response to the ongoing pandemic could affect macroeconomic conditions, market liquidity conditions, and interest rates. Significant fiscal policy changes and/or initiatives, including as a result of the change in the U.S. presidential administration and Congress, may also increase uncertainty surrounding the formulation and direction of U.S. monetary policy and volatility of interest rates. Higher U.S. interest rates relative to other major economies could increase the likelihood of a more volatile and appreciating U.S. dollar. Changes, or proposed changes, to certain U.S. trade and international investment policies, or measures could upsetparticularly with important trading partners (including China and the EU) have negatively impacted and may continue to negatively impact financial markets, and disrupt world trade and commerce.commerce and lead to trade retaliation, including through the use of tariffs, foreign exchange measures or the large-scale sale of U.S. Treasury Bonds. Further, the use of tariffs among countries not directly involving the U.S. could spread and could damage our customers directly and indirectly.
Any of these developments could adversely affect our consumer and commercial businesses, our customers, our securities and derivatives portfolios, including the risk of lower re-investment rates within those portfolios, our level of charge-offs and provision for credit losses, the carrying value of our deferred tax assets, our capital levels, andour liquidity and the costs of running our business, and our results of operations.
For more information about economic conditions Additionally, the uncertainty related to the transition from Interbank Offered Rates (IBORs) and challenges discussedother benchmark rates to alternative reference rates (ARRs) could negatively impact markets globally and our business, and/or magnify any negative impact of the above see Executive Summary – 2017 Economicreferenced factors on our business, customers and Business Environment in the MD&A on page 19.results of operations.
Increased market volatility and adverse changes in other financial or capital market conditions may increase our market risk.
Our liquidity, competitive position, business, results of operations and financial condition are affected by market risks such as changes in interest and currency exchange rates, fluctuations in equity and futures prices, lower trading volumes and prices of securitized products, the implied volatility of interest rates and credit spreads and other economic and business factors. These market risks may adversely affect, among other things, (i) the value of our on- and off-balance sheet
securities, trading assets and other financial instruments, and MSRs, (ii) the cost of debt capital and our access to credit markets, (iii) the value of assets under management (AUM), (iv) fee income relating to AUM, (v) customer allocation of capital among investment alternatives, (vi) the volume of client activity in our trading operations, (vii) investment banking fees, (viii) the general profitability and risk level of the transactions in which we engage and (ix) our competitiveness with respect to deposit pricing. For example, the value of certain of our assets is sensitive to changes in market interest rates. If the Federal

5Bank of America 2017



Reserve or a non-U.S. central bank changes or signals a change in monetary policy, market interest rates could be affected, which could adversely impact the value of such assets. Changes to fiscal policy, including rapid expansion of U.S. federal deficit spending and resultant debt issuance, could also affect market interest rates. In addition, the ongoing low interest rate environment and recent flattening of thea flat or inverted yield curve has had and could negativelycontinue to have a negative impact on our liquidity, financial condition or results of operations, including on future revenue and earnings growth.
We use various models and strategies to assess and control our market risk exposures, but those are subject to inherent limitations. For more information regarding models and strategies, see Item 1A. Risk Factors – Other on page 15. In times of market stress or other unforeseen circumstances, previously uncorrelated indicators may become correlated and vice versa. These types of market movements may limit the effectiveness of our hedging strategies and cause us to incur significant losses. These changes in correlation can be exacerbated where other market participants are using risk or trading models with assumptionassumptions or algorithms that are similar to ours. In these and other cases, it may be difficult to reduce our risk positions due to activity of other market participants or widespread market dislocations, including circumstances where asset values are declining significantly or no market exists for certain assets. To the extent that we own securities that do not have an established liquid trading market or are otherwise subject to restrictions on sale or hedging, we may not be able to reduce our positions and therefore reduce our risk associated with such positions. In addition, challenging market conditions may also adversely affect our investment banking fees.
For more information about market risk and our market risk management policies and procedures, see Market Risk Management in the MD&A on page 76.
We may incur losses if the value of certain assets declines,decline, including due to changes in interest rates and prepayment speeds.
We have a large portfolio of financial instruments, including among others, certain loans and loan commitments, loans held-for-sale, securities financing agreements, asset-backed secured financings, long-term deposits, long-term debt, trading account assets and liabilities, derivative assets and liabilities, available-for-sale (AFS) debt andsecurities, marketable equity securities other debt securities, certain MSRs and certain other assets and liabilities that we measure at fair value.value that are subject to valuation and impairment assessments. We determine the fairthese values of these instruments based on applicable accounting guidance, which for financial instruments measured at fair value, requires an entity to base fair value on exit price and to maximize the use of observable inputs and minimize the use of unobservable inputs in fair value measurements. The fair values of these financial instruments include adjustments for market liquidity, credit quality, funding impact on certain derivatives and other transaction-specific factors, where appropriate.
Gains or losses on these instruments can have a direct impact on our results of operations, including higher or lower mortgage banking income and earnings, unless we have effectively hedged our exposures. For example, decreases in interest rates and increases in mortgage prepayment speeds, which are influenced by interest rates and other factors such as reductions in mortgage insurance premiums and origination costs, could adversely impact the value of our MSR asset, causing a significant acceleration of purchase premium amortization on our mortgage portfolio, because a decline in long-term interest rates shortens the expected lives of the securities, and adversely affects our net interest margin. Conversely, increasesIncreases in interest rates may result in a decrease in residential mortgage loan originations. In addition, increases in interest rates may adversely impact the fair value of debt securities and, accordingly, for debt securities classified as AFS,available for sale, may adversely affect accumulated other comprehensive income and, thus, capital levels. Decreases in interest rates may increase prepayment speeds of certain assets, and therefore may adversely affect net interest income.
Fair values may be impacted by declining values of the underlying assets or the prices at which observable market
Bank of America 8


transactions occur and the continued availability of these transactions.transactions or indices. The financial strength of counterparties, with whom we have economically hedged some of our exposure to these assets, also will affect the fair value of these assets. Sudden declines and volatility in the prices of assets may curtail or eliminate trading activities in these assets, which may make it difficult to sell, hedge or value these assets. The inability to sell or effectively hedge assets reduces our ability to limit losses in such positions and the difficulty in valuing assets may increase our risk-weighted assets (RWA), which requires us to maintain additional capital and increases our funding costs. Asset valuesValues of AUM also directly impact revenues in our wealth management and related advisory businesses. We receivebusinesses for asset-based management fees based on the value of our clients’ portfolios or investments in funds managed by us and in some cases, we also receive performance fees based on increases in the value of such investments.fees. Declines in asset values can reduce the value of our clients’ portfolios or fund assets, which in turnAUM can result in lower fees earned for managing such assets.
For more information on fair value measurements, see Note 20 – Fair Value Measurements to the Consolidated Financial Statements. For more information on our asset management businesses, see GWIM in the MD&A on page 33. For more information on interest rate risk management, see Interest Rate Risk Management for the Banking Book in the MD&A on page 81.
Liquidity
If we are unable to access the capital markets or continue to maintain deposits, or our borrowing costs increase, our liquidity and competitive position will be negatively affected.
Liquidity is essential to our businesses. We fund our assets primarily with globally sourced deposits in our bank entities, as well as secured and unsecured liabilities transacted in the capital markets. We rely on certain secured funding sources, such as repo markets, which are typically short-term and credit-sensitive in nature. We also engage in asset securitization transactions, including with the government-sponsored enterprises (GSEs), to fund consumer lending activities. Our liquidity could be adversely affected by any inability to access the capital markets;markets, illiquidity or volatility in the capital markets;markets, the decrease in value of eligible collateral or increased collateral requirements (including as a result of credit concerns for short-term borrowing), changes to our relationships with our funding providers based on real or perceived changes in our risk profile;profile, prolonged federal government shutdowns, or changes in regulations, guidance or guidanceGSE status that impact our funding avenues or ability to access certain funding sources;sources. Additionally, our liquidity may be negatively impacted by the refusalunwillingness or inability of the Federal Reserve to act as lender of last resort;resort, unexpected simultaneous draws on lines of credit, slower customer payment rates, restricted access to the assets of prime brokerage clients, the withdrawal of or failure to attract customer deposits or invested funds (which could result from customer attrition for higher yields, the desire for more conservative alternatives or our customers’ increased need for cash), increased regulatory liquidity, capital and margin requirements for our U.S. or international banks and their nonbank subsidiaries; significantsubsidiaries, changes in patterns of intraday liquidity usage resulting from a counterparty or technology failure or other idiosyncratic event or failure or default by a significant market participant or third party such as a(including clearing agentagents, custodians or custodian; reputational issues; or negative perceptions aboutcentral counterparties (CCPs)). These factors also have the potential to increase our short- or long-term business prospects, including downgrades of our credit ratings. borrowing costs.
Several of these factors may arise due to circumstances beyond our control, such as a general market volatility, disruption, shock or shock,stress, the emergence of widespread health emergencies or pandemics, Federal Reserve policy decisions (including fluctuations in interest rates or Federal Reserve balance sheet composition), negative views about the Corporation (including short- and long-term business prospects) or the financial services industry generally or due to a specific news event, changes in the regulatory environment or governmental fiscal or monetary policies (including as a result of the change in the U.S. presidential administration and Congress), actions by credit rating agencies or an operational
problem that affects third parties or us. The impact of these events, whether within our control or not, could include an inability to sell assets or redeem investments, or unforeseen outflows of cash, including customer deposits,the need to draw on liquidity facilities, the reduction of financing balances and the loss of equity secured funding, debt repurchases to support the secondary market or meet client requests, the need for additional funding for commitments and contingencies as well asand unexpected collateral calls, among other things.
things, the result of which could be increased costs, a liquidity shortfall and/or impact on our liquidity coverage ratio.

Bank of America 20176


Our liquidity and cost of obtaining funding is directly related to prevailing market conditions, including changes in interest and currency exchange rates, fluctuations in equity and tofutures prices, lower trading volumes and prices of securitized products and our credit spreads. Credit spreads are the amount in excess of the interest rate of U.S. Treasury securities, or other benchmark securities, of a similar maturity that we need to pay to our funding providers. Increases in interest rates and our credit spreads can increase the cost of our funding.funding and result in mark-to-market or credit valuation adjustment exposures. Changes in our credit spreads are market-driven and may be influenced by market perceptions of our creditworthiness. Changes to interest rates and our credit spreads occur continuously and may be unpredictable and highly volatile. We may also experience spread compression as a result of offering higher than expected deposit rates in order to attract and maintain deposits due to increased marketplace rate competition. Additionally, concentrations within our funding profile, such as maturities, currencies or counterparties, can reduce our funding efficiency.
For more information about our liquidity position and other liquidity matters, including credit ratings and outlooks and the policies and procedures we use to manage our liquidity risks, see Liquidity RiskReduction in the MD&A on page 49.
Adverse changes to our credit ratings from the major credit rating agencies could significantly limit our access to funding or the capital markets, increase our borrowing costs or trigger additional collateral or funding requirements.
Our borrowing costs and ability to raise funds are directly 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 OTC derivatives. 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 asset securitizations. Our credit ratings are subject to ongoing review by rating agencies, which consider a number of factors, including our own financial strength, performance, prospects and operations as well asand factors not under our control, such as the likelihood ofmacroeconomic and geopolitical environment, including the U.S. government providing meaningful support to us or our subsidiaries in a crisis.macroeconomic stress caused by the pandemic.
Rating agencies could make adjustments to our credit ratings at any time, and there can be no assurance thatas to when and whether downgrades will not occur.
A reduction in certain of our credit ratings could result in a wider credit spread and negatively affect our liquidity, access to credit markets, the related cost of funds, our businesses and certain trading revenues, particularly in those businesses where counterparty creditworthiness is critical. If the short-term credit ratings of our parent company, or bank or broker-dealer subsidiaries, were downgraded by one or more levels, we may suffer the potential loss of access to short-term funding sources such as repo financing, and/or incur increased cost of funds.funds and increased collateral requirements. Under the terms of certain OTC derivative contracts and other trading agreements, if our or our subsidiaries’ credit ratings are downgraded, the counterparties may require additional collateral or terminate these contracts or agreements.
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While certain potential impacts are contractual and quantifiable, the full consequences of a credit rating downgrade to a financial institution are inherently uncertain, as they depend upon numerous dynamic, complex and inter-related factors and assumptions, including whether any downgrade of a firm’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 the amount of additional collateral required and derivative liabilities that would be subject to unilateral termination at December 31, 2017 if the rating agencies had downgraded their long-term senior debt ratings for the Corporation or certain subsidiaries by each of two incremental notches, see Credit-related Contingent Features and Collateral in Note 2 – Derivatives to the Consolidated Financial Statements.
For more information about our credit ratings and their potential effects to our liquidity, see Liquidity Risk – Credit Ratings in the MD&A on page 52 and Note 2 – Derivatives to the Consolidated Financial Statements.
Bank of America Corporation is a holding company, and we depend upon ouris dependent on its subsidiaries for liquidity including the ability to pay dividends to shareholders and to fund payments on other obligations. Applicable laws and regulations, including capital and liquidity requirements, and actions taken pursuant to our resolution plan could restrict our ability to transfermay be restricted from transferring funds from subsidiaries to Bank of America Corporation or other subsidiaries.
Bank of America Corporation, as the parent company, is a separate and distinct legal entity from our bankingbank and nonbank subsidiaries. We evaluate and manage liquidity on a legal entity basis. Legal entity liquidity is an important consideration as there are legal, regulatory, contractual and other limitations on our ability to utilize liquidity from one legal entity to satisfy the liquidity requirements of another, including the parent company.company, which could result in adverse liquidity events. The parent company depends on dividends, distributions, loans advances and other payments from our bankingbank and nonbank subsidiaries to fund dividend payments on our common stock and preferred stock and to fund all payments on our other obligations, including debt obligations. Any inability of our subsidiaries to pay dividends or make payments to us may adversely affect our cash flow and financial condition.
Many of our subsidiaries, including our bank and broker-dealer subsidiaries, are subject to laws that restrict dividend payments, or authorize regulatory bodies to block or reduce the flow of funds from those subsidiaries to the parent company or other subsidiaries. Our bank and broker-dealer subsidiaries are subject to restrictions on their ability to lend or transact with affiliates and to minimum regulatory capital and liquidity requirements, as well as restrictions on their ability to use funds deposited with them in bank or brokerage accounts to fund their businesses. Intercompany arrangements we entered into in connection with our resolution planning submissions could restrict the amount of funding available to the Corporationparent company from our subsidiaries under certain adverse conditions.
Additional restrictions on related party transactions, increased capital and liquidity requirements and additional limitations on the use of funds on deposit in bank or brokerage accounts, as well as lower earnings, can reduce the amount of funds available to meet the obligations of the parent company and even require the parent company to provide additional funding to such subsidiaries. Also, regulatory action that requires additional liquidity at each of our subsidiaries could impede access to funds we need to pay our obligations or pay dividends. In addition, our right to participate in a distribution of assets upon a subsidiary’s liquidation or reorganization is subject to prior claims of the subsidiary’s creditors. For more information regarding our ability to pay dividends, see Capital Management in the MD&A on page 45 and Note 13 – Shareholders’ Equity to the Consolidated Financial Statements.
In the event of our resolution under the single point of entry resolution strategy, such resolution could materially adversely affect ourOur liquidity and financial condition, and the ability to pay dividends to shareholders and to pay obligations.obligations could be materially adversely affected in the event of a resolution.
Bank of America Corporation, our parent holding company, is required to periodically to submit a plan to the FDIC and Federal Reserve describing its resolution strategy under the U.S. Bankruptcy Code in the event of material financial distress or failure. In the current plan, Bank of America Corporation’s preferred resolution strategy is a single“single point of entryentry” strategy. This strategy provides that only the parent holding company files for resolution under the U.S. Bankruptcy Code and contemplates providing certain key operating subsidiaries with sufficient capital and liquidity to operate through severe stress and to enable such subsidiaries to continue operating or be wound
down in a solvent

7Bank of America 2017



manner following a bankruptcy of the parent holding company. Bank of America Corporation has entered into intercompany arrangements resulting in the contribution of most of its capital and liquidity to key subsidiaries. Pursuant to these arrangements, if Bank of America Corporation’s liquidity resources deteriorate so severely that resolution becomes imminent, Bank of America Corporation will no longer be able to draw liquidity from its key subsidiaries, and will be required to contribute its remaining financial assets to a wholly-owned holding company subsidiary, which could materially and adversely affect our liquidity and financial condition and the ability to return capital to shareholders, including through the payment of dividends and repurchase of the Corporation’s common stock, and meet our payment obligations.
In addition, ifIf the FDIC and Federal Reserve jointly determine that Bank of America Corporation’s resolution plan is not credible, they could impose more stringent capital, leverage or liquidity requirements or restrictions on our growth, activities or operations. Further, weWe could also be required to take certain actions that could impose operating costs and could potentially result in the divestiture or restructuring of certain businesses and subsidiaries.
UnderAdditionally, under the Financial Reform Act, when a G-SIB such as Bank of America Corporation is in default or danger of default, the FDIC may be appointed receiver in order to conduct an orderly liquidation of such institution. In the event of such appointment, the FDIC could, among other things, invoke the orderly liquidation authority, instead of the U.S. Bankruptcy Code, if the Secretary of the Treasury makes certain financial distress and systemic risk determinations. In 2013, the FDIC issued a notice describing its preferred “single point of entry” strategy for resolving a G-SIB. Under this approach, the FDIC could replace Bank of America Corporation with a bridge holding company, which could continue operations and result in an orderly resolution of the underlying bank, but whose equity would be held solely for the benefit of our creditors. The FDIC’s single“single point of entryentry” strategy may result in our security holders suffering greater losses than would have been the case under a bankruptcy proceeding or a different resolution strategy.
Credit
Economic or market disruptions and insufficient credit loss reserves or concentration of credit risk may result in an increase in thea higher provision for credit losses, which could have an adverse effect on our financial condition and results of operations.losses.
A number of our products expose us to credit risk, including loans, letters of credit, derivatives, debt securities, trading account assets and assets held-for-sale. TheDeterioration in the financial condition of our consumer and commercial borrowers, counterparties andor underlying collateral could adversely affect our financial condition and results of operations.
GlobalOur credit portfolios may be impacted by global and U.S. economicmacroeconomic and market conditions, may impact our credit portfolios. Economicevents and disruptions, including sustained weakness in GDP, consumer-spending declines, property value declines or asset-price corrections, increasing consumer and corporate leverage, increases in corporate bond spreads, rising or elevated unemployment levels, fluctuations in foreign exchange or interest rates, widespread health emergencies or pandemics, extreme weather events and the impacts of climate change and domestic and global efforts to transition to a low-carbon economy. Significant economic or market stresses and disruptions would likelytypically have a negative impact on the business environment and financial markets. Property value declines or asset-price corrections could increase the risk thatof borrowers or counterparties would defaultdefaulting or becomebecoming delinquent in their obligations to us. Increasesus, which could increase credit losses. Simultaneous drawdowns on lines of credit and/or an increase in delinquenciesa borrower’s leverage in a
Bank of America 10


weakening economic environment could result in deterioration in our credit portfolio, should borrowers be unable to fulfill competing financial obligations. Credit portfolio deterioration could also be magnified by lending to leveraged borrowers, elevated asset prices or declining property or collateral values unrelated to macroeconomic stress. Increased delinquency and default rates could adversely affect our consumer credit card, home equity and residential mortgage and purchased credit-impaired portfolios through increased charge-offs and provision for credit losses. Additionally,
Beginning in the first quarter of 2020, the pandemic resulted in changes to consumer and business behaviors and restrictions on economic activity, which have negatively impacted the global economy and could continue to negatively impact our consumer and commercial credit portfolios. Accordingly, we increased our allowance for credit losses as a deterioratingresult of the expected macroeconomic impact of COVID-19, which has adversely affected our results of operations. Although the economy, including GDP, and unemployment have improved since the first half of 2020, certain sectors remain significantly impacted (e.g., hospitality, entertainment and travel). As COVID-19 cases have surged in the fourth quarter of 2020 and early 2021, compared to earlier levels, and restrictions on economic environment could also adversely affectactivity have been reintroduced in certain geographies, there remains significant uncertainty on what the ultimate impact the pandemic will have on the economy and our commercial loan portfolios with weakened client and collateral positions.allowance for credit losses.
We estimate and establish an allowance for credit losses, which includes the allowance for loan and lease losses and the reserve for unfunded lending commitments, based on management's best estimate of lifetime expected credit losses inherent in our lending activities (including unfunded lending commitments), excluding those measured at fair value, through a charge to earnings.the Corporation's relevant financial assets. The process for determining the amount ofto determine the allowance requires us to make difficult and complex judgments, including loss forecasts onforecasting how borrowers will reactperform in changing and unprecedented economic conditions and predicting developments in public health and fiscal policy related to changing economic conditions.the pandemic. The ability of our borrowers or counterparties to repay their obligations will likely be impacted by
changes in future economic conditions, which in turn could impact the accuracy of our loss forecasts and allowance estimate.estimates. There is also the possibility that we have failed or will fail to accurately identify the appropriate economic indicators or that we will fail to accurately estimate their impacts.impacts to our borrowers, which similarly could impact the accuracy of our loss forecasts and allowance estimates.
We may suffer unexpected losses if the models and assumptions we use to establish reserves andor the judgments we make judgments in extending credit to our borrowers or counterparties, which are more sensitive due to the uncertainty regarding the magnitude and duration of the pandemic and related macroeconomic impact, prove inaccurate in predicting future events. In addition, changes to external factors such as natural disasters, can influencenegatively impact our recognition of credit losses in our portfolios and impactallowance for credit losses.
As of January 1, 2020, we implemented a new accounting standard to estimate our allowance for credit losses. Although we believe that ourthe allowance for credit losses wasis in compliance with applicablethe new accounting standards at December 31, 2017,standard, there is no guarantee that it will be sufficient to address credit losses, particularly if the economic conditions deteriorate.outlook deteriorates significantly. In such an event, we may increase the size of our allowance which would reduce our earnings. Additionally, to the extent that economic conditions worsen as a result of COVID-19 or otherwise, impacting our consumer and commercial borrowers, counterparties or underlying collateral, and credit losses are worse than expected, we may further increase our provision for credit losses, which
could have a further adverse effect on our results of operations and could negatively impact our financial condition.
Our concentrations of credit risk could adversely affect our credit losses, results of operations and financial condition.
In the ordinary course of our business, we also may be subject to a concentrationconcentrations of credit risk because of a common characteristic or common sensitivity to economic, financial, public health or business developments. For example, concentrations in credit risk may result in a particular industry, geographic location,geography, product, asset class, counterparty, borrowerindividual exposure or issuer.within any pool of exposures with a common risk characteristic. A deterioration in the financial condition or prospects of a particular industry, geographic location, product or asset class, or a failure or downgrade of, or default by, any particular entity or group of entities could negatively affect our businesses, and the processes by which we setit is possible our limits and monitor the level of our credit monitoring exposure to individual entities, industries and countries maycontrols will not function as we have anticipated.
While our activities expose us to many different industries and counterparties, we routinely execute a high volume of transactions with counterparties in the financial services industry, including broker-dealers, commercial banks, investment banks, insurers, mutual funds and hedge funds, central counterparties and other institutional clients. This has resultedclients, resulting in significant credit concentration with respect to this industry. Financial services institutions and other counterparties are inter-related because of trading, funding, clearing or other relationships. As a result, defaults by one or evenmore counterparties, or market uncertainty about the financial stability of one or more financial services institutions, or the financial services industry generally, could lead to market-wide liquidity disruptions, losses and defaults.
Many of these transactions expose us to credit risk and, in some cases, disputes and litigation in the event of default of a counterparty. In addition, our credit risk may be heightened by market risk when the collateral held by us cannot be liquidated or is liquidated at prices not sufficient to recover the full amount of the loan or derivatives exposure due to us.us, which may occur as a result of fraud or other events that impact the value of the collateral. Further, disputes with obligors as to the valuation of collateral could increase in times of significant market stress, volatility or illiquidity, and we could suffer losses during such periods if we are unable to realize the fair value of the collateral or manage declines in the value of collateral.
In the ordinary course of business, we also enter into transactions with sovereign nations, U.S. states and U.S. municipalities. Unfavorable economic or political conditions, disruptions to capital markets, currency fluctuations, changes in oil prices, social instability and changes in government policies could impact the operating budgets or credit ratings of these government entities and expose us to credit risk.
We also have a concentration of credit risk with respect to our consumer real estate loans, including home equity lines of credit (HELOCs), auto loans, consumer credit card and commercial real estate portfolios, which represent a significant percentage of our overall credit portfolio. Our home equity portfolio includes HELOCs not yet in their amortization period. HELOCs that have entered the amortization period are characterized by a higher percentage of early stage delinquencies and nonperforming status relative to the HELOC portfolio as a whole. Loans in our HELOC portfolio generally have an initial draw period of 10 years and 10 percent of these

Bank of America 20178


loans will enter the amortization period during 2018. In addition, our home equity portfolio contains a significant percentage of loans in second-lien or more junior-lien positions which have elevated risk characteristics. As a result, delinquencies and defaults may increase in future periods. For more information, see Consumer Portfolio Credit Risk Management in the MD&A on page 54. Furthermore, our commercial portfolios include exposures to certain industries, including the energy sector. For more information, see Commercial Portfolio Credit Risk Management in the MD&A on page 63.asset managers and funds, real estate, capital goods and finance companies. Economic weaknesses, adverse business conditions, market disruptions, rising interest or capitalization rates, the collapse of speculative bubbles, greater volatility in areas where we have concentrated credit risk or deterioration in real estate values or household incomes may cause us to experience a decrease in cash flow and higher credit losses in either our consumer or commercial portfolios or cause us to write-downwrite down the value of certain assets. Additionally, we could experience continued and long-term negative impact to our commercial credit exposure and an increase in credit losses within those industries that continue to be disproportionately impacted by COVID-19 or are permanently impacted by a change in consumer preferences resulting from COVID-19 (including hospitality, entertainment and travel).
Furthermore, we have concentrations of credit risk with respect to our consumer real estate, auto, consumer credit card and commercial real estate portfolios, which represent a significant percentage of our overall credit portfolio. Decreases in home price valuations or commercial real estate valuations in certain markets where we have large concentrations, as well as
11 Bank of America


more broadly within the U.S. or globally, could result in increased defaults, delinquencies or credit loss. In particular, the impact of climate change, such as rising average global temperatures and rising sea levels, and the increasing frequency and severity of extreme weather events and natural disasters such as droughts, floods, wildfires and hurricanes could negatively impact collateral, the valuations of home prices or commercial real estate or our customers’ ability and/or willingness to pay outstanding loans. This could also cause insurability risk and/or increased insurance costs to customers.
We also enter into transactions with sovereign nations, U.S. states and municipalities. Unfavorable economic or political conditions, disruptions to capital markets, currency fluctuations, changes in oil prices, social instability and changes in government or monetary policies could adversely impact the operating budgets or credit ratings of these government entities and expose us to credit risk.
Liquidity disruptions in the financial markets may result in our inability to sell, syndicate or realize the value of our positions, leading to increased concentrations, which could increase the credit and market risk associated with our positions, as well as increase our risk-weighted assets.RWA.
For more information about our credit risk and credit risk management policies and procedures, see Credit Risk Management in the MD&A on page 54, Note 1 – Summary of Significant Accounting Principles,Note 4 – Outstanding Loans and Leases and Note 5 – Allowance for Credit Losses to the Consolidated Financial Statements.
IfWe may be adversely affected if the U.S. housing market weakens or home prices decline, our consumer loan portfolios, credit quality, credit losses, representations and warranties exposures, and earnings may be adversely affected.decline.
While U.S. home prices continued to improve during 2017,generally remain stable or increase in 2020, supported by single-family housing demand and low interest rates. However, changes in business and household behaviors and restrictions on activity in response to the pandemic have had a negative impact on some property markets, particularly in high-density urban areas. We remain conscious of geographic markets where housing price growth has slowed or decreased, or is vulnerable to lasting shifts in demand due to the pandemic, as further declines in future periods may negatively impact the demand for many of our products. Additionally, our mortgage loan production volume is generally influenced by the rate of growth in residential mortgage debt outstanding and the size of the residential mortgage market.market, both of which may be adversely affected by rising interest rates. Conditions in the U.S. housing market in prior years have alsoduring the 2008 financial crisis resulted in both significant write-downs of asset values in several asset classes, notably mortgage-backed securities, and exposure to monolines. If the U.S. housing market were to weaken, the value of real estate could decline, which could result in increased credit losses and delinquent servicing expenses and negatively affect our exposure to representations and warranties exposures, and could have an adverse effect onadversely affect our financial condition and results of operations.
Our derivatives businesses may expose us to unexpected risks and potential losses.
We are party to a large number of derivatives transactions including credit derivatives. Our derivatives businessesthat may expose us to unexpected market, credit and operational risks that could cause us to suffer unexpected losses. Severe declines in asset values, unanticipated credit events or unforeseen circumstances that may cause previously uncorrelated factors to become correlated and vice versa, may create losses resulting from risks not appropriately taken into account or anticipated in the development, structuring or pricing of a derivative instrument. The terms of certain of ourCertain OTC derivative contracts and other trading agreements provide that upon the occurrence of certain specified events, such as a change in ourthe credit ratingsrating of the Corporation or thatone or more of certain of our subsidiaries,its affiliates, we may be required to provide additional collateral or take other remedies,remedial actions and could experience increased difficulty obtaining funding or hedging risks. In some cases our counterparties may have the right to terminate or otherwise diminish our rights under these contracts or agreements.
Many
We are also a member of various central counterparties (CCPs), in part due to regulatory requirements for mandatory clearing of derivative instrumentstransactions, which potentially increases our credit risk exposures to CCPs. In the event that one or more members of the CCP defaults on its obligations, we may be required to pay a portion of any losses incurred by the CCP as a result of that default. A CCP may modify, in its discretion, the margin we are individually negotiatedrequired to post, which could mean unexpected and non-standardized, which can make exiting, transferring or settling some positions difficult. Many derivatives require that we deliver
increased exposure to the counterpartyCCP. As a clearing member, we are exposed to the underlying security, loan or other obligation in order to receive payment. In a numberrisk of cases,non-performance by our clients for which we do not hold, andclear transactions, which may not be able to obtain, the underlying security, loan or other obligation.
In the event ofcovered by available collateral. Additionally, default by a downgrade of our credit ratings, certain derivativesignificant market participant may result in further risk and other counterparties may request we substitute BANA (which has generally had equal or higher credit ratings than the parent company) as counterparty for certain derivative contracts and other trading agreements. Our ability to substitute or make changes to these agreements may be subject to certain limitations, including counterparty willingness, operational considerations, regulatory limitations on naming BANA as the new counterparty and the type or amount of collateral required. It is possible that such limitations on our ability to substitute or make changes to these agreements, including naming BANA as the new counterparty, could adversely affect our results of operations.
For more information on our derivatives exposure, see Note 2 – Derivatives to the Consolidated Financial Statements.potential losses.
Geopolitical
We are subject to numerous political, economic, market, reputational, operational, legal, regulatory and other risks in the non-U.S. jurisdictions in which we operate.
We do business throughout the world, including in emerging markets. Economic or geopolitical stress in one or more countries could have a negative impact regionally or globally, resulting in, among other things, market volatility, reduced market value and economic output. Our businesses and revenues derived from non-U.S. jurisdictions are subject to risk of loss from currency fluctuations, financial, social or judicial instability, changes in government leadership, including as a result of electoral outcomes or otherwise, changes in governmental policies or policies of central banks, expropriation, nationalization and/or confiscation of assets, price controls, high inflation, natural disasters, the emergence of widespread health emergencies or pandemics, capital controls, currency redenomination risk, exchange controls, protectionist trade policies, and other restrictive actions, unfavorable political and diplomatic developments, oil price fluctuationfluctuations and changes in legislation. These risks are especially elevated in emerging markets. Additionally, protectionist trade policies and continued trade tensions between the U.S. and important trading partners, particularly China and the EU, including the risk that tariffs continue to rise and other restrictive actions on cross-border trade, investment, and transfer of information technology are taken that weigh heavily on regional trade volumes and domestic demand through falling business sentiment and lower consumer confidence, could adversely affect our businesses and revenues, as well as our customers and counterparties. Elevated tensions between the U.S. and China also raise the risk that current or future U.S. sanctions against individuals or export controls targeting Chinese firms could prompt retaliatory responses, potentially impacting our operations and revenue.
Additionally, the realization of any significant geopolitical events, negative market conditions and/or change in market dynamics as a result of the U.K.’s exit from the EU could adversely impact our businesses. The short- and long-term impact of the U.K.’s exit from the EU on European and global macroeconomic conditions, our business operations and results of operations remain unknown.
A number of non-U.S. jurisdictions in which we do business have been or may be negatively impacted by slowslowing growth rates or recessionary conditions, market volatility and/or political or civil unrest. The politicalongoing pandemic has had a severe negative impact on global GDP, and the global economic environment in Europe has improved but remains challenging even as output has begun to improve. Economic weakness may prove persistent in many countries and the current degree of politicalregions, including Europe, Japan, and economic uncertainty could increase. In the U.K., the ongoing negotiation of the terms of the exit of the U.K. from the EU continues to inject uncertainty.
numerous emerging markets. Potential risks of default on or devaluation of sovereign debt in some non-U.S. jurisdictions could expose us to substantial losses. As a result of the pandemic and fiscal policy responses
Bank of America 12


to it, government debt levels have increased significantly, raising the risk of volatility, significant valuation changes, or default in markets for sovereign debt. Risks in one nation can limit our opportunities for portfolio growth and negatively affect our operations in other nations, including our U.S. operations. Market and economic disruptions of all types may affect consumer confidence levels and spending, corporate investment and job creation, bankruptcy rates, levels of incurrence and default on consumer and corporate debt, economic growth rates and asset values, among other factors. Any such unfavorable conditions or developments could have an adverseadversely impact on our company.us.
We also invest or trade in the securities of corporations and governments located in non-U.S. jurisdictions, including emerging markets. Revenues from the trading of non-U.S. securities may be subject to negative fluctuations as a result of the above factors. Furthermore, the impact of these fluctuations could be magnified because non-U.S. trading markets, particularly in emerging markets, are generally smaller, less liquid and more volatile than U.S. trading markets.
Our non-U.S. businesses are also subject to extensive regulation by governments, securities exchanges and regulators, central banks and other regulatory bodies. In many countries, the laws and regulations applicable to the financial services and securities industries are uncertain and evolving, and it may be difficult for

9Bank of America 2017



us to determine the exact requirements of local laws in every market or manage our relationships with multiple regulators in various jurisdictions. Our potential inability to remain in compliance with local laws in a particular market and manage our relationships with regulators could have an adverse effect not only onresult in increased expenses and changes to our organizational structure and adversely affect our businesses and results of operations in that market, but also onas well as our reputation in general.
In connection with the U.K.’s exit from the EU, we are now subject to different laws, regulations and regulatory authorities and increased organizational and operational complexity. We may incur additional costs and/or experience negative tax consequences as a result of operating our principal EU banking and broker-dealer operations outside of the U.K., which could adversely impact our EU business, results of operations and operational model. Further, changes to the legal and regulatory framework under which our subsidiaries provide products and services in the U.K. and in the EU may result in additional compliance costs and have negative tax consequences or an adverse impact on our results of operations.
In addition to non-U.S. legislation, our international operations are also subject to U.S. legal requirements.requirements, which subjects us to operational and compliance costs and risks. For example, our international operations are subject to U.S. and non-U.S. laws on foreign corrupt practices, the Office of Foreign Assets Control, know-your-customer requirements and regulations relating to bribery and corruption, anti-money laundering, regulations. Emerging technologies, such as cryptocurrencies,and economic sanctions, which can vary by jurisdiction. The increasing speed and novel ways in which funds circulate could limit our abilitymake it more challenging to track the movement of funds.funds and heightens financial crimes risk. Our ability to comply with these laws is dependentlegal requirements depends on our ability to continually improve surveillance, detection and reporting capabilities and reduce variationanalytic capabilities.
In the U.S., debt ceiling and budget deficit concerns, which have increased the possibility of U.S. government defaults on its debt and/or downgrades to its credit ratings, and prolonged government shutdowns could negatively impact the global economy and banking system and adversely affect our financial condition, including our liquidity. Additionally, changes in control processesfiscal, monetary or regulatory policy, including as a result of the change in the U.S. presidential administration and oversight accountability.Congress, could increase our compliance costs and adversely affect our
business operations, organizational structure and results of operations. We are also subject to geopolitical risks, including economic sanctions, acts or threats of international or domestic terrorism, and actions taken by the U.S. or other governments in response thereto, state-sponsored cyber attacks or campaigns, civil unrest and/or military conflicts, which could adversely affect business and economic conditions abroad as well asand in the U.S.
For more information on our non-U.S. credit and trading portfolios, see Non-U.S. Portfolio in the MD&A on page 70.
The U.K. Referendum, and the potential exit of the U.K. from the EU, could adversely affect us.
We conduct business in Europe primarily through our U.K. subsidiaries. For the year ended December 31, 2017, our operations in Europe, Middle East and Africa, including the U.K., represented approximately nine percent of our total revenue, net of interest expense.
A referendum was held in the U.K. on June 23, 2016, which resulted in a majority vote in favor of exiting the EU. Negotiations between the EU and U.K. regarding this exit are ongoing and consist of three phases: a divorce agreement, a new trade deal and an arrangement for a transition period. There has been progress on the agreement of divorce bill, which is expected to be finalized in the next 12 months. A high degree of uncertainty remains on the timing and the details of a future trade agreement and transition phase. In this context, the ultimate impact of the U.K.’s exit remains unclear and episodes of economic and market volatility may occur. If uncertainty resulting from the U.K.’s exit negatively impacts economic conditions, financial markets and consumer confidence, our business, results of operations, financial position and/or operational model could be adversely affected. In addition, if the terms of the U.K.’s exit limit the ability of our U.K. entities to conduct business in the EU or otherwise result in a significant increase in economic barriers between the U.K. and the EU, it is possible these changes could impose additional costs on us, cause us to be subject to different laws, regulations and/or regulatory authorities, cause adverse tax consequences to us, and could adversely impact our business, financial condition and operational model.
Business Operations
A failure in or breach of our operational or security systems or infrastructure or business continuity plans, or those of third parties or the financial services industry, could disrupt our businesses,critical business operations and customer services, result in regulatory, market, privacy, liquidity and operational risk exposures, and adversely impact our results of operations liquidity and financial condition, as well asand cause legal or reputational harm.
The potential for operational risk exposure exists throughout our organization and as a result of our interactions with, and reliance on, third parties is not limited to our own internal operational functions.(including their downstream service providers) and the financial services industry infrastructure. Our operational and security systems infrastructure, and including our computer systems, emerging technologies, data management and internal processes, as well as those of third parties, are integral to our performance. We also rely on our employees
and third parties (including downstream service providers) in our day-to-day and ongoing operations, who may, as a result of human error, misconduct (including fraudulent activity), malfeasance or a failure or breach of systems or infrastructure cause disruptions to our organization and expose us to risk. We have taken measures to implement backup systemsoperational and other safeguards to supportregulatory risk.
Additionally, our operations, but our ability to conduct business may be adversely affected by any significant disruptions to us or to third parties with whom we interact or upon whom we rely. For example, technology project implementation challenges may cause business interruptions. In addition, our ability to implement backup systems and other safeguards with respect to third-party systems is more limited than with respect to our own systems. Our financial, accounting, data processing and transmission, storage, backup or other operating or security systems and infrastructure, or those of third parties with whom we interact or upon whom we rely may fail to operate properly or become disabled or damaged as a result of a number of factors including events that are wholly or partially beyond our or such third party’s control, which could adversely affect our ability to process transactions or provide services. ThereWe could bealso experience prolonged computer and network outages resulting in disruptions to our critical business operations and customer services, including abuse or failure of our electronic trading and algorithmic platforms. We may experience sudden increases in customer transaction volume;volume or electrical, telecommunications or other major physical infrastructure outages;outages, newly identified vulnerabilities in key hardware or software;software, failure of aging infrastructure and technology project implementation challenges, which could result in prolonged operational outages. Climate change is increasing the frequency and severity of natural disasters, such as earthquakes, wildfires, tornadoes, hurricanes and floods; disease pandemics; andfloods, which could result in increased exposure to operational risks, including outages. Additionally, events arising from local or larger scale political or social matters, including civil unrest and terrorist acts. Inacts, could result in operational disruptions and prolonged operational outages.
Additionally, the eventCorporation and the third parties on which it relies have been and will likely continue to be subject to additional operational risks while operating in a work-from-home posture (which places greater reliance on remote access tools and technology and employees’ personal systems), while executing business continuity plans due to COVID-19. We are increasingly dependent upon our information technology infrastructure to operate our businesses remotely due to our work-from-home posture and evolving customer preferences, including increased reliance on digital banking and other digital
13 Bank of America


services provided by our businesses. Effective management of our work-from-home posture depends on the security, reliability and adequacy of such systems. We are also at greater risk of business disruptions due to illness and unavailability.
Regardless of the measures we have taken to implement training, procedures, backup systems and other safeguards to support our operations and bolster our operational resilience, our ability to conduct business may be adversely affected by any significant disruptions to us or to third parties (including their downstream service providers) with whom we interact or upon whom we rely, including systemic cyber events that result in system outages and unavailability of part or all of the financial services industry infrastructure. Our ability to implement backup systems and other safeguards with respect to third-party systems and the financial services industry infrastructure is more limited than with respect to our own systems.
Furthermore, to the extent that backup systems are available and utilized, they may not process data as quickly as our primary systems and some data might not have been backed up. We continuouslyregularly update the systems on which we rely to support our operations and growth and to remain compliant with all applicable laws, rules and regulations globally. This updating entails significant costs and creates risks associated with implementing new systems and integrating them with existing ones, including business interruptions. OperationalA failure or breach of our operational or security systems or infrastructure or business continuity plans resulting in disruption to our critical business operations and customer services could expose us to regulatory, market, privacy and liquidity risk, exposures couldand adversely impact our results of operations liquidity and financial condition, as well as cause legal or reputational harm.
A cyber attack, information or security breach, or a technology failure of ours or of a third party could adversely affect our ability to conduct our business, manage our exposure to risk or expand our businesses, result in the disclosure or misuse of confidential or proprietary information, and/or fraudulent activity, and increase our costs to maintain and update our operational and security systems and infrastructure, and adversely impact our results of operations, liquidity and financial condition, as well as cause legal or reputational harm.infrastructure.
Our businesses arebusiness is highly dependent on the security, controls and efficacy of our infrastructure, computer and data management systems, as well as those of our customers, suppliers, counterparties and other third parties (including their downstream service providers) the financial services industry and financial data aggregators, with whom we interact, or on whom we rely.rely or who have access to our customers' personal or account information. Our businesses relybusiness relies on effective access management and the secure collection, processing, transmission, storage and retrieval of confidential, proprietary, personal and other information in our computer and data management systems and networks, and in the computer and data management systems and networks of third parties. In addition, to access our network, products and services, our employees, customers, suppliers, counterparties and other third parties mayincreasingly use personal mobile devices or computing devices that are outside of our network environmentand control environments and are subject to their own cybersecurity risks.
We, our employees and customers, regulators and other third parties have been subject to,(including contractors and vendors) are regularly the target of cyber attacks and are likely to continue to be the target of cyber attacks. These cyber attacks are pervasive, sophisticated, evolving, difficult to prevent and include computer viruses, malicious or destructive code (such as ransomware), social engineering (including phishing, attacks,vishing and smithing), denial of service or information or other security breachesbreach tactics that could result in the unauthorized release, gathering,
monitoring, misuse, loss or destruction or theft of confidential, proprietary and other information, including intellectual property, of ours, our employees, our customers or of third parties,parties. These cyber attacks could also result in damages to systems, financial risk or otherwise material disruption to our or our customers’ or other third parties’ network access or business
operations, both domestically and internationally.

BankOur cybersecurity risk and exposure remains heightened because of, among other things, the evolving nature and pervasiveness of America 201710


operations. As cyber threats, continueour prominent size and scale, our geographic footprint and international presence and our role in the financial services industry and the broader economy. Additionally, our risk and exposure to evolve,cyber attacks and security breaches is magnified due to our work-from-home posture which places greater reliance on remote access tools and technology, resulting in a larger number of access points to our networks that must be secured. This increased risk of unauthorized access to our networks results in greater amounts of information being available for access from employees’ personal devices over which we maydo not have the same controls as we do in a non-work-from-home posture. Additionally, our customers’ increasing reliance on digital banking and other digital services provided by our businesses in response to COVID-19, has resulted in more demand on our information technology infrastructure and security tools and processes.
The financial services industry is particularly at risk because of the proliferation of new and emerging technologies, including third-party financial data aggregators, and the use of the internet and telecommunications technologies to conduct financial transactions. Additionally, our use of automation, artificial intelligence (AI) and robotics, increased use of internet and mobile banking products, including mobile payment and other web- and cloud-based products and applications and plans to use or develop additional remote connectivity solutions increase our cybersecurity risks and exposure.
Additionally, we have exposure to cyber threats as a result of our continuous transmission of sensitive information to, and storage of such information by, third parties, including our vendors and regulators, the outsourcing of some of our business operations, and system and customer account updates and conversions. Cybersecurity risks have also significantly increased in recent years in part due to the increasingly sophisticated activities of organized crime groups, hackers, terrorist organizations, extremist parties, hostile foreign governments and state-sponsored actors, in some instances acting to promote political ends. We could also be required to expend significant additional resources to continue to modifythe target of disgruntled employees or enhance our protective measures or to investigatevendors, activists and remediate any information security vulnerabilities or incidents.other parties, including those involved in corporate espionage.
Cyber threats and the techniques used in cyber attacks change rapidly and frequently. Despite substantial efforts to protect the integrity and resilience of our systems and implement controls, processes, policies and other protective measures, we may not be able to anticipate allcyber attacks or information or security breaches nor may we be ableand implement effective preventive or defensive measures to implement guaranteed preventive measures againstaddress or mitigate such securityattacks or breaches. Cyber threats are rapidly evolving and we may not be able to anticipate or prevent all such attacks.
Cybersecurity risks for banking organizations have significantly increased in recent years in part because of the proliferation of new technologies, and the use of the Internet and telecommunications technologies to conduct financial transactions. For example, cybersecurity risks may increase in the future as we continue to increase our mobile-payment and other internet-based product offerings and expand our internal usage of web-based products and applications. In addition, cybersecurity risks have significantly increased in recent years in part due to the increased sophistication and activities of organized crime groups, hackers, terrorist organizations, hostile foreign governments, disgruntled employees or vendors, activists and other external parties, including those involved in corporate espionage. Even the most advanced internal control environment may beis vulnerable to compromise. Targeted social engineering attacks are becoming more sophisticated and are extremely difficult to prevent. The techniques used by bad actors change frequently, may not be recognized until launched and may not be recognized until well after a breach has occurred. Additionally,Internal access management failures could result in the existencecompromise or unauthorized exposure of cyberconfidential data.
Cyber attacks or security breaches could persist for an extended period of time before being detected. It could take considerable additional time for us to determine the scope, extent, amount, and type of information compromised, at which time the impact on the Corporation and measures to recover and restore to a business-as-usual state may be difficult to
Bank of America 14


assess. As cyber threats continue to evolve, we may be required to expend significant additional resources to modify or enhance our protective measures, investigate and remediate any information security vulnerabilities or incidents and develop our capabilities to respond and recover. As a result, increasing resources to develop and enhance our controls, processes and practices designed to protect our systems, workstations, intellectual property and proprietary information, software, data and networks from attack, damage or unauthorized access, remains a critical priority.
We also face indirect technology, cybersecurity and operational risks relating to the customers, clients and other third parties (including their downstream service providers) and the financial services industry, with accesswhom we do business, upon whom we rely to facilitate or enable our business activities or upon whom our customers rely. Such third parties also include financial counterparties, financial data aggregators, financial intermediaries, such as clearing agents, exchanges and clearing houses, vendors, regulators, providers of critical infrastructure, such as internet access and electrical power, and retailers for whom we process transactions. As a result of increasing consolidation, interdependence and complexity of financial entities and technology systems, a technology failure, cyber attack or other information or security breach that significantly degrades, deletes or compromises the systems or data of one or more financial entities or third parties (or their downstream service providers) could have a material impact on counterparties or other market participants, including us. Similarly, any failure, cyber attack or other information or security breach that significantly degrades, deletes or compromises our systems or data could adversely impact third parties, counterparties and the financial services industry infrastructure, which in turn could harm our reputation and damage our business. This consolidation, interconnectivity and complexity increases the risk of operational failure, on both individual and industry-wide bases, as disparate systems need to be integrated, often on an accelerated basis. Any technology failure, cyber attack or other information or security breach, termination or constraint of any third party (including their downstream service providers) the financial services industry infrastructure or financial data aggregators, could, among other things, adversely affect our ability to conduct day-to-day business activities, effect transactions, service our clients, manage our exposure to risk or expand our businesses, result in the misappropriation or destruction of the personal, proprietary or confidential information of our employees, customers, suppliers, counterparties and other third parties or result in fraudulent or unauthorized transactions. Further, any such event may not be disclosed to us in a timely manner.
Although to date we have not experienced any material losses or other material consequences relating to technology failure, cyber attacks or other information or security breaches, whether directed at us or third parties, there can be no assurance that our controls and procedures in place to monitor and mitigate the risks of cyber threats will be sufficient and that we will not suffer suchmaterial losses or other consequences in the future. Our risk and exposure to these matters remain heightened because of, among other things, the evolving nature of these threats, our prominent size and scale, and our role in the financial services industry and the broader economy, our plans to continue to implement our internet banking and mobile banking channel strategies and develop additional remote connectivity solutions to serve our customers when and how they want to be served, our continuous transmission of sensitive information to, and storage of such information by, third parties, including our vendors and regulators, our geographic footprint and international presence, the outsourcing of some of our business operations, threats of cyber terrorism, external extremist parties, including foreign state actors, in some circumstances as a means to promote political ends, and system and customer account updates and conversions. As a result, cybersecurity and the continued development and enhancement of our controls, processes and practices designed to protect our systems, computers, software, data and networks from attack, damage or unauthorized access remain a priority.
We also face indirect technology, cybersecurity and operational risks relating to the customers, clients and other third parties with whom we do business or upon whom we rely to facilitate or enable our business activities, including financial counterparties; financial intermediaries such as clearing agents, exchanges and clearing houses; vendors; regulators; providers of critical infrastructure such as internet access and electrical power; and retailers for whom we process transactions. As a result of increasing consolidation, interdependence and complexity of financial entities and technology systems, a technology failure,
cyber attack or other information or security breach that significantly degrades, deletes or compromises the systems or data of one or more financial entities could have a material impact on counterparties or other market participants, including us. This consolidation interconnectivity and complexity increases the risk of operational failure, on both individual and industry-wide bases, as disparate systems need to be integrated, often on an accelerated basis. Any third-party technology failure, cyber attack or other information or security breach, termination or constraint could, among other things, adversely affect our ability to effect transactions, service our clients, manage our exposure to risk or expand our businesses.
Cyber attacks or other information or security breaches, whether directed at us or third parties, may result in a material loss or have materialsignificant lost revenue, give rise to losses and claims brought by third parties, government penalties and other negative consequences. Furthermore, the public perception that a cyber attack on our systems has been successful, whether or not this perception is correct, may damage our reputation with customers and third parties with whom we do business. AAlthough we maintain cyber insurance, there can be no assurance that liabilities or losses
we may incur will be covered under such policies or that the amount of insurance will be adequate.
Also, successful penetration or circumvention of system security could cause usresult in negative consequences, including loss of customers and business opportunities, disruptionthe withdrawal of customer deposits, prolonged computer and network outages resulting in disruptions to our critical business operations and business,customer services, misappropriation or destruction of our intellectual property, proprietary information or confidential information and/or thatthe confidential, proprietary or personal information of certain parties, such as our employees, customers, suppliers, counterparties and other third parties, or damage to our customers’ and/or third parties’their computers or systems, andsystems. This could result in a violation of applicable privacy laws and other laws in the U.S. and abroad, litigation exposure, regulatory fines, penalties or intervention, loss of confidence in our security measures, reputational damage, reimbursement or other compensatory costs, additional compliance costs, and our internal controls or disclosure controls being rendered ineffective. The occurrence of any of these events could adversely impact our results of operations, liquidity and financial condition.
Our mortgage loan repurchase obligations or claims from third parties could result in additional losses.
We and our legacy companies have sold significant amounts of residential mortgage loans. In connection with these sales, we or certain of our subsidiaries or legacy companies made various representations and warranties, breaches of which may result in a requirement that we repurchase the mortgage loans, or otherwise make whole or provide other remedies to counterparties. At December 31, 2017, we had $17.6 billion of unresolved repurchase claims, net of duplicate claims and excluding claims where the statute of limitations has expired without litigation being commenced. We have also received notifications pertaining to loans for which we have not received a repurchase request from sponsors of third-party securitizations with whom we engaged in whole-loan transactions and for which we may owe indemnity obligations.
We have recorded a liability of $1.9 billion for obligations under representations and warranties exposures. We also have an estimated range of possible loss of up to $1 billion over our recorded liability. The recorded liability and estimated range of possible loss are based on currently available information, significant judgment and a number of assumptions that are subject to change. Future representations and warranties losses may occur in excess of our recorded liability and estimated range of possible loss and such losses could have an adverse effect on our liquidity, financial condition and results of operations.
Additionally, our recorded liability for representations and warranties exposures and the corresponding estimated range of possible loss do not consider certain losses related to servicing, including foreclosure and related costs, fraud, indemnity or claims (including for residential mortgage-backed securities ) related to securities law. Losses with respect to one or more of these matters could be material to our results of operations or liquidity.
For more information about our representations and warranties exposure, including the estimated range of possible loss, see Off-

11Bank of America 2017



Balance Sheet Arrangements and Contractual Obligations – Representations and Warranties in the MD&A on page 40, Consumer Portfolio Credit Risk Management in the MD&A on page 54 and Note 7 – Representations and Warranties Obligations and Corporate Guarantees to the Consolidated Financial Statements.
Failure to satisfy our obligations as servicer for residential mortgage securitizations, along withloans owned by other entities and other losses we could incur in our capacity as servicer, and foreclosure delays and/could adversely impact our reputation, servicing costs or investigations into our residential mortgage foreclosure practices could cause losses.results of operations.
We and our legacy companies have securitized a significant portion of the residentialservice mortgage loans that we originated or acquired. We service a portion of the loans we have securitized and also service loans on behalf of third-party securitization vehicles and other investors. If we commit a material breach of our obligations as servicer or master servicer, we may be subject to termination if the breach is not cured within a specified period of time following notice, which could cause us to lose servicing income. In addition, for loans principally held in private-label securitization trusts, we may have liability for any failure by us, as a servicer or master servicer, for any act or omission on our part that involves willful misfeasance, bad faith, gross negligence or reckless disregard of our duties. If any such breach werewas found to have occurred, it may harm our reputation, increase our servicing costs, result in litigation or regulatory action or adversely impact our results of operations. Additionally, with respect to foreclosures, we may incur costs or losses due to irregularities in the underlying documentation, or if the validity of a foreclosure action is challenged by a borrower or overturned by a court because of errors or deficiencies in the foreclosure process. We may also incur costs or losses relating to delays or alleged deficiencies in processing documents necessary to comply with state law governing foreclosure.
Changes in the structure of the GSEs and the relationship among the GSEs the government and the private markets, or the conversion of the current conservatorship of Fannie Mae or Freddie Mac into receivership, could result in significant changes to our business operations and may adversely impact our business.
During 2017,2020, we sold approximately $7.9$3.6 billion of loans to GSEs, primarily Freddie Mac (FHLMC). FHLMC and Fannie Mae and Freddie Mac. Each is(FNMA) are currently in a conservatorship with itstheir primary regulator, the Federal Housing Finance Agency (FHFA) acting as conservator. We cannot predict whetherIn September 2019, the conservatorships will end, any associated changesTreasury Department published a proposal to recapitalize FHLMC and FNMA and remove them from conservatorship as well as reduce their business structurerole in the marketplace. Consistent with this proposal, in January 2021, the Treasury Department further amended the agreement that could result or whethergoverns the conservatorships will end in receivership, privatization orconservatorship of FHLMC and FNMA to allow them to retain their earnings until they reach certain previously determined capital requirements, among other change in business structure. There are several proposed approachespolicy actions, potentially putting them on a long-term path to reform that, if enacted, could change the structure and the relationship among the GSEs, the government and the private markets, including the trading markets for agency conforming mortgage loans and markets for mortgage-related securities in whichemergence from conservatorship. However, weparticipate. We cannot predict the future prospects forof the enactment,GSEs, timing of the recapitalization or release from conservatorship, or content of legislative or rulemaking proposals regarding the future status of any GSEs.the GSEs in the housing market. Additionally, if the GSEs were to take a reduced role in
15 Bank of America


the marketplace, including by limiting the mortgage products they offer, we could be required to seek alternative funding sources, retain additional loans on our balance sheet, secure funding through the Federal Home Loan Bank system, or securitize the loans through Private Label Securitization. Accordingly, uncertainty regarding their future and the mortgage-backed securities they guarantee continues to exist including whether they will continue to exist in their current forms or continue to guarantee mortgagesfor the foreseeable future.
Any of these developments could adversely affect the value of our securities portfolios, capital levels, liquidity and provide funding for mortgage loans.results of operations.
Our risk management framework may not be effective in mitigating risk and reducing the potential for losses.
Our risk management framework is designed to minimize risk and loss to us. We seek to effectively and consistently identify, measure, monitor, report and control our exposure to the types of risk to which we are subject, including strategic, credit, market, liquidity, compliance, operational and reputational risks. While we employ a broad and diversified set of controls and risk monitoring and mitigation techniques, including modeling and forecasting, hedging strategies and techniques that seek to balance our ability to profit from trading positions with our exposure to
potential losses, those techniques are inherently limited because they cannot anticipate the existence or development of currently unanticipated or unknown risks and rely upon our ability to control and mitigate risks that result in losses is inherently limited by our ability to identify all risks, including emerging and unknown risks, anticipate the timing of risks, apply effective hedging strategies, make correct assumptions, manage and aggregate data. For instance, we use variousdata correctly and efficiently, and develop risk management models to assess and control risk, which are subject to inherent limitations.risk.
Our ability to manage risk is dependent on our ability to consistently execute all elements of our risk management framework depends onprogram and develop and maintain a soundculture of managing risk culture existingwell throughout the Corporation and that we manage risks associated with third parties (including their downstream service providers) and vendors.vendors, to enable effective risk management and ensure that risks are appropriately considered, evaluated and responded to in a timely manner. Uncertain economic conditions, heightened legislative and regulatory scrutiny of and change within the financial services industry, the pace of technological changes, accounting and market developments, the failure of employees to comply with policies, values and our risk framework and the overall complexity of our operations, among other developments, have resultedmay result in a heightened level of risk for us. We have experienced increased operational, reputational and compliance risk as a result of the need to rapidly implement multiple and varying pandemic relief programs, including consumer and commercial assistance programs and the PPP, coupled with the concurrent transition of the Corporation’s workforce to a work-from-home posture. Accordingly, we could suffer losses as a result of our failure to manage evolving risks or properly anticipate, and manage, control or mitigate risks.
For more information about our risk management policies and procedures, see Managing Risk in the MD&A on page 41.
Regulatory, Compliance and Legal
We are subject to comprehensive government legislation and regulations both domestically and internationally, which impact our operating costs, and could require us to make changes to our operations and result in an adverse impact on our results of operations. Additionally, these regulations and uncertainty surrounding the scope and requirements of the final rules implementing recently enacted and proposed legislation, as well as certain settlements, orders and consent orders we have entered into, have increased and could continueagreements with government authorities from time to increase our compliance and operational risks and costs.time.
We are subject to comprehensive regulation under federal and state laws in the U.S. and the laws of the various jurisdictions in which we operate.operate, including increasing and complex economic sanctions regimes. These laws and regulations significantly affect and have the potential to restrict the scope of our existing businesses, limit our ability to pursue certain business opportunities, including the products and
services we offer, reduce certain fees and rates or make our products and services more expensive for clients and customers.
In response to the financial crisis as well as other factors such as technological and market changes, the U.S. adopted the Financial Reform Act, which has resulted in significant rulemaking and proposed rulemaking by the U.S. Department of the Treasury, the Federal Reserve, the OCC, the CFPB, Financial Stability Oversight Council, the FDIC, the Department of Labor, the SEC and CFTC. Under the provisions of the Financial Reform Act known as the “Volcker Rule,” we are prohibited from proprietary trading and limited in our sponsorship of, and investment in, hedge funds, private equity funds and certain other covered private funds. Non-U.S. regulators, such as the U.K. financial regulators and the European Parliament and Commission, have adopted or proposed laws and regulations regarding financial institutions located in their jurisdictions, which have required and could require us to make significant modifications to our non-U.S. businesses, operations and legal entity structure in order to comply with these requirements.clients.
We continue to make adjustments to our business and operations, legal entity structure and capital and liquidity management policies, procedures and controls to comply with thesecurrently effective laws and regulations, as well as final rulemaking, guidance and interpretation by regulatory authorities, including the Department of Treasury, Federal Reserve, OCC, CFPB, Financial Stability Oversight Council, FDIC, Department of Labor, SEC and CFTC in the U.S. and foreign regulators and other government authorities. Further, we could become subject to future legislation and regulatory requirements beyond those currently proposed, adopted or contemplated. Accordingly,contemplated in the U.S. or abroad, including policies and rulemaking related to the Financial Reform Act, the pandemic and climate change. The cumulative effect of all of the legislation and regulations on our business, operations and profitability remains uncertain. This uncertainty necessitates that in our business planning we make certain assumptions with respect to the scope and requirements of theprospective and proposed rules. If these assumptions prove incorrect, we could be subject to increased regulatory and compliance risks and costs

Bank of America 201712


as well as potential reputational harm. In addition, U.S. and international regulatory initiatives may overlap, and non-U.S. regulations and initiatives may be inconsistent or may conflict with current or proposed U.S. regulations, which could lead to compliance risks and increased costs.
Our regulators’ prudential and supervisory authority gives them broad power and discretion to direct our actions, and they have assumed an active oversight, inspection and investigatory role across the financial services industry. RegulatoryHowever, regulatory focus is not limited to laws and regulations applicable to the financial services industry, specifically, but also extends to other significant laws and regulations that apply across industries and jurisdictions, including those related to data management and privacy, anti-money laundering, anti-corruption and economic sanctions.
We are also subject to laws, rules and regulations in the U.S. and abroad, including GDPR, CCPA and CPRA, regarding compliance with our privacy policies and the disclosure, collection, use, sharing and safeguarding of personal identifiable information of certain parties, such as our employees, customers, suppliers, counterparties and other third parties, the Foreign Corrupt Practices Actviolation of which could result in litigation, regulatory fines and enforcement actions. Additionally, we will likely be subject to new and evolving data privacy laws in the U.S. and international anti-money laundering regulations. abroad, which could result in additional costs of compliance, litigation, regulatory fines and enforcement actions. In particular, there is increased complexity and uncertainty, including potential suspension or prohibition, regarding the standards used by the Corporation for cross-border flows and transfers of personal data from the European Economic Area (EEA) to the U.S. and other jurisdictions outside of the EEA resulting from a decision of the Court of Justice of the EU and guidance from the European Data Protection Board. Additionally, the European Commission has proposed new standards of personal data transfer. If our personal data transfers are suspended or prohibited or we are required to implement new standards, this could result in operational disruptions to our businesses, additional costs, increased enforcement activity, new contract negotiations with third parties, and/or modification of our cross-border data management.
As part of their enforcement authority, our regulators and other government authorities have the authority to, among other things, assess significant civil or criminal monetary penalties fines or restitution and issue cease and desist or removal orders and
Bank of America 16


initiate injunctive actions. The amounts paid by us and other financial institutions to settle proceedings or investigations have, in some instances, been substantial and may continue to increase. In some cases, governmental authorities have required criminal pleas or other extraordinary terms as part of such settlements,resolutions, which could have significant consequences, for a financial institution, including reputational harm, loss of customers, restrictions on the ability to access capital markets, and the inability to operate certain businesses or offer certain products for a period of time.
The Corporation and the conduct of its employees and representatives are subject to regulatory scrutiny across jurisdictions. The complexity of the federal and state regulatory and enforcement regimes in the U.S., coupled with the global scope of our operations and the aggressiveness of the regulatory environment worldwide also means that a single event or practice or a series of related events or practices may give rise to a largesignificant number of overlapping investigations and regulatory proceedings, either by multiple federal and state agencies in the U.S. or by multiple regulators and other governmental entities in different jurisdictions. Additionally, actions by other members of the financial services industry related to business activities in which we participate may result in investigations by regulators or other government authorities. Responding to inquiries, investigations, lawsuits and proceedings regardless of the ultimate outcome of the matter, is time-consuming and expensive and can divert the attention of our senior management attention from our business. The outcome of such proceedings, which may last a number of years, may be difficult to predict or estimate until late in the proceedings, which may last a number of years.estimate.
We are currentlyand may become subject to the terms of settlements, orders and consent ordersagreements that we have entered into with government agenciesentities and may become subject to additional settlementsregulatory authorities, which impose, or orders in the future. Such settlements and consent orderscould impose, significant operational and compliance costs on us as they typically require us to enhance our procedures and controls, expand our risk and control functions within our lines of business, invest in technology and hire significant numbers of additional risk, control and compliance personnel. Moreover, if we fail to meet the requirements of the regulatory settlements, and orders or agreements to which we are subject, or, more generally, fail to maintain risk and control procedures and processes that meet the heightened standards established by our regulators and other government agencies,authorities, we could be required to enter into further settlements, orders or agreements and orders, pay additional fines, penalties or judgments, or accept material regulatory restrictions on our businesses.
While we believe that we have adopted appropriate risk management and compliance programs to identify, assess, monitor and report on applicable laws, policies and procedures, compliance risks will continue to exist, particularly as we adapt to new and evolving laws, rules and regulations. Additionally, changing U.S. fiscal, monetary and regulatory policies arising from changes to the U.S. presidential administration and Congress result in ongoing regulatory uncertainties. There is no guarantee that our risk management and compliance programs will be consistently executed to successfully manage compliance risk. We also rely upon third parties who may expose us to compliance and legal risk. Future legislative or regulatory actions, and any required changes to our business or operations, or those of third parties (including their downstream providers) upon whom we rely, resulting from such developments and actions could result in a significant loss of revenue, impose additional compliance and other costs or otherwise reduce our profitability, limit the products and services
that we offer or our ability to pursue certain business opportunities, require us to dispose of or curtail certain businesses, affect the value of assets that we hold, require us to increase our prices and therefore reduce demand for our
products, or otherwise adversely affect our businesses. In addition, legal and regulatory proceedings and other contingencies will arise from time to time that may result in fines, regulatory sanctions, penalties, equitable relief and changes to our business practices. As a result, we are and will continue to be subject to heightened compliance and operating costs that could adversely affect our results of operations.
We are subject to significant financial and reputational risks from potential liability arising from lawsuits and regulatory and government action.
We continue to face significant legal risks in our business, and thewith a high volume of claims and amount of damages, penalties and fines claimed in litigation, and regulatory and government proceedings against us and other financial institutions remain high. Greater than expected litigationinstitutions. The damages, penalties and investigation costs, substantial legal liability or significant regulatory or government action againstfines that litigants and regulators seek from us could have adverse effects on our financial condition and results of operations or cause significant reputational harm to us, which in turn could adversely impact our liquidity, financial condition and results of operations. We continue to experience a significant volume of litigation and other disputes, including claims for contractual indemnification with counterparties regarding relative rights and responsibilities. Consumers, clients and other counterpartiesfinancial institutions continue to be litigious. Amonghigh. This includes disputes with consumers, customers and other things, financialcounterparties.
Financial institutions, including us, continue to be the subject of claims alleging anti-competitive conduct with respect to various products and markets, including U.S. antitrust class actions claiming joint and several liability for treble damages. As disclosed in Note 12 — Commitments and Contingencies to the Consolidated Financial Statements, we also face contractual indemnification and loan-repurchase claims arising from alleged breaches of representations and warranties in the sale of residential mortgages by legacy companies, which may result in a requirement that we repurchase the mortgage loans, or otherwise make whole or provide other remedies to counterparties.
In addition, regulatory authorities have had a supervisory focus on enforcement, including in connection with alleged violations of law and customer harm. For example, U.S. regulators and government agencies have pursued claims against financial institutions under FIRREA, the Financial Institutions Reform, Recovery, and Enforcement Act, False Claims Act, Equal Credit Opportunity Act, Fair Housing Act and under the antitrust laws. Such claims may carry significant and, in certain cases, treble damages. There is also an increased focus on compliance with global laws, rules and regulations related to the collection, use, sharing and safeguarding of personally identifiable information and corporate data. Additionally, misconduct by employees, including unethical, fraudulent, improper or illegal conduct, or other unfair, deceptive, abusive or discriminatory business practices, can result in litigation and/or government investigations and enforcement actions, and cause significant reputational harm.
The ongoingglobal environment of extensive regulation, regulatory compliance burdens, litigation and regulatory and government enforcement, combined with uncertainty related to the continually evolving regulatory environment, have resulted inmay affect operational and compliance costs and risks, which may limit or cease our ability to continue providing certain products and services.
For more information on litigation risks, see Note 12 – Commitments and ContingenciesThis is magnified by the Corporation's implementation of government relief measures related to the Consolidated Financial Statements.pandemic. Lawsuits and regulatory actions may result in judgments, settlements, penalties and fines adverse to the Corporation. Litigation and investigation costs, substantial legal liability or significant regulatory or government action against us could have adverse effects on our business, financial condition, including liquidity, and results of operations, and/or cause significant reputational harm to us.
U.S. federal banking agencies may require us to increase our regulatory capital, total loss absorbingloss-absorbing capacity (TLAC), long-term debt or liquidity requirements, which could result in the need to issue additional qualifying securities or to take other actions, such as to sell company assets.requirements.
We are subject to U.S. regulatory capital and liquidity rules. These rules, among other things, establish minimum requirements to qualify as a “well-capitalized”well-capitalized institution. If any of
17 Bank of America


our subsidiary insured depository institutions fails to maintain its status as “well capitalized”well capitalized under the applicable regulatory capital rules, the Federal Reserve will require us to agree to bring the insured depository institution back to “well-capitalized”well-capitalized status. For the duration of such an agreement, the Federal Reserve may impose restrictions on our activities. If we were to fail to enter into or comply with such an agreement, or fail to comply with the terms of such agreement, the Federal Reserve may impose more severe restrictions on our activities, including requiring us to cease and desist activities permitted under the Bank Holding Company Act of 1956.

13Bank of America 2017



In the current regulatory environment, capitalCapital and liquidity requirements are frequently introduced and amended. It is possible that regulators may increase regulatory capital requirements including TLAC and long-term debt requirements, change how regulatory capital is calculated or increase liquidity requirements. Our risk-basedability to return capital to our shareholders depends in part on our ability to maintain regulatory capital levels above minimum requirements plus buffers. To the extent that increases occur in our SCB, G-SIB surcharge (G-SIB surcharge) may increase from current estimates, and we are also subject to aor countercyclical capital buffer, our returns of capital to shareholders could decrease.
As part of its CCAR, the Federal Reserve conducts stress testing on parts of our business using hypothetical economic scenarios prepared by the Federal Reserve. Those scenarios may affect our CCAR stress test results, which while currently set at zero, may be increased by regulators. impact the level of our SCB. Additionally, the Federal Reserve may impose limitations or prohibitions on taking capital actions, such as paying or increasing dividends or repurchasing common stock. For example, as a result of the economic uncertainty resulting from the pandemic, the Federal Reserve applied certain restrictions on our common stock dividends and repurchase program during the second half of 2020, and the first quarter of 2021, as disclosed in Item 1. Business Distributions on page 5 and MD&A Executive Summary Recent Developments Capital Management on page 25.
A significant component of regulatory capital ratios is calculating our risk-weighted assets, including operational risk,RWA and our leverage exposure, which may increase. Additionally, in April 2016, the U.S. banking regulators proposed Net Stable Funding Ratio requirements which target longer term liquidity risk and would apply to us and our subsidiary insured depository institutions. The Basel Committee on Banking Supervision has also revised several key methodologies for measuring risk-weighted assets,RWA that have not yet been implemented in the U.S., including a standardized approach for creditoperational risk, standardized approach for operationalrevised market risk requirements and constraints on the use of internal models, as well as a capital floor based on the revised standardized approaches. U.S. banking regulators may update the U.S. Basel 3 rules to incorporate the Basel Committee revisions.
As part of its annual CCAR review, the Federal Reserve conducts stress testing on parts of our business using hypothetical economic scenarios prepared by the Federal Reserve. Those scenarios may affect our CCAR stress test results, which may have an effect on our projected regulatory capital amounts in the annual CCAR submission, including the CCAR capital plan affecting our dividends and stock repurchases.
We are also subject to the Federal Reserve’s rule effective January 1, 2019 requiring U.S. G-SIBs to maintain minimum amounts of external total loss-absorbing capacity (TLAC) to improve the resolvability and resiliency of large, interconnected BHCs, with minimum requirements for TLAC and long-term debt based on our risk-weighted assets, supplementary leverage exposure and G-SIB surcharge. Increases to these measures may impact our minimum external TLAC and long-term debt requirements.
Changes to and compliance with the regulatory capital and liquidity requirements may impact our operations by requiring us to liquidate assets, increase borrowings, issue additional equity or other securities, cease or alter certain operations sell company assets, or hold highly liquid assets, which may adversely affect our results of operations. We may be prohibited from taking capital actions such as paying or increasing dividends, or repurchasing securities if the Federal Reserve objects to our CCAR capital plan. For more information, see Capital Management – Regulatory Capital in the MD&A on page 45.
Changes in accounting standards or assumptions in applying accounting policies could adversely affect us.
Our accounting policies and methods are fundamental to how we record and report our financial condition and results of operations. Some of these policies require use of estimates and assumptions that may affect the reported value of our assets or liabilities and results of operations and are critical because they require management to make difficult, subjective and complex judgments about matters that are inherently uncertain. If those assumptions, estimates or judgments were incorrectly made, we could be required to correct and restate prior-period financial statements. Accounting standard-setters and those who interpret the accounting standards, the SEC, banking regulators and our independent registered public accounting firm may also
amend or even reverse their previous interpretations or positions on how various standards should be applied. These changes may be difficult to predict and could impact how we prepare and report our financial statements. In some cases, we could be required to
apply a new or revised standard retrospectively, resulting in us revising prior-period financial statements.
In June 2016, the Financial Accounting Standards Board issued a new accounting standard that will require the earlier recognition of credit losses on loans and other financial instruments based on an expected loss model, replacing the incurred loss model that is currently in use. The new guidance is effective on January 1, 2020, with early adoption permitted on January 1, 2019. This new accounting standard is expected, on the date of adoption, to increase the allowance for credit losses with a resulting negative adjustment to retained earnings. For more information on some of our critical accounting policies and recent accounting changes, see Complex Accounting Estimates in the MD&A on page 84 and Note 1 – Summary of Significant Accounting Principles to the Consolidated Financial Statements.
We may be adversely affected by changes in U.S. and non-U.S. tax laws and regulations.
OnIn December 22, 2017, the President signed into law the Tax Cuts and Jobs Act (the Tax Act) was enacted, which made significant changes to federal income tax law including, among other things, reducing the statutory corporate income tax rate to 21 percent from 35 percent and changing the taxation of our non-U.S. business activities. We have accounted for the effects of the Tax Act using reasonable estimates based on currently available information and our interpretations thereof. This accounting may change due to, among other things, changes in interpretations we have made and the issuance of new tax or accounting guidance.
In addition, we have U.K. net deferred tax assets (DTA) which consist primarily of net operating losses that are expected to be realized by certain subsidiaries over an extended number of years. Adverse developments with respect to tax laws or to other material factors, such as prolonged worsening of Europe’s capital markets or changes in the ability of our U.K. subsidiaries to conduct business in the EU, could lead our management to reassess and/or change its current conclusion that no valuation allowance is necessary with respect to our U.K. net deferred tax assets.DTA.
It is possible that governmental authorities in the U.S. and/or other countries could further amend or repeal tax laws in a way that would adversely affect us.us, including the possibility that aspects of the Tax Act could be amended in the future. Any future change in tax laws and regulations or interpretations of current or future tax laws and regulations could adversely affect our results of operations.
Reputation
Damage to our reputation could harm our businesses, including our competitive position and business prospects.
Our ability to attract and retain customers, clients, investors and employees is impacted by our reputation. Harm to our reputation can arise from various sources, including officer, director or employee fraud, misconduct and unethical behavior, security breaches, unethical behavior, litigation or regulatory outcomes, compensation practices, lending practices, the suitability or reasonableness of recommending particular trading or investment strategies, including the reliability of our research and models, prohibiting clients from engaging in certain transactions and employee sales practices,practices. Additionally, our reputation may be harmed by failing to deliver products, subpar standards of service and quality expected by our customers, clients and the community, compliance failures, the inability to manage technology change or maintain effective data management, cyber incidents, internal and external fraud, inadequacy of responsiveness to internal controls, unintended disclosure of personal, proprietary or confidential information, perceptionconflicts of our environmental, socialinterest and governance practices and disclosures,breach of fiduciary obligations, the handling of health emergencies or pandemics, and the activities of our clients, customers, counterparties and counterparties,third parties, including vendors. For example, our reputation may be harmed in connection with our implementation of government programs to provide relief to address the economic impact of the pandemic. Our reputation may also be negatively impacted by our ESG practices and disclosures, our businesses and our customers, including practices and disclosures related to climate change. Actions by the financial services industry generally or by certain members or individuals in the industry also can adversely affect our reputation. In addition, adverse publicity or negative information posted on social media websites,by employees, the media or otherwise, whether or not factually
Bank of America 18


correct, may adversely impact our business prospects or financial results.
We are subject to complex and evolving laws and regulations regarding privacy, know-your-customer requirements, data protection, including the EU General Data Protection Regulation

Bank of America 201714


(GDPR),GDPR, CCPA and CPRA, cross-border data movement and other matters. Principles concerning the appropriate scope of consumer and commercial privacy vary considerably in different jurisdictions, and regulatory and public expectations regarding the definition and scope of consumer and commercial privacy may remain fluid. It is possible that these laws may be interpreted and applied by various jurisdictions in a manner inconsistent with our current or future practices, or that is inconsistent with one another. If personal, confidential or proprietary information of customers or clients in our possession, or in the possession of third parties (including their downstream service providers) or financial data aggregators, is mishandled, misused or misused,mismanaged, or if we do not timely or adequately address such information, we may face regulatory, reputational and operational risks which could have an adverse effect onadversely affect our financial condition and results of operations.
We could suffer reputational harm if we fail to properly identify and manage potential conflicts of interest. Management of potential conflicts of interestsinterest has become increasingly complex as we expand our business activities through more numerous transactions, obligations and interests with and among our clients.
The failure to adequately address, or the perceived failure to adequately address, conflicts of interest could affect the willingness of clients to deal with us,use our products and services, or give rise to litigation or enforcement actions, which could adversely affect our businesses.business.
Our actual or perceived failure to address these and other issues, such as operational risks, gives rise to reputational risk that could harm us and our business prospects. Failure to appropriately address any of these issues could also give rise to additional regulatory restrictions, legal risks and reputational harm, which could, among other consequences, increase the size and number of litigation claims and damages asserted or subject us to enforcement actions, fines and penalties, and cause us to incur related costs and expenses.
Other
Reforms to and replacement of IBORs and certain other rates or indices may adversely affect our reputation, business, financial condition and results of operations.
There is a major transition in progress in global financial markets with respect to the replacement of IBORs, including the London Interbank Offered Rate (LIBOR), and certain other rates or indices that serve as “benchmarks.” Such benchmarks are used extensively across global financial markets and in our business. In particular, LIBOR is used in many of our products and contracts, including derivatives, consumer and commercial loans, mortgages, floating-rate notes and other adjustable-rate products and financial instruments. The aggregate notional amount of these products and contracts is material to our business, and there are significant risks and challenges associated with the transition that may result in significant uncertainty, or have other consequences that cannot be fully anticipated, which expose us to various financial, operational, supervisory, conduct and legal risks.
Although certain ARRs have been proposed to replace LIBOR and other IBORs, market and client adoption of ARRs may vary across or within categories of contracts, products and services, resulting in market fragmentation, decreased trading volumes and liquidity, increased complexity and modeling and
operational risks. ARRs have compositions and characteristics that differ significantly from the benchmarks they may replace, in some cases have limited history, and may demonstrate less predictable performance over time than the benchmarks they replace. Additionally, most ARRs are calculated on a compounded or weighted-average basis, involve complex billing and reconciliation and, unlike IBORs, do not reflect bank credit risk and therefore may require a spread adjustment. The market transition from IBORs to ARRs is complex and there are important differences between the fallbacks, triggers and calculation methodologies being implemented in cash and derivatives markets (including within cash markets). Any mismatch between the adoption of ARRs in loans, securities and derivatives markets may impact hedging or other financial arrangements we have implemented, and as a result we may experience unanticipated market exposures. There can be no assurance that ARRs will be comparable or adequate alternatives to IBORs or perform in the same way, that existing assets and liabilities based on or linked to IBORs will transition successfully to ARRs, of the timing of adoption and degree of integration and acceptance of ARRs in the financial markets, or of the future availability or representativeness of such ARRs.
The discontinuation of IBORs, including LIBOR, requires us to transition a significant number of IBOR-based products and contracts, including related hedging arrangements (IBOR Products). Although, 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, the transitioning of certain contracts, products and clients will be more complex. While some of these outstanding IBOR Products include fallback provisions to ARRs, some of these products and contracts do not include fallback provisions or adequate fallback mechanisms and require remediation to modify their terms. Additionally, some outstanding IBOR Products are particularly challenging to modify due to the requirement that all impacted parties consent to such modification. Legislation has been adopted in the EU and proposed in the U.S. and the U.K. to address such challenges in IBOR Products, including the use of a statutory replacement or “synthetic” rate to replace the existing benchmark rate in certain of our IBOR Products. Litigation, disputes or other action may occur as a result of the interpretation or application of legislation, in particular, if there is an overlap between legislation introduced in different jurisdictions. There is no guarantee that the legislative proposals will become law and no assurance that we and other market participants will be able to successfully modify all outstanding IBOR Products or be adequately prepared for a discontinuation of an IBOR at the time such IBOR may cease to be published or otherwise discontinued. Also, there can be no assurance that existing or new provisions for successor rates in our IBOR Products will include adequate methodologies for adjustments or that the characteristics of the successor rates will be similar to or produce the economic equivalent of the benchmarks they seek to replace. These changes may adversely affect the yield on loans or securities held by us, amounts paid on securities we have issued, amounts received and paid on derivatives we have entered into, the value of such loans, securities or derivative instruments, the trading market for such products and contracts, and our ability to effectively use hedging instruments to manage risk. Certain impacted clients, counterparties and other market participants may refuse, delay, or lack operational readiness to transition to ARRs, resulting in the risk that some contracts and products may not transition to an ARR before discontinuation of the relevant IBOR, exposing us to financial, operational, supervisory, conduct and legal risks.
19 Bank of America


Our products and contracts that reference IBORs, in particular LIBOR, may contain language that determines when a successor rate including the ARR and/or the applicable spread adjustment to the designated rate (including IBORs) would be selected or determined. If a trigger is satisfied, our products and contracts may give the calculation agent (which may be us) discretion over the successor rate to be selected. We may face a risk of litigation, disputes or other actions from clients, counterparties, customers, investors or others regarding the interpretation or enforcement of IBOR-based contract provisions or if we fail to appropriately communicate the effect that the transition to ARRs will have on existing and future products.
The Corporation has launched, and expects to continue to develop, launch and support, ARR-based products and services. The transition to ARR-based products is complex and involves client and financial contract changes, internal and external communication, technology and operations modifications, industry and regulatory engagement, migration of existing clients, execution of business strategy and governance. New financial products linked to ARRs may be less liquid, result in mispricing and additional legal, financial, tax, operational, market, compliance, reputational, competitive or other risks to us, our clients and other market participants. There is no guarantee that liquidity in ARR-based products will develop, and it is possible that ARR-based products will perform differently to IBOR Products during times of economic stress, adverse or volatile market conditions and across the credit and economic cycle, which may impact the value, return on and profitability of our ARR-based assets.
Failure to meet industry-wide IBOR transition milestones and to cease issuance of IBOR Products by relevant cessation dates may, subject to certain regulatory exceptions, result in supervisory enforcement by applicable regulators, increase our cost of, and access to, capital and other consequences. In addition, IBOR Products held by us may become less liquid as the transition process develops, and other unforeseen consequences may arise if such products are held beyond relevant cessation dates.
Changes or uncertainty resulting from the market transition from IBORs to ARRs could adversely affect the return on and pricing, liquidity and value of outstanding IBOR Products, cause significant market dislocations and disruptions, potentially increase the cost of and access to capital, increase the risk of litigation or other disputes, including in connection with the interpretation and enforceability of, or our historical marketing practices or disclosures with respect to outstanding IBOR products with counterparties, and/or increase expenses related to the transition to ARRs, among other adverse consequences.
The market transition may also alter our risk profile and risk management strategies, including derivatives and hedging strategies, modeling and analytics, valuation tools, product design and systems, controls, procedures and operational infrastructure. This may prove challenging given the limited history of many of the proposed ARRs and may increase the costs and risks related to potential regulatory compliance, requirements or inquiries. Among other risks, various products and contracts may transition to ARRs at different times or in different manners, with the result that we may face significant unexpected interest rate, pricing or other exposures across business or product lines. Reforms to and uncertainty regarding market transition and other factors may adversely affect our business, including the ability to serve customers and maintain market share, financial condition or results of operations and could result in reputational harm to the Corporation.
We face significant and increasing competition in the financial services industry.
We operate in a highly competitive environment and will continue to experience intense competition from local and global financial institutions as well as new entrants, in both domestic and foreign markets.markets, in which we compete on the basis of a number of factors, including customer service, quality and range of products and services offered, technology, price, fees, reputation, interest rates on loans and deposits, lending limits and customer convenience. Additionally, the changing regulatory environment may create competitive disadvantages for certain financial institutionsus given geography-driven capital and liquidity requirements. For example, U.S. regulators have in certain instances adopted stricter capital and liquidity requirements than those applicable to non-U.S. institutions. To the extent we expand into new business areas and new geographic regions,Additionally, we may face competitors with more experience and more established relationships with clients, regulators and industry participants in the relevant market, which could adversely affect our ability to compete.
In addition, technologicalemerging technologies and advances and the growth of e-commerce have lowered geographic and monetary barriers of other financial institutions, made it easier for non-depository institutions to offer products and services that traditionally were banking products and forallowed non-traditional financial institutionsservice providers and technology companies to compete with technologytraditional financial service companies in providing electronic and internet-based financial solutions and services, including electronic securities trading with low or no fees and commissions, marketplace lending, financial data aggregation and payment processing.processing, including real-time payment platforms. Further, clients may choose to conduct business with other market participants who engage in business or offer products in areas we deem speculative or risky, such as cryptocurrencies. Increased competition may negatively affect our earnings by creating pressure to lower prices, fees, commissions or credit standards on our products and services requiring additional investment to improve the quality and delivery of our technology and/or reducing our market share, or affecting the willingness of our clients to do business with us.
Our inability to adapt our products and services to evolving industry standards and consumer preferences could harm our business.
Our business model is based on a diversified mix of businesses that provide a broad range of financial products and services, delivered through multiple distribution channels. Our success depends on our, and our third-party vendors', ability to adapt ourand develop products, services and servicestechnology to rapidly evolving industry standards.standards and consumer preferences. In particular, the emergence of the pandemic has resulted in increased reliance on digital banking and other digital services provided by the Corporation’s businesses. There is increasing pressure by competitors to provide products and services aton more attractive terms, including higher interest rates on deposits, and offer lower prices and thiscost investment strategies, which may impact our ability to grow revenue and/or effectively compete, in part, due tocompete. Additionally, legislative and regulatory developments thatmay affect the competitive landscape. Additionally,Further, the competitive landscape may be impacted by the growth of non-depository institutions that offer products that were traditionallytraditional banking products as well as new innovativeat higher rates or with low or no fees, or otherwise offer alternative products. This can reduce our net interest margin and revenues from our fee-based products and services. services, either from a decrease in the volume of transactions or through a compression of spreads.
In addition, the widespread adoption and rapid evolution of new technologies, including analytic capabilities, self-service digital trading platforms, internet services, distributed ledgers, such as the blockchain system, cryptocurrencies and payment systems, could require substantial expenditures to modify or adapt our existing products and services as we grow and develop our internet bankingonline and mobile banking channel strategies in
Bank of America 20


addition to remote connectivity solutions. We mightmay not be as timely or successful in developing or introducing new products and services, integrating new products or services into our existing offerings, responding or adapting to changes in consumer behavior, preferences, spending, investing and/or saving habits, achieving market acceptance of our products and services, reducing costs in response to pressures to deliver products and services at lower prices or sufficiently developing and maintaining loyal customers. The Corporation’s or its third-party vendors' inability to adapt products and services to evolving industry standards and consumer preferences could result in service disruptions and harm our business and adversely affect our results of operations and reputation.
We could suffer operational, reputational and financial harm if our models and strategies fail to properly anticipate and manage risk.
We use proprietary models and strategies extensively to forecast losses, project revenue, measure and assess capital requirements for credit, country, market, operational and strategic risks and assess and control our operations and financial condition. Model risk management is a dedicated and independent risk function that defines model risk governance, policy and guidelines for the Corporation based on laws, rules and regulations, as well as internal requirements. Under the Corporation's Enterprise Model Risk Policy, model risk management is required to perform model oversight, including independent validation before initial use, ongoing monitoring through outcomes analysis and benchmarking, and periodic revalidation. Models are subject to inherent limitations due to the use of historical trends and simplifying assumptions, uncertainty regarding economic and financial outcomes, and emerging risks from the use of applications that rely on AI.
Our models and strategies may not be sufficiently predictive of future results due to limited historical patterns, extreme or unanticipated market movements or customer behavior and liquidity, especially during severe market downturns or stress events, which could limit their effectiveness. The models that we use to assess and control our market risk exposures also reflect assumptions about the degree of correlation among prices of various asset classes or other market indicators, which may not be representative of the next downturn and would magnify the limitations inherent in using historical data to manage risk. Our models may not be effective if we fail to properly oversee them and detect their flaws during our review and monitoring processes, they contain erroneous data, assumptions, valuations, formulas or algorithms or our applications running the models do not perform as expected. Regardless of the steps we take to ensure effective controls, governance, monitoring and testing, and implement new
technology and automated processes, we could suffer operational, reputational and financial harm if models and strategies fail to properly anticipate and manage current and evolving risks.
Failure to properly manage and aggregate data may result in our inability to manage risk and business needs, errors in our day-to-day operations, critical reporting and strategic decision-making and inaccurate reporting.
We rely on our ability to manage, surveil, aggregate, interpret and use data in an accurate, timely and complete manner for effective risk reporting and management. Our policies, programs, processes and practices govern how data is surveilled, managed, aggregated, interpreted and used. While we continuously update our policies, programs, processes and practices and implement emerging technologies, such as
automation, AI and robotics, our data management and aggregation processes are subject to failure, including human error, system failure or failed controls. Failure to surveil, maintain and manage data and information effectively and to aggregate data and information in an accurate, timely and complete manner may impact its quality and reliability and limit our ability to manage current and emerging risk, to produce accurate financial, regulatory and operational reporting, as well as to manage changing business needs, strategic decision-making and day-to-day operations. The failure to establish and maintain effective, efficient and controlled data management could adversely impact our ability to develop our products and relationships with our customers and damage our reputation.
Our operations, businesses and customers could be materially adversely affected by the impacts related to climate change.
There is an increasing concern over the risks of climate change and related environmental sustainability matters. The physical risks of climate change include rising average global temperatures, rising sea levels and an increase in the frequency and severity of extreme weather events and natural disasters, including floods, wildfires, hurricanes and tornados. Such disasters could disrupt our operations or the operations of customers or third parties on which we rely. Such disasters could result in market volatility or negatively impact our customers’ ability to pay outstanding loans, damage collateral or result in the deterioration of the value of collateral or insurance shortfalls. Additionally, climate change concerns could result in transition risk. Changes in consumer preferences and additional legislation and regulatory requirements, including those associated with the transition to a low-carbon economy, could increase expenses or otherwise adversely impact the Corporation, its businesses or its customers. We could also experience increased expenses resulting from strategic planning, litigation and technology and market changes, and reputational harm as a result of negative public sentiment, regulatory scrutiny and reduced investor and stakeholder confidence due to our response to climate change and our climate change strategy.
Our ability to attract and retain qualified employees is critical to theour success, of our business and failure to do so could hurt our business prospects and competitive position.
Our performance is heavily dependent on the talents and efforts of highly skilled individuals. Competition for qualified personnel within the financial services industry and from businesses outside the financial services industry is intense.
Our competitors include non-U.S. based institutions and institutions subject to different compensation and hiring regulations than those imposed on U.S. institutions and financial institutions.
In order to attract and retain qualified personnel, we must provide market-level compensation. As a large financial and banking institution, we are and may bebecome subject to additional limitations on compensation practices, (whichwhich may or may not affect our competitors)competitors, by the Federal Reserve, the OCC, the FDIC orand other regulators around the world. Recent EU and U.K. rules limit and subject to clawback certain forms of variable
compensation for senior employees. Current and potential future limitations on executive compensation imposed by legislation or regulation could adversely affect our ability to attract and maintain qualified employees. Furthermore, a substantial portion of our annual incentive compensation paid to our senior employees has in recent years taken the formconsists of long-term equity awards. Therefore,equity-based awards, the ultimate value of this compensation dependswhich is based on the price of our common stock when the awards vest. If we are unable to continue to attract and retain qualified individuals, ourOur business prospects and competitive position could be adversely affected.affected if we cannot attract and retain qualified individuals.
We could suffer losses if our models and strategies fail to properly anticipate and manage risk.
We use proprietary models and strategies extensively to measure and assess capital requirements for credit, country, market, operational and strategic risks and to assess and control

1521Bank of America 2017




our operations. These models require oversight and periodic re-validation and are subject to inherent limitations due to the use of historical trends and simplifying assumptions, and uncertainty regarding economic and financial outcomes. Our models may not be sufficiently predictive of future results due to limited historical patterns, extreme or unanticipated market movements and illiquidity, especially during severe market downturns or stress events. The models that we use to assess and control our market risk exposures also reflect assumptions about the degree of correlation among prices of various asset classes or other market indicators. Market conditions in recent years have involved unprecedented dislocations and highlight the limitations inherent in using historical data to manage risk. We could suffer losses if our models and strategies fail to properly anticipate and manage risks.
Failure to properly manage and aggregate data may result in inaccurate financial, regulatory and operational reporting.
We rely on our ability to manage data and our ability to aggregate data in an accurate and timely manner for effective risk reporting and management which may be limited by the effectiveness of our policies, programs, processes and practices that govern how data is acquired, validated, stored, protected and processed. While we continuously update our policies, programs, processes and practices, many of our data management and aggregation processes are manual and subject to human error or system failure. Failure to manage data effectively and to aggregate data in an accurate and timely manner may limit our ability to manage current and emerging risk, to produce accurate financial, regulatory and operational reporting as well as to manage changing business needs.
Reforms to and uncertainty regarding LIBOR and certain other indices may adversely affect our business.
The U.K. FCA announced in July 2017 that it will no longer persuade or require banks to submit rates for LIBOR after 2021. This announcement, in conjunction with financial benchmark reforms more generally and changes in the interbank lending markets have resulted in uncertainty about the future of LIBOR and certain other rates or indices which are used as interest rate “benchmarks.” These actions and uncertainties may have the effect of triggering future changes in the rules or methodologies used to calculate benchmarks or lead to the discontinuance or unavailability of benchmarks. ICE Benchmark Administration is the administrator of LIBOR and maintains a reference panel of contributor banks, which includes Bank of America, N.A., London branch for certain LIBOR rates. Uncertainty as to the nature and effect of such reforms and actions, and the potential or actual discontinuance of benchmark quotes, may adversely affect the value of, return on and trading market for our financial assets and liabilities that are based on or are linked to benchmarks, including any LIBOR-based securities, loans and derivatives, or our financial condition or results of operations. Furthermore, there can be no assurances that we and other market participants will be adequately prepared for an actual discontinuation of benchmarks, including LIBOR, that may have an unpredictable impact on contractual mechanics (including, but not limited to, interest rates to be paid to or by us) and cause significant disruption to financial markets that are relevant to our business segments, particularly Global Banking and Global Markets, among other adverse consequences, which may also result in adversely affecting our financial condition or results of operations.

Item 1B. Unresolved Staff Comments
None

Item 2. Properties
As of December 31, 2017, our2020, certain principal offices and other materially important properties consisted of the following:
Facility NameLocationGeneral Character of the Physical PropertyPrimary Business SegmentProperty Status
Property Square Feet (1)
Bank of America Corporate CenterCharlotte, NC60 Story BuildingPrincipal Executive OfficesOwned1,212,177
Bank of America Tower at One Bryant ParkNew York, NY55 Story Building
GWIM, Global Banking and
 Global Markets
Leased (2)
1,836,575
 Bank of America Merrill Lynch Financial CentreLondon, UK4 Building Campus
Global Banking and Global Markets
Leased562,595565,362
Cheung Kong CenterHong Kong62 Story Building
Global Banking and Global Markets
Leased149,790
(1)
(1)For leased properties, property square feet represents the square footage occupied by the Corporation.
(2)The Corporation has a 49.9 percent joint venture interest in this property.
For leased properties, property square feet represents the square footage occupied by the Corporation.
(2)
The Corporation has a 49.9 percent joint venture interest in this property.
We own or lease approximately 79.174.6 million square feet in over 20,000 facilityfacilities and ATM locations globally, including approximately 74.169.2 million square feet in the U.S. (all 50 states and the District of Columbia, the U.S. Virgin Islands, Puerto Rico and Guam) and approximately 5.05.4 million square feet in more thanapproximately 35 countries.
We believe our owned and leased properties are adequate for our business needs and are well maintained. We continue to evaluate our owned and leased real estate and may determine from time to time that certain of our premises and facilities, or ownership structures, are no longer necessary for our
operations. In connection therewith, we are evaluatingregularly evaluate the sale or sale/leaseback of certain properties and we may incur costs in connection with any such transactions.


Item 3. Legal Proceedings
See Litigation and Regulatory Matters in Note 12 – Commitments and Contingencies to the Consolidated Financial Statements, which is incorporated herein by reference.
Item 4. Mine Safety Disclosures
None

Bank of America 201716


Part II
Bank of America Corporation and Subsidiaries
Item 5. Market for Registrant’s Common Equity, Related Stockholder Matters and Issuer Purchases of Equity Securities
The principal market on which our common stock is traded is the New York Stock Exchange.Exchange under the symbol “BAC.” As of February 21, 2018,23, 2021, there were 174,913156,206 registered shareholders of common stock. The table below sets forth the high and low closing sales prices of the common stock on the New York Stock Exchange for the periods indicated during 2016 and 2017, as well as the dividends we paid on a quarterly basis:
        
 Quarter High Low Dividend
2016First $16.43
 $11.16
 $0.05
 Second 15.11
 12.18
 0.05
 Third 16.19
 12.74
 0.075
 Fourth 23.16
 15.63
 0.075
2017First 25.50
 22.05
 0.075
 Second 24.32
 22.23
 0.075
 Third 25.45
 22.89
 0.12
 Fourth 29.88
 25.45
 0.12
For more information regarding our ability to pay dividends, see Note 13 – Shareholders’ Equity and Note 16 – Regulatory Requirements and Restrictions to the Consolidated Financial Statements, which are incorporated herein by reference.
For more information on our equity compensation plans, see Note 18 – Stock-based Compensation Plans to the Consolidated Financial Statements and Item 12 on page 193 of this report, which are incorporated herein by reference.
The table below presents share repurchase activity for the three months ended December 31, 2017.2020. The primary source of funds for cash distributions by the Corporation to its shareholders is dividends received from its bank subsidiaries.
Each of the bank subsidiaries is subject to various regulatory policies and requirements relating to the payment of dividends, including requirements to maintain capital above regulatory minimums. All of the Corporation’s preferred stock outstanding has preference over the Corporation’s common stock with respect to payment of dividends.
(Dollars in millions, except per share information; shares in thousands)
Total Common Shares Purchased (1,2)
Weighted-Average Per Share PriceTotal Shares
Purchased as
Part of Publicly
Announced Programs
Remaining Buyback
Authority Amounts (3)
October 1 - 31, 202010,762 $24.44 — $— 
November 1 - 30, 202024.81 — — 
December 1 - 31, 202027.39 — — 
Three months ended December 31, 202010,764 24.44   
        
(Dollars in millions, except per share information; shares in thousands)
Common Shares Repurchased (1)
 Weighted-Average Per Share Price 
Shares
Purchased as
Part of Publicly
Announced Programs
 
Remaining Buyback
Authority Amounts (2)
October 1 - 31, 201732,986
 $26.92
 32,982
 $9,040
November 1 - 30, 201768,951
 27.23
 68,951
 7,162
December 1 - 31, 201772,075
 29.18
 72,073
 10,059
Three months ended December 31, 2017174,012
 27.98
  
  
(1)
Includes shares of the Corporation’s common stock acquired by the Corporation in connection with satisfaction of tax withholding obligations on vested restricted stock or restricted stock units and certain forfeitures and terminations of employment-related awards under equity incentive plans.
(2)
On June 28, 2017, following the Federal Reserve’s non-objection to our 2017 CCAR capital plan, the Board authorized the repurchase of $12.0 billion in common stock from July 1, 2017 through June 30, 2018, plus approximately $900 million to offset the effect of equity-based compensation plans during the same period. On December 5, 2017, the Corporation announced that the Board authorized the repurchase of an additional $5.0 billion of common stock by June 30, 2018. During the three months ended December 31, 2017, pursuant to the Board’s authorizations, the Corporation repurchased approximately $4.9 billion of common stock, which included common stock to offset equity-based compensation awards. For more information, see Capital Management -- CCAR and Capital Planning on page 45 and Note 13 – Shareholders’ Equity to the Consolidated Financial Statements.
On August 24, 2017, the holders of the Corporation’s Series T preferred stock exercised warrants to acquire 700 million(1)Includes two thousand shares of the Corporation’s common stock. To purchasestock acquired by the Corporation’sCorporation in connection with satisfaction of tax withholding obligations on vested restricted stock or restricted stock units and certain forfeitures and terminations of employment-related awards and for potential re-issuance to certain employees under equity incentive plans.
(2)During the three months ended December 31, 2020, pursuant to the Corporation's Board's authorization, the Corporation repurchased approximately 11 million shares, or $263 million, of its common stock upon exercisesolely to offset shares awarded under equity-based compensation plans.
(3)On January 19, 2021, the Board authorized the repurchase of the warrants, the holders submitted as consideration $5$2.9 billion of Series T preferred stock. On August 29, 2017, the Corporation issued 700 million shares ofin common stock through March 31, 2021, plus approximately $300 million to offset shares awarded under equity-based compensation plans during the same period. For more information, see Capital Management - CCAR and Capital Planning in the MD&A on page 50 and Note 13 – Shareholders’ Equityto the holders. The terms of the warrants were previously disclosed in the Corporation’s Current Report on Form 8-K filed on August 25, 2011.  The sale of the Corporation’s
Consolidated Financial Statements.
common stock pursuant to exercise of the warrants has not been registered with the Securities and Exchange Commission. Such sale is exempt from registration pursuant to Section 4(2) and Section 3(a)(9) of the Securities Act of 1933, as amended. The Corporation did not receivehave any proceeds fromunregistered sales of equity securities during the sale of the common stock upon exercise of the warrants; the cash proceeds the Corporation received in connection with the sale of the Series T preferred stock in August 2011 were used for general corporate purposes.
three months ended December 31, 2020.
Item 6. Selected Financial Data
See Tables 76 and 87 in the MD&A beginning on page 25,32, which are incorporated herein by reference.


Bank of America 22


Item 7. Bank of America Corporation and Subsidiaries
Management's Discussion and Analysis of Financial Condition and Results of Operations
Table of Contents
17Bank of America 2017



Item 7. Bank of America Corporation and Subsidiaries
Management’s Discussion and Analysis of Financial Condition and Results of Operations

23Bank of America 201718



Management’s Discussion and Analysis of Financial Condition and Results of Operations
Bank of America Corporation (the “Corporation”) and 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”.“could.” Forward-looking statements represent the Corporation’s 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.
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 this Annual Report on Form 10-K:10-K: the Corporation’s potential claims,judgments, damages, penalties, fines and reputational damage resulting from pending or future litigation, regulatory proceedings and enforcement actions, including inquiries into our retail sales practices, andactions; the possibility that amountsthe Corporation's future liabilities may be in excess of the Corporation’sits recorded liability and estimated range of possible loss for litigation, exposures;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 servicing, securities, fraud, indemnity, contribution or other claims from one or more counterparties, including trustees, purchasers of loans, underwriters, issuers, other parties involved in securitizations, monolines or private-label and other investors; the possibility that future representations and warranties losses may occur in excess of the Corporation’s recorded liability and estimated range of possible loss for its representations and warranties exposures;mortgage securitizations; the Corporation’s ability to resolve representations and warranties repurchase and related claims,claims; the risks related to the discontinuation of the London Interbank Offered Rate and other reference rates, including claims brought by investors or trustees seeking to avoidincreased expenses and litigation and the statuteeffectiveness of limitations for repurchase claims;hedging strategies; uncertainties about the financial stability and growth rates of non-U.S. jurisdictions, the risk that those jurisdictions may face difficulties servicing their sovereign debt, and related stresses on financial markets, currencies and trade, and the Corporation’s exposures to such risks, including direct, indirect and operational; the impact of U.S. and global interest rates, inflation, currency exchange rates, economic conditions, trade policies and tensions, including tariffs, and potential geopolitical instability; the impact of the interest rate environment on the Corporation’s business, financial condition and results of operations of a potential higher interest rate environment;operations; the possibility that future credit losses may be higher than currently expected due to changes in economic assumptions, customer behavior, adverse developments with respect to U.S. or global economic conditions and other uncertainties; the Corporation's concentration of credit risk; the Corporation’s ability to achieve its expense targets and expectations regarding revenue, net interest income, expectations,provision for credit losses, net charge-offs, effective tax rate, loan growth or other projections; adverse changes to the Corporation’s credit ratings from the major credit rating agencies; an inability to access capital markets or maintain deposits or borrowing costs; estimates of the fair value and other accounting values, subject to impairment assessments, of certain of the Corporation’s assets
and liabilities; the estimated or actual impact of changes in accounting standards or assumptions in applying those standards; uncertainty regarding the content, timing and impact of regulatory capital and liquidity requirements; the potential impact of adverse changes to total loss-absorbing capacity requirements; potential adverse changes to ourrequirements, stress capital buffer requirements and/or global systemically important bank surcharge;surcharges; the potential impact of actions of the Board of Governors of the Federal Reserve actions System on the Corporation’s capital plans; the possible impact of the Corporation’s failure to
remediate a shortcoming identified by banking regulators in the Corporation’s Resolution Plan; the effect of regulations, other guidance or additional information on our estimatedthe impact offrom 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 (FDIC) assessments, the Volcker Rule, fiduciary standards, derivatives regulations and derivativesthe Coronavirus Aid, Relief, and Economic Security Act and any similar or related rules and regulations; a failure or disruption in or breach of the Corporation’s operational or security systems or infrastructure, or those of third parties, including as a result of cyber attacks;attacks or campaigns; the impact on the Corporation’s business, financial condition and results of operations from the plannedUnited Kingdom's exit of the United Kingdom from the European Union; the impact of climate change; the impact of any future federal government shutdown and 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 similar matters.
Forward-looking statements speak only as of the date they are made, and the Corporation undertakes no obligation to update any forward-looking statement to reflect the impact of circumstances or events that arise after the date the forward-looking statement was made.
Notes to the Consolidated Financial Statements referred to in the Management’s Discussion and Analysis of Financial Condition and Results of Operations (MD&A) are incorporated by reference into the MD&A. Certain prior-year amounts have been reclassified to conform to current-year presentation. Throughout the MD&A, the Corporation uses certain acronyms and abbreviations which are defined in the Glossary.
Executive Summary
Business Overview
The Corporation is a Delaware corporation, a bank holding company (BHC) and a financial holding company. When used in this report, “the Corporation”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 bankingvarious bank and various nonbank subsidiaries throughout the U.S. and in international markets, we provide a diversified range of banking and nonbank financial services and products through four business segments: Consumer Banking, Global Wealth & Investment Management (GWIM), Global Banking and Global Markets, with the remaining operations recorded in All Other. We operate our banking activities primarily under the Bank of
Bank of America 24


America, National Association (Bank of America, N.A. or BANA) charter. At December 31, 2017,2020, the Corporation had approximately $2.3$2.8 trillion in assets and a headcount of approximately 209,000213,000 employees. Headcount remained relatively unchanged since December 31, 2016.
As of December 31, 2017,2020, we operated in all 50 states,served clients through operations across the District of Columbia, the U.S. Virgin Islands, Puerto Rico, its territories and more thanapproximately 35 countries. Our retail banking footprint covers approximately 85 percent ofall major markets in the U.S. population,, and we serve approximately 4766 million consumer and small business relationshipsclients with approximately 4,5004,300 retail financial centers, approximately 16,00017,000 ATMs, and leading digital banking platforms (www.bankofamerica.com) with approximately 35more than 39 million active users, including approximately 2431 million active mobile active users. We offer industry-leading support to approximately three million small business owners.households. Our wealth managementGWIM businesses, with client balances of nearly $2.8$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

19Bank of America 2017



broad range of asset classes serving corporations, governments, institutions and individuals around the world.
2017 Economic and Business Environment
The U.S. economy gained momentum in 2017, as it grew for the eighth consecutive year. Following a soft start, partly driven by sharp inventory liquidation and adverse weather effects, GDP growth accelerated over the remainder of the year. Economic growth was supported by a noticeable pickup in business investment in high-tech equipment, a recovery in oil exploration and solid consumer demand growth. A revitalization in U.S. export growth, on the back of a weakening dollar and stronger global growth, also had beneficial impacts. GDP growth was limited by a mid-year softening in residential investment and a flat period for government consumption and investment. The housing market finished the year strongly. A lean supply of unsold inventory and solid demand was supportive of steady home price appreciation through much of the year.
The labor market continued to tighten as job creation exceeded the growth in the labor force. The unemployment rate fell to a 17-year low. Wage growth, however, remained relatively muted.
Inflation also remained low. The headline rate edged somewhat higher on recovering energy prices. But core inflation, excluding volatile food and energy components, slowed unexpectedly over much of the year, as goods’ prices and health care inflation softened, and the acceleration in rents leveled off. Core inflation once again finished the year below the Federal Reserve’s two percent target level.
Equity markets advanced strongly in 2017, with the S&P 500 increasing by approximately 20 percent. The anticipation of corporate tax reform and strong global earnings growth appeared to fuel the stock market’s strong performance. Following a mid-year decline, long-term Treasury yields recovered towards the end of 2017, but finished little changed from the start of the year. With short-end rates rising over the course of the year, the yield curve flattened considerably. After a brief surge following the 2016 election, the trade-weighted dollar declined over most of 2017.
The Federal Open Market Committee (FOMC) raised its target range for the Federal funds rate three times in 2017, bringing the total rise in the funds rate during the current cycle to 125 basis points (bps). The Federal Reserve also began allowing a small portion of its Treasury and mortgage-backed securities (MBS) to roll off as monetary policy normalization continued. Current Federal Reserve baseline forecasts suggest gradual rate increases will continue into 2018 against a backdrop of solid economic expansion and a tightening labor market.
The improved economic momentum in 2017 was not confined to the U.S. The eurozone posted its strongest GDP growth in 10 years, despite heightened political uncertainty and fragmentation.
In this context, the European Central Bank decided to taper its quantitative easing program even if domestic inflationary pressures remained historically weak. The impact of the 2016 U.K. referendum vote in favor of leaving the European Union (EU) started to materialize within the U.K. economy which, despite the robust global momentum, showed its weakest GDP growth in five years.
Supported by a very accommodative monetary policy stance and sustained growth in external demand, the Japanese economy expanded at the strongest pace since 2010 with headline inflation remaining positive throughout the year. Across emerging nations, economic activity was supported by China’s continued transition towards a more consumption-based growth model, as well as by the recovery in Brazil and Russia following the 2016 recession.
Recent EventsDevelopments
Capital Management
During 2017, we repurchased approximately $12.8 billionIn June 2020, the Board of common stock pursuant toGovernors of the Board’s repurchase authorizations under our 2017 and 2016Federal Reserve System (Federal Reserve) notified BHCs of their 2020 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 includingin 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 awards,plans, and pursuant to an additional $5 billion share repurchase authorization approved bylimit common stock dividends to existing rates that did not exceed the Board andaverage of the last four quarters’ net income. In December 2020, the Federal Reserve announced that beginning in December 2017.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 45.50.
ChangeCOVID-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 Tax Lawglobal economic activity, reduced U.S. and global economic output and a deterioration in macroeconomic conditions in the U.S. and globally. This has
On December 22, 2017, the President signed into law the Tax Cuts and Jobs Act (the Tax Act) which made significant changes to federal income tax law including,
resulted in, among other things, reducinghigher rates of unemployment and underemployment and caused volatility and disruptions in the statutory corporate income tax rateglobal financial markets, including 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 21 percent from 35 percentearlier levels. Businesses, market participants, our counterparties and changingclients, and the taxationU.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 Consolidated Appropriations Act of 2021 (the 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 non-U.S.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 activities. Resultscontinuity 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 for 2017 includedsite-based operations for our remaining employees. We continue to evaluate our continuity plans and work-from-home strategy in an estimated reduction in net incomeeffort to best protect the health and safety of $2.9 billion due to the Tax Act, driven largely by a lower valuation of certain U.S. deferred tax assets and liabilities. We have accounted for the effects of the Tax Act using reasonable estimates based on currently available information and our interpretations thereof. This accounting may change due to, among other things, changes in interpretations we have made and the issuance of new tax or accounting guidance.
Long-term Debt Exchange
In December 2017, pursuant to a private offering, we exchanged $11.0 billion of outstanding long-term debt for new fixed/floating-rate senior notes, subject to certain terms and conditions. The impact on our results of operations related to this exchange was not significant. For more information on this exchange, see Liquidity Risk on page 49.employees.



25 Bank of America


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 61, 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 47.
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 the CARES Act by extending the exemption from TDR 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
1 – Summary of Significant Accounting Principles and Note 5 – Outstanding Loans and Leases and Allowance for Credit Lossesto 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 Part I. Item 1A. Risk Factors on page 7.
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 financial industry working groups have 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-based products and contracts, including related hedging arrangements. In response, the Corporation established an enterprise-wide IBOR transition program 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 communications, technology and operations modifications,
Bank of America 20172026



Selected Financial Data
Table 1 provides selected consolidated financial data for 2017 and 2016.
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.
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 industry-recommended 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 central clearing counterparties. In October 2020, the 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.
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
     
Table 1Selected Financial Data   
   
(Dollars in millions, except per share information)2017 2016
Income statement   
Revenue, net of interest expense$87,352
 $83,701
Net income18,232
 17,822
Diluted earnings per common share1.56
 1.49
Dividends paid per common share0.39
 0.25
Performance ratios   
Return on average assets0.80% 0.81%
Return on average common shareholders’ equity6.72
 6.69
Return on average tangible common shareholders’ equity (1)
9.41
 9.51
Efficiency ratio62.67
 65.81
Balance sheet at year end 
  
Total loans and leases$936,749
 $906,683
Total assets2,281,234
 2,188,067
Total deposits1,309,545
 1,260,934
Total common shareholders’ equity244,823
 240,975
Total shareholders’ equity267,146
 266,195
(1)
Return on average tangible common shareholders’ equity is a non-GAAP financial measure. For more information and a corresponding reconciliation to accounting principles generally accepted in the United States of America (GAAP) financial measures, see Non-GAAP Reconciliations on page 88.
expected replacement of LIBOR and other benchmark rates, see Item 1A. Risk Factors – Other on page 19.
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 – Geopolitical on page 12.
Financial Highlights
Net income was $18.2 billion, or $1.56 per diluted share in 2017 compared to $17.8 billion, or $1.49 per diluted share in 2016. The results for 2017 include an estimated charge of $2.9 billion related toEffective January 1, 2020, we adopted the Tax Act. The pre-tax results for 2017 compared to 2016 were driven by higher revenue, largely the result of an increase in net interest income, lower provision fornew accounting standard on current expected credit losses and a decline in noninterest expense.
Effective October 1, 2017, we changed our accounting method for determining when certain stock-based compensation awards granted to retirement-eligible employees are deemed authorized, changing from(CECL), under which the grant date to the beginningallowance is measured based on management’s best estimate of lifetime expected credit losses (ECL). Prior-year periods presented reflect measurement of the year preceding the grant date when the incentive award plans are generally approved.  As a result, the estimated valueallowance based on management’s estimate of the awards is now expensed ratably over the year preceding the grant date. All prior periods presented herein have been restated for this change in accounting method. The change affected consolidated financial information and All Other; it did not affect the business segments. Under the applicable bank regulatory rules, we are not required to and, accordingly, did not restate previously-filed capital metrics and ratios. The cumulative impact of the change in accounting
method resulted in an insignificant pro forma change to our capital metrics and ratios.probable incurred credit losses. For more information, see Note 1 - Summary of Significant Accounting Principles to the Consolidated Financial Statements.
Table 1Summary Income Statement and Selected Financial Data
(Dollars in millions, except per share information)20202019
Income statement
Net interest income$43,360 $48,891 
Noninterest income42,168 42,353 
Total revenue, net of interest expense85,528 91,244 
Provision for credit losses11,320 3,590 
Noninterest expense55,213 54,900 
Income before income taxes18,995 32,754 
Income tax expense1,101 5,324 
Net income17,894 27,430 
Preferred stock dividends1,421 1,432 
Net income applicable to common shareholders$16,473 $25,998 
Per common share information  
Earnings$1.88 $2.77 
Diluted earnings1.87 2.75 
Dividends paid0.72 0.66 
Performance ratios
Return on average assets (1)
0.67 %1.14 %
Return on average common shareholders’ equity (1)
6.76 10.62 
Return on average tangible common shareholders’ equity (2)
9.48 14.86 
Efficiency ratio (1)
64.55 60.17 
Balance sheet at year end  
Total loans and leases$927,861 $983,426 
Total assets2,819,627 2,434,079 
Total deposits1,795,480 1,434,803 
Total liabilities2,546,703 2,169,269 
Total common shareholders’ equity248,414 241,409 
Total shareholders’ equity272,924 264,810 
     
Table 2Summary Income Statement   
     
(Dollars in millions)2017 2016
Net interest income$44,667
 $41,096
Noninterest income42,685
 42,605
Total revenue, net of interest expense87,352
 83,701
Provision for credit losses3,396
 3,597
Noninterest expense54,743
 55,083
Income before income taxes29,213
 25,021
Income tax expense10,981
 7,199
Net income18,232
 17,822
Preferred stock dividends1,614
 1,682
Net income applicable to common shareholders$16,618
 $16,140
     
Per common share information   
Earnings$1.63
 $1.57
Diluted earnings1.56
 1.49
(1)For definitions, see Key Metrics on page 173.
(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 88.

2127Bank of America 2017




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 increased $3.6decreased $5.5 billion to $44.7$43.4 billion in 20172020 compared to 2016.2019. 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 increased 11 bps to 2.32 percentand the FTE basis, see Supplemental Financial Data on page 31, and for 2017. These increases were primarily driven by the benefits from higher interest rates and loan and deposit growth, partially offset by the sale of the non-U.S. consumer credit card business in the second quarter of 2017. For more information regardingon interest rate risk management, see Interest Rate Risk Management for the Banking Book on page 81.82.
Noninterest Income
Table 2Table 2Noninterest Income
    
Table 3Noninterest Income   
  
(Dollars in millions)(Dollars in millions)2017 2016(Dollars in millions)20202019
Fees and commissions:Fees and commissions:
Card incomeCard income$5,902
 $5,851
Card income$5,656 $5,797 
Service chargesService charges7,818
 7,638
Service charges7,141 7,674 
Investment and brokerage servicesInvestment and brokerage services13,281
 12,745
Investment and brokerage services14,574 13,902 
Investment banking income6,011
 5,241
Trading account profits7,277
 6,902
Mortgage banking income224
 1,853
Gains on sales of debt securities255
 490
Investment banking feesInvestment banking fees7,180 5,642 
Total fees and commissionsTotal fees and commissions34,551 33,015 
Market making and similar activitiesMarket making and similar activities8,355 9,034 
Other incomeOther income1,917
 1,885
Other income(738)304 
Total noninterest incomeTotal noninterest income$42,685
 $42,605
Total noninterest income$42,168 $42,353 
Noninterest income increaseddecreased$80185 million to $42.7$42.2 billion for 2017in 2020 compared to 2016.2019. The following highlights the significant changes.
Service charges increased $180 million primarily driven by the impact of pricing strategies and higher treasury services-related revenue.
Investment and brokerage services income increased$536 million primarily driven by the impact of assets under management (AUM) flows and higher market valuations, partially offset by the impact of changing market dynamics on transactional revenue and AUM pricing.
    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.
    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.
Investment banking income increased $770 million primarily due to higher advisory fees and higher debt and equity issuance fees.
Trading account profits increased $375 million primarily due to increased client financing activity in equities, partially offset by weaker performance across most fixed-income products.
Mortgage banking income decreased $1.6 billion primarily driven by lower net servicing income due to lower net mortgage servicing rights (MSR) results, and lower production income primarily due to lower volume.
Gains on sales of debt securities decreased $235 million primarily driven by lower activity.
Other income remained relatively unchanged. Included was a $793 million pre-tax gain recognized in connection with the sale of the non-U.S. consumer credit card business and a downward valuation adjustment of $946 million on tax-advantaged energy investments in connection with the Tax Act.
Provision for Credit Losses
The provision for credit losses decreased $201 millionincreased $7.7 billion to $3.4$11.3 billion for 2017in 2020 compared to 20162019 primarily driven by higher ECL due to reductions in
energy exposures in the commercial portfolio and credit quality improvements in the consumer real estate portfolio. This was partially offset by portfolio seasoning and loan growth in the U.S. credit card portfolio and a single-name non-U.S. commercial charge-off.weaker economic outlook related to COVID-19. For more information on the provision for credit losses, see ProvisionAllowance for Credit Losses on page 72.76.
Noninterest Expense
     
Table 4Noninterest Expense   
   
(Dollars in millions)2017 2016
Personnel$31,642
 $31,748
Occupancy4,009
 4,038
Equipment1,692
 1,804
Marketing1,746
 1,703
Professional fees1,888
 1,971
Data processing3,139
 3,007
Telecommunications699
 746
Other general operating9,928
 10,066
Total noninterest expense$54,743
 $55,083
Table 3Noninterest Expense
(Dollars in millions)20202019
Compensation and benefits$32,725 $31,977 
Occupancy and equipment7,141 6,588 
Information processing and communications5,222 4,646 
Product delivery and transaction related3,433 2,762 
Marketing1,701 1,934 
Professional fees1,694 1,597 
Other general operating3,297 5,396 
Total noninterest expense$55,213 $54,900 
Noninterest expense decreased $340increased $313 million to $54.7$55.2 billion for 2017in 2020 compared to 2016.2019. The decreaseincrease was primarily due to lowerhigher operating costs a reduction from the salerelated to COVID-19, merchant services expenses, which were previously recorded in other income as part of the non-U.S. consumer credit card businessjoint venture net earnings, and lower litigation expense,higher activity-based expenses due to increased client activity, partially offset by a $316 million$2.1 billion pretax impairment charge related to certain data centersthe notice of termination of the merchant services joint venture in the process of being sold and $145 million for the shared success discretionary year-end bonus awarded to certain employees.2019.
Income Tax Expense
Table 4Income Tax Expense
(Dollars in millions)20202019
Income before income taxes$18,995 $32,754 
Income tax expense1,101 5,324 
Effective tax rate5.8 %16.3 %
     
Table 5Income Tax Expense   
   
(Dollars in millions)2017 2016
Income before income taxes$29,213
 $25,021
Income tax expense10,981
 7,199
Effective tax rate37.6% 28.8%
TaxIncome tax expense was $1.1 billion for 2017 included a charge of $1.92020 compared to $5.3 billion reflecting the impact of the Tax Act discussed below. Included in the tax charge was $2.3 billion related primarily to a lower valuation of certain deferred tax assets and liabilities and a $347 million tax benefit on the pre-tax loss from the lower valuation of our tax-advantaged energy investments. Other than the impact of the Tax Act, the2019, resulting in an effective tax rate for 2017 was driven by our recurring tax preference benefits as well as an expense recognized in connection with the sale of the non-U.S. consumer credit card business, largely offset by benefits related5.8 percent compared to the adoption of the new accounting standard for the tax impact associated with share-based compensation and the restructuring of certain subsidiaries. The effective tax rate for 2016 was driven by our recurring tax preferences and net tax benefits related to various tax audit matters, partially offset by a charge for the impact of U.K. tax law changes enacted in 2016.16.3 percent.



Bank of America 20172228



On DecemberThe 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, 2017,2020, the President signed into lawU.K. enacted a repeal of the Tax Actfinal two percent of scheduled decreases in the U.K. corporation tax rate, which made significant changes to federalhad been previously enacted. This change will unfavorably affect income tax law including, among other things, reducingexpense on future U.K.
earnings, and requires a reversal of the statutory corporate income tax rate to 21 percent from 35 percent and changing the taxation of our non-U.S. business activities. Results for 2017 included an estimated reduction in net income of $2.9 billion dueadjustment to the Tax Act, driven largely by a lower valuation of certain U.S.U.K. net deferred tax assets and liabilities. Additionally,recognized at the change intime the corporatetax 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 impacted our tax-advantaged energy investments, resulting in a downward valuation adjustment of $946 million recorded in other income that was fully offset byfor 2019 included net tax benefits arising from lower deferredprimarily related to the resolution of various tax liabilities on these investments. We have accounted for the effects of the Tax Act using reasonable estimates based on currently available
controversy matters.
information and our interpretations thereof. This accounting may change due to, among other things, changes in interpretationsAbsent unusual items, we have made and the issuance of new tax or accounting guidance.
We expect the effective tax rate for 20182021 to be approximately 20 percent, absent unusual items.
Our U.K. deferred tax assets, which consist primarily of net operating losses, are expected to be realized by certain subsidiaries over a number of years. Significant changes to management’s earnings forecasts for those subsidiaries, changes in applicable laws, further changes in tax laws or changes in the abilityrange of 10 12 percent, reflecting tax credits related to our U.K. subsidiaries to conduct business in the EU, could lead management to reassess our ability to realize the U.K. deferred tax assets.ESG investment activity.

Balance Sheet Overview
      
Table 6Selected Balance Sheet Data     
Table 5Table 5Selected Balance Sheet Data
      
 December 31   December 31
(Dollars in millions)(Dollars in millions)2017 2016 % Change(Dollars in millions)20202019% Change
AssetsAssets 
  
  Assets  
Cash and cash equivalentsCash and cash equivalents$157,434
 $147,738
 7 %Cash and cash equivalents$380,463 $161,560 135 %
Federal funds sold and securities borrowed or purchased under agreements to resellFederal funds sold and securities borrowed or purchased under agreements to resell212,747
 198,224
 7
Federal funds sold and securities borrowed or purchased under agreements to resell304,058 274,597 11 
Trading account assetsTrading account assets209,358
 180,209
 16
Trading account assets198,854 229,826 (13)
Debt securitiesDebt securities440,130
 430,731
 2
Debt securities684,850 472,197 45 
Loans and leasesLoans and leases936,749
 906,683
 3
Loans and leases927,861 983,426 (6)
Allowance for loan and lease lossesAllowance for loan and lease losses(10,393) (11,237) (8)Allowance for loan and lease losses(18,802)(9,416)100 
All other assetsAll other assets335,209
 335,719
 
All other assets342,343 321,889 
Total assetsTotal assets$2,281,234
 $2,188,067
 4
Total assets$2,819,627 $2,434,079 16 
LiabilitiesLiabilities     Liabilities
DepositsDeposits$1,309,545
 $1,260,934
 4
Deposits$1,795,480 $1,434,803 25 
Federal funds purchased and securities loaned or sold under agreements to repurchaseFederal funds purchased and securities loaned or sold under agreements to repurchase176,865
 170,291
 4
Federal funds purchased and securities loaned or sold under agreements to repurchase170,323 165,109 
Trading account liabilitiesTrading account liabilities81,187
 63,031
 29
Trading account liabilities71,320 83,270 (14)
Short-term borrowingsShort-term borrowings32,666
 23,944
 36
Short-term borrowings19,321 24,204 (20)
Long-term debtLong-term debt227,402
 216,823
 5
Long-term debt262,934 240,856 
All other liabilitiesAll other liabilities186,423
 186,849
 
All other liabilities227,325 221,027 
Total liabilitiesTotal liabilities2,014,088
 1,921,872
 5
Total liabilities2,546,703 2,169,269 17 
Shareholders’ equityShareholders’ equity267,146
 266,195
 
Shareholders’ equity272,924 264,810 
Total liabilities and shareholders’ equityTotal liabilities and shareholders’ equity$2,281,234
 $2,188,067
 4
Total liabilities and shareholders’ equity$2,819,627 $2,434,079 16 
Assets
At December 31, 2017,2020, total assets were approximately $2.3$2.8 trillion, up $93.2$385.5 billion from December 31, 2016.2019. The increase in assets was primarily due to higher loans and leases drivencash held at central banks that was primarily funded by client demand for commercial loans, higher trading assets and securities borrowed or purchased under agreements to resell due to increased customer activity, and higher cash and cash equivalentsdeposit growth and debt securities, drivenpartially offset by the deployment of deposit inflows.a decline in loans and leases.
Cash and Cash Equivalents
Cash and cash equivalents increased $9.7$218.9 billion primarily driven by deposit growth and net debt issuances, partially offset by loan growth and net securities purchases..
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 $14.5$29.5 billion primarily due to a higher leveldeployment of customer financing activity.deposit inflows.

Trading Account Assets
Trading account assets consist primarily of long positions in equity and fixed-income securities including U.S. government and agency securities, corporate securities and non-U.S. sovereign debt. Trading account assets increased $29.1decreased $31.0 billion primarily driven by additionaldue to a decline in inventory in fixed-income, currencies and commodities (FICC) to meet expected client demand and increased client financing activities in equities within Global Markets.
Debt Securities
Debt securities primarily include U.S. Treasury and agency securities, MBS,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 $9.4$212.7 billion primarily driven by the deployment of deposit inflows. For more information on debt securities, see Note 34 – Securities to the Consolidated Financial Statements.

29 Bank of America


Loans and Leases
Loans and leases increased $30.1decreased $55.6 billion compared to December 31, 2016. The increase was primarily driven by commercial loan paydowns, lower credit card spending and lower residential mortgages due to net loan growth driven by strong client demand for commercial loanshigher paydowns and increasesa decline in

23Bank of America 2017



residential mortgage. originations. For more information on the loan portfolio, see Credit Risk Management on page 54.61.
Allowance for Loan and Lease Losses
The allowance for loan and lease losses decreased $844 millionincreased $9.4 billion primarily due to the weaker economic outlook related to COVID-19 and the impact of improvements inthe adoption of the new credit quality from a stronger economy.loss accounting standard. For more information, see Allowance for Credit Losses on page 72.76.
Liabilities
At December 31, 2017,2020, total liabilities were approximately $2.0$2.5 trillion, up $92.2$377.4 billion from December 31, 2016,2019, primarily due to an increase in deposits, higher trading account liabilities due to an increase in short positions, and higher long-term debt due to net issuances.deposit growth.
Deposits
Deposits increased $48.6$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 to repurchase are collateralized borrowing transactions utilized to accommodate customer transactions, earn interest rate spreads and finance assets on the balance sheet. Federal funds purchased and securities loaned or sold under agreements to repurchase increased $6.6$5.2 billion primarily due to an increase in repurchase agreements.driven by client activity within Global Markets.
Trading Account Liabilities
Trading account liabilities consist primarily of short positions in equity and fixed-income securities including U.S. Treasury and agency securities, corporate securities and non-U.S. sovereign debt. Trading account liabilities increased $18.2decreased $12.0 billion primarily due to higher equitylower levels of short positions and higher levels of shortwithin Global Markets.

government bonds driven by expected client demand within Global Markets.
Short-term Borrowings
Short-term borrowings provide an additional funding source and primarily consist of Federal Home Loan Bank (FHLB) short-term borrowings, notes payable and various other borrowings that generally have maturities of one year or less. Short-term borrowings increased $8.7decreased $4.9 billion primarily due to an increase in short-term bank notes and short-term FHLB Advances.higher deposit levels. For more information on short-term borrowings, see Note 10 – Federal Funds Sold or Purchased, Securities Financing Agreements, and Short-term Borrowings and Restricted Cash to the Consolidated Financial Statements.
Long-term Debt
Long-term debt increased $10.6$22.1 billion primarily drivendue to debt issuances and valuation adjustments, partially offset by issuances outpacing maturities and redemptions. For more information on long-term debt, see Note 11 – Long-term Debt to the Consolidated Financial Statements.
Shareholders’ Equity
Shareholders’ equity increased $1.0$8.1 billion driven by earnings, largelynet income, market value increases on debt securities and issuances of preferred and common stock, partially offset by returnsthe return of capital to shareholders of $18.4totaling $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 share repurchases.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 49.57.



Bank of America 20172430


           
Table 7Five-year Summary of Selected Financial Data         
           
(In millions, except per share information)2017 2016 2015 2014 2013
Income statement     
  
  
Net interest income$44,667
 $41,096
 $38,958
 $40,779
 $40,719
Noninterest income42,685
 42,605
 44,007
 45,115
 46,783
Total revenue, net of interest expense87,352
 83,701
 82,965
 85,894
 87,502
Provision for credit losses3,396
 3,597
 3,161
 2,275
 3,556
Noninterest expense54,743
 55,083
 57,617
 75,656
 69,213
Income before income taxes29,213
 25,021
 22,187
 7,963
 14,733
Income tax expense10,981
 7,199
 6,277
 2,443
 4,194
Net income18,232
 17,822
 15,910
 5,520
 10,539
Net income applicable to common shareholders16,618
 16,140
 14,427
 4,476
 9,190
Average common shares issued and outstanding10,196
 10,284
 10,462
 10,528
 10,731
Average diluted common shares issued and outstanding10,778
 11,047
 11,236
 10,585
 11,491
Performance ratios 
  
  
  
  
Return on average assets0.80% 0.81% 0.74% 0.26% 0.49%
Return on average common shareholders’ equity6.72
 6.69
 6.28
 2.01
 4.21
Return on average tangible common shareholders’ equity (1)
9.41
 9.51
 9.16
 2.98
 6.35
Return on average shareholders’ equity6.72
 6.70
 6.33
 2.32
 4.51
Return on average tangible shareholders’ equity (1)
9.08
 9.17
 8.88
 3.34
 6.58
Total ending equity to total ending assets11.71
 12.17
 11.92
 11.57
 11.06
Total average equity to total average assets11.96
 12.14
 11.64
 11.11
 10.81
Dividend payout24.24
 15.94
 14.49
 28.20
 4.66
Per common share data 
  
  
  
  
Earnings$1.63
 $1.57
 $1.38
 $0.43
 $0.86
Diluted earnings1.56
 1.49
 1.31
 0.42
 0.83
Dividends paid0.39
 0.25
 0.20
 0.12
 0.04
Book value23.80
 23.97
 22.48
 21.32
 20.69
Tangible book value (1)
16.96
 16.89
 15.56
 14.43
 13.77
Market price per share of common stock 
  
      
Closing$29.52
 $22.10
 $16.83
 $17.89
 $15.57
High closing29.88
 23.16
 18.45
 18.13
 15.88
Low closing22.05
 11.16
 15.15
 14.51
 11.03
Market capitalization$303,681
 $222,163
 $174,700
 $188,141
 $164,914
Average balance sheet 
  
  
  
  
Total loans and leases$918,731
 $900,433
 $876,787
 $898,703
 $918,641
Total assets2,268,633
 2,190,218
 2,160,536
 2,145,393
 2,163,296
Total deposits1,269,796
 1,222,561
 1,155,860
 1,124,207
 1,089,735
Long-term debt225,133
 228,617
 240,059
 253,607
 263,417
Common shareholders’ equity247,101
 241,187
 229,576
 222,907
 218,340
Total shareholders’ equity271,289
 265,843
 251,384
 238,317
 233,819
Asset quality (2)
 
  
  
  
  
Allowance for credit losses (3)
$11,170
 $11,999
 $12,880
 $14,947
 $17,912
Nonperforming loans, leases and foreclosed properties (4)
6,758
 8,084
 9,836
 12,629
 17,772
Allowance for loan and lease losses as a percentage of total loans and leases outstanding (4, 5)
1.12% 1.26% 1.37% 1.66% 1.90%
Allowance for loan and lease losses as a percentage of total nonperforming loans and leases (4, 5)
161
 149
 130
 121
 102
Allowance for loan and lease losses as a percentage of total nonperforming loans and leases, excluding the PCI loan portfolio (4, 5)
156
 144
 122
 107
 87
Net charge-offs (6, 7)
$3,979
 $3,821
 $4,338
 $4,383
 $7,897
Net charge-offs as a percentage of average loans and leases outstanding (4, 6)
0.44% 0.43% 0.50% 0.49% 0.87%
Net charge-offs as a percentage of average loans and leases outstanding, excluding the PCI loan portfolio (4)
0.44
 0.44
 0.51
 0.50
 0.90
Capital ratios at year end (8)
 
  
  
  
  
Common equity tier 1 capital11.8% 11.0% 10.2% 12.3% n/a
Tier 1 common capitaln/a
 n/a
 n/a
 n/a
 10.9%
Tier 1 capital13.2
 12.4
 11.3
 13.4
 12.2
Total capital15.1
 14.3
 13.2
 16.5
 15.1
Tier 1 leverage8.6
 8.9
 8.6
 8.2
 7.7
Tangible equity (1)
8.9
 9.2
 8.9
 8.4
 7.8
Tangible common equity (1)
7.9
 8.0
 7.8
 7.5
 7.2
(1)
Tangible equity ratios and tangible book value per share of common stock are non-GAAP financial measures. For more information on these ratios, see Supplemental Financial Data on page 27, and for corresponding reconciliations to GAAP financial measures, see Non-GAAP Reconciliations on page 88.
(2)
For more information on the impact of the purchased credit-impaired (PCI) loan portfolio on asset quality, see Consumer Portfolio Credit Risk Management on page 54.
(3)
Includes the allowance for loan and lease losses and the reserve for unfunded lending commitments.
(4)
Balances and ratios do not include loans accounted for under the fair value option. For additional exclusions from nonperforming loans, leases and foreclosed properties, see Consumer Portfolio Credit Risk Management – Nonperforming Consumer Loans, Leases and Foreclosed Properties Activity on page 62 and corresponding Table 31, and Commercial Portfolio Credit Risk Management – Nonperforming Commercial Loans, Leases and Foreclosed Properties Activity on page 67 and corresponding Table 38.
(5)
Asset quality metrics for 2016 include $243 million of non-U.S. credit card allowance for loan and lease losses and $9.2 billion of non-U.S. credit card loans, which were included in assets of business held for sale on the Consolidated Balance Sheet at December 31, 2016. In 2017, the Corporation sold its non-U.S. consumer credit card business.
(6)
Net charge-offs exclude $207 million, $340 million, $808 million, $810 million and $2.3 billion of write-offs in the PCI loan portfolio for 2017, 2016, 2015, 2014 and 2013, respectively. For more information on PCI write-offs, see Consumer Portfolio Credit Risk Management – Purchased Credit-impaired Loan Portfolio on page 60.
(7)
Includes net charge-offs of $75 million and $175 million on non-U.S. credit card loans in 2017 and 2016, which were included in assets of business held for sale on the Consolidated Balance Sheet at December 31, 2016.
(8)
Risk-based capital ratios are reported under Basel 3 Advanced - Transition at December 31, 2017, 2016 and 2015. We reported risk-based capital ratios under Basel 3 Standardized - Transition at December 31, 2014 and under the general risk-based approach at December 31, 2013. For more information, see Capital Management on page 45.
n/a = not applicable

25Bank of America 2017




                 
Table 8Selected Quarterly Financial Data
                 
  2017 Quarters 2016 Quarters
(In millions, except per share information)Fourth Third Second First Fourth Third Second First
Income statement 
  
  
  
  
  
  
  
Net interest income$11,462
 $11,161
 $10,986
 $11,058
 $10,292
 $10,201
 $10,118
 $10,485
Noninterest income (1)
8,974
 10,678
 11,843
 11,190
 9,698
 11,434
 11,168
 10,305
Total revenue, net of interest expense20,436
 21,839
 22,829
 22,248
 19,990
 21,635
 21,286
 20,790
Provision for credit losses1,001
 834
 726
 835
 774
 850
 976
 997
Noninterest expense13,274
 13,394
 13,982
 14,093
 13,413
 13,734
 13,746
 14,190
Income before income taxes6,161
 7,611
 8,121
 7,320
 5,803
 7,051
 6,564
 5,603
Income tax expense (1)
3,796
 2,187
 3,015
 1,983
 1,268
 2,257
 1,943
 1,731
Net income (1)
2,365
 5,424
 5,106
 5,337
 4,535
 4,794
 4,621
 3,872
Net income applicable to common shareholders2,079
 4,959
 4,745
 4,835
 4,174
 4,291
 4,260
 3,415
Average common shares issued and outstanding10,471
 10,198
 10,014
 10,100
 10,170
 10,250
 10,328
 10,370
Average diluted common shares issued and outstanding10,622
 10,747
 10,835
 10,920
 10,992
 11,034
 11,086
 11,108
Performance ratios 
  
  
  
  
    
  
Return on average assets0.41% 0.95% 0.90% 0.97% 0.82% 0.87% 0.85% 0.72%
Four quarter trailing return on average assets (2)
0.80
 0.91
 0.89
 0.88
 0.81
 0.76
 0.75
 0.76
Return on average common shareholders’ equity3.29
 7.89
 7.75
 8.09
 6.79
 7.02
 7.14
 5.80
Return on average tangible common shareholders’ equity (3)
4.56
 10.98
 10.87
 11.44
 9.58
 9.94
 10.17
 8.32
Return on average shareholders’ equity3.43
 7.88
 7.56
 8.09
 6.69
 7.10
 7.01
 5.99
Return on average tangible shareholders’ equity (3)
4.62
 10.59
 10.23
 11.01
 9.09
 9.68
 9.61
 8.27
Total ending equity to total ending assets11.71
 11.91
 12.00
 11.92
 12.17
 12.28
 12.21
 12.02
Total average equity to total average assets11.87
 12.03
 11.94
 12.00
 12.21
 12.26
 12.11
 11.96
Dividend payout60.35
 25.59
 15.78
 15.64
 18.37
 17.97
 12.17
 15.12
Per common share data 
  
  
  
  
  
  
  
Earnings$0.20
 $0.49
 $0.47
 $0.48
 $0.41
 $0.42
 $0.41
 $0.33
Diluted earnings0.20
 0.46
 0.44
 0.45
 0.39
 0.40
 0.39
 0.31
Dividends paid0.12
 0.12
 0.075
 0.075
 0.075
 0.075
 0.05
 0.05
Book value23.80
 23.87
 24.85
 24.34
 23.97
 24.14
 23.68
 23.13
Tangible book value (3)
16.96
 17.18
 17.75
 17.22
 16.89
 17.09
 16.68
 16.18
Market price per share of common stock 
  
  
  
  
  
  
  
Closing$29.52
 $25.34
 $24.26
 $23.59
 $22.10
 $15.65
 $13.27
 $13.52
High closing29.88
 25.45
 24.32
 25.50
 23.16
 16.19
 15.11
 16.43
Low closing25.45
 22.89
 22.23
 22.05
 15.63
 12.74
 12.18
 11.16
Market capitalization$303,681
 $264,992
 $239,643
 $235,291
 $222,163
 $158,438
 $135,577
 $139,427
Average balance sheet 
  
  
  
  
  
  
  
Total loans and leases$927,790
 $918,129
 $914,717
 $914,144
 $908,396
 $900,594
 $899,670
 $892,984
Total assets2,301,687
 2,271,104
 2,269,293
 2,231,649
 2,208,391
 2,189,750
 2,188,410
 2,174,126
Total deposits1,293,572
 1,271,711
 1,256,838
 1,256,632
 1,250,948
 1,227,186
 1,213,291
 1,198,455
Long-term debt227,644
 227,309
 224,019
 221,468
 220,587
 227,269
 233,061
 233,654
Common shareholders’ equity250,838
 249,214
 245,756
 242,480
 244,519
 243,220
 240,078
 236,871
Total shareholders’ equity273,162
 273,238
 270,977
 267,700
 269,739
 268,440
 265,056
 260,065
Asset quality (4)
 
  
  
  
  
  
  
  
Allowance for credit losses (5)
$11,170
 $11,455
 $11,632
 $11,869
 $11,999
 $12,459
 $12,587
 $12,696
Nonperforming loans, leases and foreclosed properties (6)
6,758
 6,869
 7,127
 7,637
 8,084
 8,737
 8,799
 9,281
Allowance for loan and lease losses as a percentage of total loans and leases outstanding (6, 7)
1.12% 1.16% 1.20% 1.25% 1.26% 1.30% 1.32% 1.35%
Allowance for loan and lease losses as a percentage of total nonperforming loans and leases (6, 7)
161
 163
 160
 156
 149
 140
 142
 136
Allowance for loan and lease losses as a percentage of total nonperforming loans and leases, excluding the PCI loan portfolio (6, 7)
156
 158
 154
 150
 144
 135
 135
 129
Net charge-offs (8, 9)
$1,237
 $900
 $908
 $934
 $880
 $888
 $985
 $1,068
Annualized net charge-offs as a percentage of average loans and leases outstanding (6, 8)
0.53% 0.39% 0.40% 0.42% 0.39% 0.40% 0.44% 0.48%
Annualized net charge-offs as a percentage of average loans and leases outstanding, excluding the PCI loan portfolio (6)
0.54
 0.40
 0.41
 0.42
 0.39
 0.40
 0.45
 0.49
Capital ratios at period end (10)
 
  
  
  
  
  
  
  
Common equity tier 1 capital11.8% 11.9% 11.6% 11.0% 11.0% 11.0% 10.6% 10.3%
Tier 1 capital13.2
 13.3
 13.2
 12.5
 12.4
 12.4
 12.0
 11.5
Total capital15.1
 15.1
 15.1
 14.4
 14.3
 14.2
 13.9
 13.4
Tier 1 leverage8.6
 9.0
 8.9
 8.8
 8.9
 9.1
 8.9
 8.7
Tangible equity (3)
8.9
 9.1
 9.2
 9.0
 9.2
 9.3
 9.2
 9.0
Tangible common equity (3)
7.9
 8.1
 8.0
 7.9
 8.0
 8.1
 8.1
 7.9
(1)
Net income for the fourth quarter of 2017 included an estimated charge of $2.9 billion from enactment of the Tax Act which consisted of $946 million in noninterest income and $1.9 billion in income tax expense. For more information on Tax Act impacts, see Income Tax Expense on page 22.
(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, see Supplemental Financial Data on page 27, and for corresponding reconciliations to GAAP financial measures, see Non-GAAP Reconciliations on page 88.
(4)
For more information on the impact of the PCI loan portfolio on asset quality, see Consumer Portfolio Credit Risk Management on page 54.
(5)
Includes the allowance for loan and lease losses and the reserve for unfunded lending commitments.
(6)
Balances and ratios do not include loans accounted for under the fair value option. For additional exclusions from nonperforming loans, leases and foreclosed properties, see Consumer Portfolio Credit Risk Management – Nonperforming Consumer Loans, Leases and Foreclosed Properties Activity on page 62 and corresponding Table 31, and Commercial Portfolio Credit Risk Management – Nonperforming Commercial Loans, Leases and Foreclosed Properties Activity on page 67 and corresponding Table 38.
(7)
Asset quality metrics for the first quarter of 2017 and the fourth quarter of 2016 include $242 million and $243 million of non-U.S. credit card allowance for loan and lease losses and $9.5 billion and $9.2 billion of non-U.S. credit card loans, which were included in assets of business held for sale on the Consolidated Balance Sheet at March 31, 2017 and December 31, 2016. In 2017, the Corporation sold its non-U.S. consumer credit card business.
(8)
Net charge-offs exclude $46 million, $73 million, $55 million and $33 million of write-offs in the PCI loan portfolio in the fourth, third, second and first quarters of 2017, respectively, and $70 million, $83 million, $82 million and $105 million in the fourth, third, second and first quarters of 2016, respectively. For more information on PCI write-offs, see Consumer Portfolio Credit Risk Management – Purchased Credit-impaired Loan Portfolio on page 60.
(9)
Includes net charge-offs of $31 million, $44 million and $41 million on non-U.S. credit card loans in the second and first quarters of 2017, and in the fourth quarter of 2016, which were included in assets of business held for sale on the Consolidated Balance Sheet at March 31, 2017 and December 31, 2016.
(10)
Risk-based capital ratios are reported under Basel 3 Advanced - Transition. For more information, see Capital Management on page 45.



Bank of America 201726


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 a fully taxable-equivalent (FTE)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 3521 percent and a representative state tax rate. In addition, certain performance measures including the efficiency ratio and netNet interest yield, utilize net interest income (and thus total revenue) on an FTE basis. The efficiency ratiowhich measures the costs expended to generate a dollar of revenue, and net interest yield measures the bpsbasis points we earn over the cost of funds.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 areis useful because theysuch measures provide additional information to assess the underlying operational performance and trends of our businesses and to allow better comparison of period-to-period operating performance.
We also evaluate our business based on certain ratios that utilize tangible equity, a non-GAAP financial measure. Tangible
equity represents an adjusted shareholders’ equity or common shareholders’ equity amount which has been reduced by goodwill and certain acquired intangible assets (excluding MSRs)mortgage servicing rights (MSRs)), net of related deferred tax liabilities.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
shareholders’ equity as key measures to support our overall growth goals.objectives. These ratios are as follows:
Return on average tangible common shareholders’ equity measures our earnings contribution as a percentage of adjusted common shareholders’ equity. The tangible common equity ratio represents adjusted ending common shareholders’ equity divided by total assets less goodwill and certain acquired intangible assets (excluding MSRs), net of related deferred tax liabilities.
Return on average tangible shareholders’ equity measures our earnings contribution as a percentage of adjusted average total shareholders’ equity. The tangible equity ratio represents adjusted ending shareholders’ equity divided by total assets less goodwill and certain acquired intangible assets (excluding MSRs), net of related deferred tax liabilities.
Tangible book value per common share represents adjusted ending common shareholders’ equity divided by ending common shares outstanding.
    Return on average tangible common shareholders’ equity measures our net income applicable to common shareholders as a percentage of adjusted average common shareholders’ equity. The tangible common equity ratio represents adjusted ending common shareholders’ equity divided by total tangible assets.
    Return on average tangible shareholders' equity measures our net income as a percentage of adjusted average total shareholders’ equity. The tangible equity ratio represents adjusted ending shareholders’ equity divided by total tangible assets.
    Tangible book value per common share represents adjusted ending common shareholders’ equity divided by ending common shares outstanding.
We believe that the use of ratios that utilizeutilizing tangible equity providesprovide 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 76 and 8.7.
For more information on the reconciliation of these non-GAAP financial measures to the corresponding GAAP financial measures, see Non-GAAP Reconciliations on page 88.
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 173.
Our consolidated key performance indicators, which include various equity and credit metrics, are presented in Table 1 on page 27 and/or Tables 6 and 7 on pages 32 and 33.
For information on key segment performance metrics, see Business Segment Operations on page 36.

27Bank of America 2017



                   
Table 9Average Balances and Interest Rates - FTE Basis
                   
  Average
Balance
 Interest
Income/
Expense
 Yield/
Rate
 Average
Balance
 Interest
Income/
Expense
 Yield/
Rate
 Average
Balance
 Interest
Income/
Expense
 Yield/
Rate
(Dollars in millions)2017 2016 2015
Earning assets 
  
  
  
  
  
  
  
  
Interest-bearing deposits with the Federal Reserve, non-U.S. central banks and other banks 
$127,431
 $1,122
 0.88% $133,374
 $605
 0.45% $136,391
 $369
 0.27%
Time deposits placed and other short-term investments12,112
 241
 1.99
 9,026
 140
 1.55
 9,556
 146
 1.53
Federal funds sold and securities borrowed or purchased under agreements to resell222,818
 2,390
 1.07
 216,161
 1,118
 0.52
 211,471
 988
 0.47
Trading account assets129,007
 4,618
 3.58
 129,766
 4,563
 3.52
 137,837
 4,547
 3.30
Debt securities435,005
 10,626
 2.44
 418,289
 9,263
 2.23
 390,849
 9,233
 2.38
Loans and leases (1):
 
  
  
  
  
  
  
  
  
Residential mortgage197,766
 6,831
 3.45
 188,250
 6,488
 3.45
 201,366
 6,967
 3.46
Home equity62,260
 2,608
 4.19
 71,760
 2,713
 3.78
 81,070
 2,984
 3.68
U.S. credit card91,068
 8,791
 9.65
 87,905
 8,170
 9.29
 88,244
 8,085
 9.16
Non-U.S. credit card (2)
3,929
 358
 9.12
 9,527
 926
 9.72
 10,104
 1,051
 10.40
Direct/Indirect consumer (3)
93,374
 2,622
 2.81
 91,853
 2,296
 2.50
 84,585
 2,040
 2.41
Other consumer (4)
2,628
 112
 4.23
 2,295
 75
 3.26
 1,938
 56
 2.86
Total consumer451,025
 21,322
 4.73
 451,590
 20,668
 4.58
 467,307
 21,183
 4.53
U.S. commercial292,452
 9,765
 3.34
 276,887
 8,101
 2.93
 248,354
 6,883
 2.77
Commercial real estate (5)
58,502
 2,116
 3.62
 57,547
 1,773
 3.08
 52,136
 1,521
 2.92
Commercial lease financing21,747
 706
 3.25
 21,146
 627
 2.97
 19,802
 628
 3.17
Non-U.S. commercial95,005
 2,566
 2.70
 93,263
 2,337
 2.51
 89,188
 2,008
 2.25
Total commercial467,706
 15,153
 3.24
 448,843
 12,838
 2.86
 409,480
 11,040
 2.70
Total loans and leases (2)
918,731
 36,475
 3.97
 900,433
 33,506
 3.72
 876,787
 32,223
 3.68
Other earning assets76,957
 3,032
 3.94
 59,775
 2,762
 4.62
 62,040
 2,890
 4.66
Total earning assets (6)
1,922,061
 58,504
 3.04
 1,866,824
 51,957
 2.78
 1,824,931
 50,396
 2.76
Cash and due from banks27,995
    
 27,893
    
 28,921
    
Other assets, less allowance for loan and lease losses318,577
  
  
 295,501
  
  
 306,684
  
  
Total assets$2,268,633
  
  
 $2,190,218
  
  
 $2,160,536
  
  
Interest-bearing liabilities 
  
  
  
  
  
  
  
  
U.S. interest-bearing deposits: 
  
  
  
  
  
  
  
  
Savings$53,783
 $5
 0.01% $49,495
 $5
 0.01% $46,498
 $7
 0.01%
NOW and money market deposit accounts628,647
 873
 0.14
 589,737
 294
 0.05
 543,133
 273
 0.05
Consumer CDs and IRAs44,794
 121
 0.27
 48,594
 133
 0.27
 54,679
 162
 0.30
Negotiable CDs, public funds and other deposits36,782
 354
 0.96
 32,889
 160
 0.49
 29,976
 95
 0.32
Total U.S. interest-bearing deposits764,006
 1,353
 0.18
 720,715
 592
 0.08
 674,286
 537
 0.08
Non-U.S. interest-bearing deposits: 
  
  
  
  
  
  
  
  
Banks located in non-U.S. countries2,442
 21
 0.85
 3,891
 32
 0.82
 4,473
 31
 0.70
Governments and official institutions1,006
 10
 0.95
 1,437
 9
 0.64
 1,492
 5
 0.33
Time, savings and other62,386
 547
 0.88
 59,183
 382
 0.65
 54,767
 288
 0.53
Total non-U.S. interest-bearing deposits65,834
 578
 0.88
 64,511
 423
 0.66
 60,732
 324
 0.53
Total interest-bearing deposits829,840
 1,931
 0.23
 785,226
 1,015
 0.13
 735,018
 861
 0.12
Federal funds purchased, securities loaned or sold under agreements to repurchase, short-term borrowings and other interest-bearing liabilities273,097
 3,538
 1.30
 251,236
 2,350
 0.94
 275,785
 2,387
 0.87
Trading account liabilities45,518
 1,204
 2.64
 37,897
 1,018
 2.69
 46,206
 1,343
 2.91
Long-term debt225,133
 6,239
 2.77
 228,617
 5,578
 2.44
 240,059
 5,958
 2.48
Total interest-bearing liabilities (6)
1,373,588
 12,912
 0.94
 1,302,976
 9,961
 0.76
 1,297,068
 10,549
 0.81
Noninterest-bearing sources: 
  
  
  
  
  
  
  
  
Noninterest-bearing deposits439,956
  
  
 437,335
  
  
 420,842
  
  
Other liabilities183,800
  
  
 184,064
  
  
 191,242
  
  
Shareholders’ equity271,289
  
  
 265,843
  
  
 251,384
  
  
Total liabilities and shareholders’ equity$2,268,633
  
  
 $2,190,218
  
  
 $2,160,536
  
  
Net interest spread 
  
 2.10%  
  
 2.02%  
  
 1.95%
Impact of noninterest-bearing sources 
  
 0.27
  
  
 0.23
  
  
 0.24
Net interest income/yield on earning assets 
 $45,592
 2.37%  
 $41,996
 2.25%  
 $39,847
 2.19%
(1)
Nonperforming loans are included in the respective average loan balances. Income on these nonperforming loans is generally recognized on a cost recovery basis. PCI loans are recorded at fair value upon acquisition and accrete interest income over the estimated life of the loan.
(2)
Includes assets of the Corporation’s non-U.S. consumer credit card business, which was sold during the second quarter of 2017.
(3)
Includes non-U.S. consumer loans of $2.9 billion, $3.4 billion and $4.0 billion in 2017, 2016 and 2015, respectively.
(4)
Includes consumer finance loans of $321 million, $514 million and $619 million; consumer leases of $2.1 billion, $1.6 billion and $1.2 billion, and consumer overdrafts of $179 million, $173 million and $156 million in 2017, 2016 and 2015, respectively.
(5)
Includes U.S. commercial real estate loans of $55.0 billion, $54.2 billion and $49.0 billion, and non-U.S. commercial real estate loans of $3.5 billion, $3.4 billion and $3.1 billion in 2017, 2016 and 2015, respectively.
(6)
Interest income includes the impact of interest rate risk management contracts, which decreased interest income on the underlying assets by $44 million, $176 million and $59 million in 2017, 2016 and 2015, respectively. Interest expense includes the impact of interest rate risk management contracts, which decreased interest expense on the underlying liabilities by $1.4 billion, $2.1 billion and $2.4 billion in 2017, 2016 and 2015, respectively. For more information, see Interest Rate Risk Management for the Banking Book on page 81.



Bank of America 201728


             
Table 10Analysis of Changes in Net Interest Income - FTE Basis
             
  
Due to Change in (1)
 Net Change 
Due to Change in (1)
 Net Change
 Volume Rate  Volume Rate 
(Dollars in millions)From 2016 to 2017 From 2015 to 2016
Increase (decrease) in interest income 
  
  
  
  
  
Interest-bearing deposits with the Federal Reserve, non-U.S. central banks and other banks$(32) $549
 $517
 $(9) $245
 $236
Time deposits placed and other short-term investments48
 53
 101
 (8) 2
 (6)
Federal funds sold and securities borrowed or purchased under agreements to resell41
 1,231
 1,272
 28
 102
 130
Trading account assets(22) 77
 55
 (265) 281
 16
Debt securities438
 925
 1,363
 722
 (692) 30
Loans and leases:       
  
  
Residential mortgage335
 8
 343
 (454) (25) (479)
Home equity(360) 255
 (105) (343) 72
 (271)
U.S. credit card290
 331
 621
 (33) 118
 85
Non-U.S. credit card(544) (24) (568) (60) (65) (125)
Direct/Indirect consumer38
 288
 326
 174
 82
 256
Other consumer11
 26
 37
 10
 9
 19
Total consumer 
  
 654
  
  
 (515)
U.S. commercial468
 1,196
 1,664
 787
 431
 1,218
Commercial real estate29
 314
 343
 159
 93
 252
Commercial lease financing19
 60
 79
 42
 (43) (1)
Non-U.S. commercial48
 181
 229
 90
 239
 329
Total commercial 
  
 2,315
  
  
 1,798
Total loans and leases 
  
 2,969
  
  
 1,283
Other earning assets793
 (523) 270
 (104) (24) (128)
Total interest income 
  
 $6,547
  
  
 $1,561
Increase (decrease) in interest expense 
  
  
  
  
  
U.S. interest-bearing deposits: 
  
  
  
  
  
Savings$
 $
 $
 $(2) $
 $(2)
NOW and money market deposit accounts20
 559
 579
 22
 (1) 21
Consumer CDs and IRAs(12) 
 (12) (16) (13) (29)
Negotiable CDs, public funds and other deposits20
 174
 194
 10
 55
 65
Total U.S. interest-bearing deposits 
  
 761
  
  
 55
Non-U.S. interest-bearing deposits: 
  
  
  
  
  
Banks located in non-U.S. countries(12) 1
 (11) (4) 5
 1
Governments and official institutions(3) 4
 1
 
 4
 4
Time, savings and other24
 141
 165
 26
 68
 94
Total non-U.S. interest-bearing deposits 
  
 155
  
  
 99
Total interest-bearing deposits 
  
 916
  
  
 154
Federal funds purchased, securities loaned or sold under agreements to repurchase, short-term borrowings and other interest-bearing liabilities217
 971
 1,188
 (201) 164
 (37)
Trading account liabilities206
 (20) 186
 (240) (85) (325)
Long-term debt(85) 746
 661
 (288) (92) (380)
Total interest expense 
  
 2,951
  
  
 (588)
Net increase in net interest income 
  
 $3,596
  
  
 $2,149
(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.


2931 Bank of America


Table 6Five-year Summary of Selected Financial Data
(In millions, except per share information)20202019201820172016
Income statement   
Net interest income$43,360 $48,891 $48,162 $45,239 $41,486 
Noninterest income42,168 42,353 42,858 41,887 42,012 
Total revenue, net of interest expense85,528 91,244 91,020 87,126 83,498 
Provision for credit losses11,320 3,590 3,282 3,396 3,597 
Noninterest expense55,213 54,900 53,154 54,517 54,880 
Income before income taxes18,995 32,754 34,584 29,213 25,021 
Income tax expense1,101 5,324 6,437 10,981 7,199 
Net income17,894 27,430 28,147 18,232 17,822 
Net income applicable to common shareholders16,473 25,998 26,696 16,618 16,140 
Average common shares issued and outstanding8,753.2 9,390.5 10,096.5 10,195.6 10,248.1 
Average diluted common shares issued and outstanding8,796.9 9,442.9 10,236.9 10,778.4 11,046.8 
Performance ratios   
Return on average assets (1)
0.67 %1.14 %1.21 %0.80 %0.81 %
Return on average common shareholders’ equity (1)
6.76 10.62 11.04 6.72 6.69 
Return on average tangible common shareholders’ equity (2)
9.48 14.86 15.55 9.41 9.51 
Return on average shareholders’ equity (1)
6.69 10.24 10.63 6.72 6.70 
Return on average tangible shareholders’ equity (2)
9.07 13.85 14.46 9.08 9.17 
Total ending equity to total ending assets9.68 10.88 11.27 11.71 12.17 
Total average equity to total average assets9.96 11.14 11.39 11.96 12.14 
Dividend payout38.18 23.65 20.31 24.24 15.94 
Per common share data   
Earnings$1.88 $2.77 $2.64 $1.63 $1.57 
Diluted earnings1.87 2.75 2.61 1.56 1.49 
Dividends paid0.72 0.66 0.54 0.39 0.25 
Book value (1)
28.72 27.32 25.13 23.80 23.97 
Tangible book value (2)
20.60 19.41 17.91 16.96 16.89 
Market capitalization$262,206 $311,209 $238,251 $303,681 $222,163 
Average balance sheet   
Total loans and leases$982,467 $958,416 $933,049 $918,731 $900,433 
Total assets2,683,122 2,405,830 2,325,246 2,268,633 2,190,218 
Total deposits1,632,998 1,380,326 1,314,941 1,269,796 1,222,561 
Long-term debt220,440 201,623 200,399 194,882 204,826 
Common shareholders’ equity243,685 244,853 241,799 247,101 241,187 
Total shareholders’ equity267,309 267,889 264,748 271,289 265,843 
Asset quality (3) 
   
Allowance for credit losses (4)
$20,680 $10,229 $10,398 $11,170 $11,999 
Nonperforming loans, leases and foreclosed properties (5)
5,116 3,837 5,244 6,758 8,084 
Allowance for loan and lease losses as a percentage of total loans and leases outstanding (5)
2.04 %0.97 %1.02 %1.12 %1.26 %
Allowance for loan and lease losses as a percentage of total nonperforming loans and leases (5)
380 265 194 161 149 
Net charge-offs$4,121 $3,648 $3,763 $3,979 $3,821 
Net charge-offs as a percentage of average loans and leases outstanding (5)
0.42 %0.38 %0.41 %0.44 %0.43 %
Capital ratios at year end (6)
   
Common equity tier 1 capital11.9 %11.2 %11.6 %11.5 %10.8 %
Tier 1 capital13.5 12.6 13.2 13.0 12.4 
Total capital16.1 14.7 15.1 14.8 14.2 
Tier 1 leverage7.4 7.9 8.4 8.6 8.8 
Supplementary leverage ratio7.2 6.4 6.8             n/a            n/a
Tangible equity (2)
7.4 8.2 8.6 8.9 9.2 
Tangible common equity (2)
6.5 7.3 7.6 7.9 8.0 
(1)For definitions, see Key Metrics on page 173
(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 31 and Non-GAAP Reconciliations on page 88.
(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.
(4)Includes the allowance for loan and leases losses and the reserve for unfunded lending commitments.
(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 67 and corresponding Table 28 and Commercial Portfolio Credit Risk Management – Nonperforming Commercial Loans, Leases and Foreclosed Properties Activity on page 71 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 50.
n/a = not applicable
Bank of America 201732




Table 7Selected Quarterly Financial Data
2020 Quarters2019 Quarters
(In millions, except per share information)FourthThirdSecondFirstFourthThirdSecondFirst
Income statement   
Net interest income$10,253 $10,129 $10,848 $12,130 $12,140 $12,187 $12,189 $12,375 
Noninterest income9,846 10,207 11,478 10,637 10,209 10,620 10,895 10,629 
Total revenue, net of interest expense20,099 20,336 22,326 22,767 22,349 22,807 23,084 23,004 
Provision for credit losses53 1,389 5,117 4,761 941 779 857 1,013 
Noninterest expense13,927 14,401 13,410 13,475 13,239 15,169 13,268 13,224 
Income before income taxes6,119 4,546 3,799 4,531 8,169 6,859 8,959 8,767 
Income tax expense649 (335)266 521 1,175 1,082 1,611 1,456 
Net income5,470 4,881 3,533 4,010 6,994 5,777 7,348 7,311 
Net income applicable to common shareholders5,208 4,440 3,284 3,541 6,748 5,272 7,109 6,869 
Average common shares issued and outstanding8,724.9 8,732.9 8,739.9 8,815.6 9,017.1 9,303.6 9,523.2 9,725.9 
Average diluted common shares issued and outstanding8,785.0 8,777.5 8,768.1 8,862.7 9,079.5 9,353.0 9,559.6 9,787.3 
Performance ratios      
Return on average assets (1)
0.78 %0.71 %0.53 %0.65 %1.13 %0.95 %1.23 %1.26 %
Four-quarter trailing return on average assets (2)
0.67 0.75 0.81 0.99 1.14 1.17 1.24 1.22 
Return on average common shareholders’ equity (1)
8.39 7.24 5.44 5.91 11.00 8.48 11.62 11.42 
Return on average tangible common shareholders’ equity (3)
11.73 10.16 7.63 8.32 15.43 11.84 16.24 16.01 
Return on average shareholders’ equity (1)
8.03 7.26 5.34 6.10 10.40 8.48 11.00 11.14 
Return on average tangible shareholders’ equity (3)
10.84 9.84 7.23 8.29 14.09 11.43 14.88 15.10 
Total ending equity to total ending assets9.68 9.82 9.69 10.11 10.88 11.06 11.33 11.23 
Total average equity to total average assets9.71 9.76 9.85 10.60 10.89 11.21 11.17 11.28 
Dividend payout30.11 35.36 47.87 44.57 23.90 31.48 19.95 21.20 
Per common share data      
Earnings$0.60 $0.51 $0.38 $0.40 $0.75 $0.57 $0.75 $0.71 
Diluted earnings0.59 0.51 0.37 0.40 0.74 0.56 0.74 0.70 
Dividends paid0.18 0.18 0.18 0.18 0.18 0.18 0.15 0.15 
Book value (1)
28.72 28.33 27.96 27.84 27.32 26.96 26.41 25.57 
Tangible book value (3)
20.60 20.23 19.90 19.79 19.41 19.26 18.92 18.26 
Market capitalization$262,206 $208,656 $205,772 $184,181 $311,209 $264,842 $270,935 $263,992 
Average balance sheet      
Total loans and leases$934,798 $974,018 $1,031,387 $990,283 $973,986 $964,733 $950,525 $944,020 
Total assets2,791,874 2,739,684 2,704,186 2,494,928 2,450,005 2,412,223 2,399,051 2,360,992 
Total deposits1,737,139 1,695,488 1,658,197 1,439,336 1,410,439 1,375,052 1,375,450 1,359,864 
Long-term debt225,423 224,254 221,167 210,816 206,026 202,620 201,007 196,726 
Common shareholders’ equity246,840 243,896 242,889 241,078 243,439 246,630 245,438 243,891 
Total shareholders’ equity271,020 267,323 266,316 264,534 266,900 270,430 267,975 266,217 
Asset quality     
Allowance for credit losses (4)
$20,680 $21,506 $21,091 $17,126 $10,229 $10,242 $10,333 $10,379 
Nonperforming loans, leases and foreclosed properties (5)
5,116 4,730 4,611 4,331 3,837 3,723 4,452 5,145 
Allowance for loan and lease losses as a percentage of total loans and leases outstanding (5)
2.04 %2.07 %1.96 %1.51 %0.97 %0.98 %1.00 %1.02 %
Allowance for loan and lease losses as a percentage of total nonperforming loans and leases (5)
380 431 441 389 265 271 228 197 
Net charge-offs$881 $972 $1,146 $1,122 $959 $811 $887 $991 
Annualized net charge-offs as a percentage of average loans and leases outstanding (5)
0.38 %0.40 %0.45 %0.46 %0.39 %0.34 %0.38 %0.43 %
Capital ratios at period end (6)
     
Common equity tier 1 capital11.9 %11.9 %11.4 %10.8 %11.2 %11.4 %11.7 %11.6 %
Tier 1 capital13.5 13.5 12.9 12.3 12.6 12.9 13.3 13.1 
Total capital16.1 16.1 14.8 14.6 14.7 15.1 15.4 15.2 
Tier 1 leverage7.4 7.4 7.4 7.9 7.9 8.2 8.4 8.4 
Supplementary leverage ratio7.2 6.9 7.1 6.4 6.4 6.6 6.8 6.8 
Tangible equity (3)
7.4 7.4 7.3 7.7 8.2 8.4 8.7 8.5 
Tangible common equity (3)
6.5 6.6 6.5 6.7 7.3 7.4 7.6 7.6 
Total loss-absorbing capacity and long-term debt metrics
Total loss-absorbing capacity to risk-weighted assets27.4 %26.9 %26.0 %24.6 %24.6 %24.8 %25.5 %24.8 %
Total loss-absorbing capacity to supplementary leverage exposure14.5 13.7 14.2 12.8 12.5 12.7 13.0 12.8 
Eligible long-term debt to risk-weighted assets13.3 12.9 12.4 11.6 11.5 11.4 11.8 11.4 
Eligible long-term debt to supplementary leverage exposure7.1 6.6 6.7 6.1 5.8 5.8 6.0 5.9 
(1)For definitions, see Key Metrics on page 173.
(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 31 and Non-GAAP Reconciliations on page 88.
(4)Includes the allowance for loan and lease losses and the reserve for unfunded lending commitments.
(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 68 and corresponding Table 28 and Commercial Portfolio Credit Risk Management – Nonperforming Commercial Loans, Leases and Foreclosed Properties Activity on page 72 and corresponding Table 35.
(6)For more information, including which approach is used to assess capital adequacy, see Capital Management on page 50.



33 Bank of America


Table 8Average Balances and Interest Rates - FTE Basis
Average
Balance
Interest
Income/
Expense
(1)
Yield/
Rate
Average
Balance
Interest
Income/
Expense
(1)
Yield/
Rate
Average
Balance
Interest
Income/
Expense
(1)
Yield/
Rate
(Dollars in millions)202020192018
Earning assets         
Interest-bearing deposits with the Federal Reserve, non-
U.S. central banks and other banks
$253,227 $359 0.14 %$125,555 $1,823 1.45 %$139,848 $1,926 1.38 %
Time deposits placed and other short-term investments8,840 29 0.33 9,427 207 2.19 9,446 216 2.29 
Federal funds sold and securities borrowed or purchased
under agreements to resell
309,945 903 0.29 279,610 4,843 1.73 251,328 3,176 1.26 
Trading account assets148,076 4,185 2.83 148,076 5,269 3.56 132,724 4,901 3.69 
Debt securities532,266 9,868 1.87 450,090 11,917 2.65 437,312 11,837 2.66 
Loans and leases (2)
         
Residential mortgage236,719 7,338 3.10 220,552 7,651 3.47 207,523 7,294 3.51 
Home equity38,251 1,290 3.37 44,600 2,194 4.92 53,886 2,573 4.77 
Credit card85,017 8,759 10.30 94,488 10,166 10.76 94,612 9,579 10.12 
Direct/Indirect and other consumer (3)
89,974 2,545 2.83 90,656 3,261 3.60 93,036 3,104 3.34 
Total consumer449,961 19,932 4.43 450,296 23,272 5.17 449,057 22,550 5.02 
U.S. commercial (4)
344,095 9,712 2.82 321,467 13,161 4.09 304,387 11,937 3.92 
Non-U.S. commercial (4)
106,487 2,208 2.07 103,918 3,402 3.27 97,664 3,220 3.30 
Commercial real estate (5)
63,428 1,790 2.82 62,044 2,741 4.42 60,384 2,618 4.34 
Commercial lease financing18,496 559 3.02 20,691 718 3.47 21,557 698 3.24 
Total commercial532,506 14,269 2.68 508,120 20,022 3.94 483,992 18,473 3.82 
Total loans and leases982,467 34,201 3.48 958,416 43,294 4.52 933,049 41,023 4.40 
Other earning assets83,078 2,539 3.06 69,089 4,478 6.48 76,524 4,300 5.62 
Total earning assets2,317,899 52,084 2.25 2,040,263 71,831 3.52 1,980,231 67,379 3.40 
Cash and due from banks31,885  26,193  25,830  
Other assets, less allowance for loan and lease losses333,338   339,374   319,185   
Total assets$2,683,122   $2,405,830   $2,325,246   
Interest-bearing liabilities         
U.S. interest-bearing deposits         
Savings$58,113 $6 0.01 %$52,020 $0.01 %$54,226 $0.01 %
Demand and money market deposit accounts829,719 977 0.12 741,126 4,471 0.60 676,382 2,636 0.39 
Consumer CDs and IRAs47,780 405 0.85 47,577 471 0.99 39,823 157 0.39 
Negotiable CDs, public funds and other deposits64,857 323 0.50 66,866 1,407 2.11 50,593 991 1.96 
Total U.S. interest-bearing deposits1,000,469 1,711 0.17 907,589 6,354 0.70 821,024 3,790 0.46 
Non-U.S. interest-bearing deposits         
Banks located in non-U.S. countries1,476 4 0.27 1,936 20 1.04 2,312 39 1.69 
Governments and official institutions184  0.01 181 — 0.05 810 — 0.01 
Time, savings and other75,386 228 0.30 69,351 814 1.17 65,097 666 1.02 
Total non-U.S. interest-bearing deposits77,046 232 0.30 71,468 834 1.17 68,219 705 1.03 
Total interest-bearing deposits1,077,515 1,943 0.18 979,057 7,188 0.73 889,243 4,495 0.51 
Federal funds purchased, securities loaned or sold under
agreements to repurchase, short-term borrowings and
other interest-bearing liabilities
293,466 987 0.34 276,432 7,208 2.61 269,748 5,839 2.17 
Trading account liabilities41,386 974 2.35 45,449 1,249 2.75 50,928 1,358 2.67 
Long-term debt220,440 4,321 1.96 201,623 6,700 3.32 200,399 6,915 3.45 
Total interest-bearing liabilities1,632,807 8,225 0.50 1,502,561 22,345 1.49 1,410,318 18,607 1.32 
Noninterest-bearing sources         
Noninterest-bearing deposits555,483   401,269   425,698   
Other liabilities (6)
227,523   234,111   224,482   
Shareholders’ equity267,309   267,889   264,748   
Total liabilities and shareholders’ equity$2,683,122   $2,405,830   $2,325,246   
Net interest spread  1.75 %  2.03 %  2.08 %
Impact of noninterest-bearing sources  0.15   0.40   0.37 
Net interest income/yield on earning assets (7)
 $43,859 1.90 % $49,486 2.43 % $48,772 2.45 %
(1)Includes the impact of interest rate risk management contracts. For more information, see Interest Rate Risk Management for the Banking Book on page 82.
(2)Nonperforming loans are included in the respective average loan balances. Income on these nonperforming loans is generally recognized on a cost recovery basis.
(3)Includes non-U.S. consumer loans of $2.9 billion, $2.9 billion and $2.8 billion for 2020, 2019 and 2018, respectively.
(4)Certain prior-period amounts for 2019 have been reclassified to conform to current-period presentation.
(5)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.



Bank of America 34


Table 9Analysis of Changes in Net Interest Income - FTE Basis
 
Due to Change in (1)
Net Change
Due to Change in (1)
Net Change
VolumeRateVolumeRate
(Dollars in millions)From 2019 to 2020From 2018 to 2019
Increase (decrease) in interest income      
Interest-bearing deposits with the Federal Reserve, non-U.S. central banks and other banks$1,849 $(3,313)$(1,464)$(193)$90 $(103)
Time deposits placed and other short-term investments(13)(165)(178)— (9)(9)
Federal funds sold and securities borrowed or purchased under agreements to resell519 (4,459)(3,940)347 1,320 1,667 
Trading account assets3 (1,087)(1,084)563 (195)368 
Debt securities2,188 (4,237)(2,049)135 (55)80 
Loans and leases  
Residential mortgage563 (876)(313)447 (90)357 
Home equity(312)(592)(904)(446)67 (379)
Credit card(1,018)(389)(1,407)(17)604 587 
Direct/Indirect and other consumer(22)(694)(716)(76)233 157 
Total consumer  (3,340)  722 
U.S. commercial (2)
912 (4,361)(3,449)665 559 1,224 
Non-U.S. commercial (2)
80 (1,274)(1,194)209 (27)182 
Commercial real estate63 (1,014)(951)75 48 123 
Commercial lease financing(76)(83)(159)(28)48 20 
Total commercial  (5,753)  1,549 
Total loans and leases  (9,093)  2,271 
Other earning assets905 (2,844)(1,939)(417)595 178 
Net increase (decrease) in interest income  $(19,747)  $4,452 
Increase (decrease) in interest expense      
U.S. interest-bearing deposits      
Savings$1 $ $1 $(1)$— $(1)
Demand and money market deposit accounts507 (4,001)(3,494)254 1,581 1,835 
Consumer CDs and IRAs2 (68)(66)29 285 314 
Negotiable CDs, public funds and other deposits(39)(1,045)(1,084)320 96 416 
Total U.S. interest-bearing deposits  (4,643)  2,564 
Non-U.S. interest-bearing deposits      
Banks located in non-U.S. countries(5)(11)(16)(6)(13)(19)
Time, savings and other68 (654)(586)41 107 148 
Total non-U.S. interest-bearing deposits  (602)  129 
Total interest-bearing deposits  (5,245)  2,693 
Federal funds purchased, securities loaned or sold under agreements to repurchase, short-term borrowings and other interest-bearing liabilities451 (6,672)(6,221)160 1,209 1,369 
Trading account liabilities(111)(164)(275)(145)36 (109)
Long-term debt619 (2,998)(2,379)41 (256)(215)
Net increase (decrease) in interest expense  (14,120)  3,738 
Net increase (decrease) in net interest income (3)
  $(5,627)  $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.
35 Bank of America


Business Segment Operations
Segment Description and Basis of Presentation
We report our results of operations through the following four business segments: Consumer Banking,, GWIM,, Global Bankingand 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 andAll Otherare shown below.
bac-20201231_g1.jpg
We periodically review capital allocated to our businesses and allocate capital annually during the strategic and capital planning processes. We utilize a methodology that considers the effect of regulatory capital requirements in addition to internal risk-based capital models. Our internal risk-based capital models use a risk-adjusted methodology incorporating each segment’s credit, market, interest rate, business and operational risk components. For more information on the nature of these risks, see Managing Risk on page 41.47. 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 87 – Goodwill and Intangible Assets to the Consolidated Financial Statements.
For more information on theour presentation of financial information on an FTE basis, of presentationsee Supplemental Financial Data on page 31, and for business segments and reconciliations to consolidated total revenue, net income and year-endperiod-end total assets, seeNote 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.

Bank of America 20173036



Consumer Banking
DepositsConsumer LendingTotal Consumer Banking
(Dollars in millions)202020192020201920202019% Change
Net interest income$13,739 $16,904 $10,959 $11,254 $24,698 $28,158 (12)%
Noninterest income:
Card income(20)(33)4,693 5,117 4,673 5,084 (8)
Service charges3,416 4,216 1 3,417 4,218 (19)
All other income310 833 164 294 474 1,127 (58)
Total noninterest income3,706 5,016 4,858 5,413 8,564 10,429 (18)
Total revenue, net of interest expense17,445 21,920 15,817 16,667 33,262 38,587 (14)
Provision for credit losses379 269 5,386 3,503 5,765 3,772 53 
Noninterest expense11,508 10,718 7,370 6,928 18,878 17,646 
Income before income taxes5,558 10,933 3,061 6,236 8,619 17,169 (50)
Income tax expense1,362 2,679 750 1,528 2,112 4,207 (50)
Net income$4,196 $8,254 $2,311 $4,708 $6,507 $12,962 (50)
Effective tax rate (1)
24.5 %24.5 %
Net interest yield1.69 %2.40 %3.53 %3.80 %2.88 3.81 
Return on average allocated capital35 69 9 19 17 35 
Efficiency ratio65.97 48.90 46.60 41.56 56.76 45.73 
Balance Sheet
Average
Total loans and leases$5,144 $5,371 $310,436 $295,562 $315,580 $300,933 %
Total earning assets (2)
813,779 703,481 310,862 296,051 858,724 738,807 16 
Total assets (2)
849,924 735,298 314,599 306,169 898,606 780,742 15 
Total deposits816,968 702,972 6,698 5,368 823,666 708,340 16 
Allocated capital12,000 12,000 26,500 25,000 38,500 37,000 
Year end
Total loans and leases$4,673 $5,467 $295,261 $311,942 $299,934 $317,409 (6)%
Total earning assets (2)
899,951 724,573 295,627 312,684 945,343 760,174 24 
Total assets (2)
939,629 758,459 299,186 322,717 988,580 804,093 23 
Total deposits906,092 725,665 6,560 5,080 912,652 730,745 25 
            
 Deposits Consumer Lending Total Consumer Banking  
(Dollars in millions)20172016 20172016 20172016 % Change
Net interest income (FTE basis)$13,353
$10,701
 $10,954
$10,589
 $24,307
$21,290
 14 %
Noninterest income:          
Card income8
9
 5,062
4,926
 5,070
4,935
 3
Service charges4,265
4,141
 1
1
 4,266
4,142
 3
Mortgage banking income (1)


 481
960
 481
960
 (50)
All other income391
403
 6
1
 397
404
 (2)
Total noninterest income4,664
4,553
 5,550
5,888
 10,214
10,441
 (2)
Total revenue, net of interest expense (FTE basis)18,017
15,254
 16,504
16,477
 34,521
31,731
 9
           
Provision for credit losses201
174
 3,324
2,541
 3,525
2,715
 30
Noninterest expense10,380
9,677
 7,407
7,977
 17,787
17,654
 1
Income before income taxes (FTE basis)7,436
5,403
 5,773
5,959
 13,209
11,362
 16
Income tax expense (FTE basis)2,816
1,993
 2,186
2,197
 5,002
4,190
 19
Net income$4,620
$3,410
 $3,587
$3,762
 $8,207
$7,172
 14
           
Net interest yield (FTE basis)2.05%1.79% 4.18%4.37% 3.54%3.38%  
Return on average allocated capital39
28
 14
17
 22
21
  
Efficiency ratio (FTE basis)57.61
63.44
 44.88
48.41
 51.53
55.64
  
            
Balance Sheet           
            
Average           
Total loans and leases$5,084
$4,809
 $260,974
$240,999
 $266,058
$245,808
 8 %
Total earning assets (2)
651,963
598,043
 261,802
242,445
 686,612
629,984
 9
Total assets (2)
679,306
624,592
 273,253
254,287
 725,406
668,375
 9
Total deposits646,930
592,417
 6,390
7,234
 653,320
599,651
 9
Allocated capital12,000
12,000
 25,000
22,000
 37,000
34,000
 9
            
Year end           
Total loans and leases$5,143
$4,938
 $275,330
$254,053
 $280,473
$258,991
 8 %
Total earning assets (2)
675,485
631,172
 275,742
255,511
 709,832
662,698
 7
Total assets (2)
703,330
658,316
 287,390
268,002
 749,325
702,333
 7
Total deposits670,802
625,727
 5,728
7,059
 676,530
632,786
 7
(1)Estimated at the segment level only.
(1)
(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.

Total consolidated mortgage banking income of $224 million for 2017 was recorded primarily in Consumer Lending and All Other compared to $1.9 billion for 2016.
(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 3438 states and the District of Columbia. Our network includes approximately 4,5004,300 financial centers, 16,000 ATMs,approximately 17,000 ATMS, nationwide call centers and leading digital banking platforms with approximately 35more than 39 million active users, including approximately 2431 million active mobile active users.users.
Consumer Banking Results.
Net income for Consumer Banking increased $1.0 decreased $6.5 billion to $8.2$6.5 billion in 20172020 compared to 20162019 primarily driven by higher net interest income, partially offset bydue to lower revenue, higher provision for credit losses and lower mortgage banking income.higher expenses. Net interest income increased $3.0decreased $3.5 billion to $24.3$24.7 billion
primarily due to lower rates, partially offset by the beneficial impact of an increase in investable assets as a resultbenefit of higher deposits,deposit and loan balances. Noninterest 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 pricing disciplinelower other income due to the allocation of asset and loan growth. Noninterest income decreased $227 million to $10.2 billion driven by lower mortgage banking income, partially offset by higher card income and service charges.liability management (ALM) results.
The provision for credit losses increased $810 million$2.0 billion to $3.5$5.8 billion primarily due to portfolio seasoning and loan growth in the U.S. credit
card portfolio.weaker economic outlook related to COVID-19. Noninterest expense increased $133 million$1.2 billion to $17.8$18.9 billion primarily driven by higher personnelincremental expense includingto support customers and employees during the shared success discretionary year-end bonus, and increased FDIC
expense,pandemic, as well as the cost of increased client activity and continued investments in digital capabilities andfor business growth, including increased primary sales professionals, combined with investments in new financial centers and renovations. These increases were partially offset by improved operating efficiencies.the merchant services platform.
The return on average allocated capital was 2217 percent, updown from 2135 percent, as higherdriven by lower net income was partially offset byand, to a lesser extent, an increased capital allocation.increase in allocated capital. For more information on capital allocations,allocated to the business segments, see Business Segment Operations on page 30.36.

37 Bank of America


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

31Bank of America 2017



capabilities including access to the Corporation’s network of financial centers and ATMs.
Deposits includes the net impact of migrating customers and their related deposit and brokerage asset balances between Deposits and GWIM as well as other client-managed businesses. For more information on the migration of customer balances to or from GWIM, see GWIM – Net Migration Summary on page 35.
Net income for Deposits increased $1.2decreased $4.1 billion to $4.6$4.2 billion in 2017primarily driven by higher revenue, partially offset by higher noninterest expense.lower revenue. Net interest income increased $2.7declined $3.2 billion to $13.4$13.7 billion primarily due to lower interest rates, partially offset by the beneficialbenefit 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 an increase in investable assetsCOVID-19, as a resultwell as lower other income due to the allocation of higher deposits, and pricing discipline. Noninterest income increased $111 million to $4.7 billion driven by higher service charges.ALM results.
The provision for credit losses increased $27$110 million to $201$379 million in 2017.2020 due to the weaker economic outlook related to COVID-19. Noninterest expense increased $703$790 million to $10.4$11.5 billion primarily driven by continued investments in digital capabilitiesthe business and business growth, including increased primary sales professionals, combined with investments in new financial centersincremental expense to support customers and renovations, higher personnel expense, includingemployees during the shared success discretionary year-end bonus, and increased FDIC expense.pandemic.
Average deposits increased $54.5$114.0 billion to $646.9$817.0 billion in 20172020 driven by strong organic growth. Growthgrowth of $79.3 billion in checking and time deposits and $34.4 billion in traditional savings and money market savingssavings.

The following table provides key performance indicators for Deposits. Management uses these metrics, and traditional savings of $57.9 billion was partially offset by a declinewe believe they are useful to investors because they provide additional information to evaluate our deposit profitability and digital/mobile trends.
Key Statistics – Deposits
20202019
Total deposit spreads (excludes noninterest costs) (1)
1.94%2.34%
Year End
Consumer investment assets (in millions) (2)
$306,104$240,132
Active digital banking users (units in thousands) (3)
39,31538,266
Active mobile banking users (units in thousands) (4)
30,78329,174
Financial centers4,3124,300
ATMs16,90416,788
(1)Includes deposits held in time deposits of $3.5 billion.Consumer Lending.
    
Key Statistics  Deposits
   
    
 2017 2016
Total deposit spreads (excludes noninterest costs) (1)
1.84% 1.65%
    
Year end   
Client brokerage assets (in millions)$177,045
 $144,696
Digital banking active users (units in thousands) (2)
34,855
 32,942
Mobile banking active users (units in thousands)24,238
 21,648
Financial centers4,470
 4,579
ATMs16,039
 15,928
(1)
Includes deposits held in Consumer Lending.
(2)
Digital users represents mobile and/or online users across consumer businesses; historical information has been reclassified primarily due to the sale of the Corporation’s non-U.S. consumer credit card business in 2017.
Client(2)Includes client brokerage assets, deposit sweep balances and AUM in Consumer Banking.
(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 $32.3$66.0 billion in 2020 driven by strongmarket performance and client flows and market performance. Mobileflows. Active mobile banking active users increased 2.6approximately two million reflecting continuing changes in our customers’ banking preferences. The numberWe had a net increase of 12 financial centers
declined 109 driven by changes in customer preferences to self-service options as we continuecontinued to optimize our consumer banking network and improve our cost-to-serve.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 card fees,
mortgage banking fee income and other miscellaneous fees. Consumer Lending products are available to our customers through our retail network, direct telephone, and online and mobile channels. Consumer Lending results also include the impact of servicing residential mortgages and home equity loans in the core portfolio, including loans held on the balance sheet of Consumer Lending and loans serviced for others.
We classify consumer real estate loans as core or 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. For more information on the core and non-core portfolios, see Consumer Portfolio Credit Risk Management on page 54. Total owned loans in the core portfolio held in Consumer Lending increased $14.7 billion to $115.9 billion in 2017, primarily driven by higher residential mortgage balances, partially offset by a decline in home equity balances.
Consumer Lending includes the net impact of migrating customers and their related loan balances between Consumer Lending and GWIM. For more information on the migration of customer balances to or from GWIM, see GWIM – Net Migration Summary on page 35.
Bank of America 38


Net income for Consumer Lending decreased $175 millionwas $2.3 billion, a decrease of $2.4 billion, primarily due to $3.6 billion in 2017 driven by higher provision for credit losses and lower noninterest income, partially offset by lower noninterest expense and higher net interest income.losses. Net interest income increased $365declined $295 million to $11.0 billion primarily drivendue to lower interest rates, partially offset by the impact of an increase in loan balances.growth. Noninterest income decreased $338$555 million to $5.6$4.9 billion primarily driven by lower mortgage bankingcard income partially offset by higher 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 $783 million$1.9 billion to $3.3$5.4 billion in 2017primarily due to portfolio seasoning and loan growth in the U.S. credit card portfolio.weaker economic outlook related to COVID-19. Noninterest expense decreased $570increased $442 million to $7.4 billion primarily driven by improved operating efficiencies.investments in the business and incremental expense to support customers and employees during the pandemic.
Average loans increased $20.0$14.9 billion to $261.0$310.4 billion in 2017primarily driven by increasesan increase in residential mortgages as well as consumer vehicle and U.S credit cardPPP loans, partially offset by lower home equitya 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 balances.growth and profitability.
Key Statistics – Consumer Lending
(Dollars in millions)20202019
Total credit card (1)
Gross interest yield (2)
10.27 %10.76 %
Risk-adjusted margin (3)
9.16 8.28 
New accounts (in thousands)2,505 4,320 
Purchase volumes$251,599 $277,852 
Debit card purchase volumes$384,503 $360,672 
(1)Includes GWIM's credit card portfolio.
(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.


    
Key Statistics  Consumer Lending
    
(Dollars in millions)2017 2016
Total U.S. credit card (1)
   
Gross interest yield9.65% 9.29%
Risk-adjusted margin8.67
 9.04
New accounts (in thousands)4,939
 4,979
Purchase volumes$244,753
 $226,432
Debit card purchase volumes$298,641
 $285,612
(1)
In addition to the U.S. credit card portfolio in Consumer Banking, the remaining U.S. credit card portfolio is in GWIM.
During 2017,2020, the total U.S. credit card risk-adjusted margin decreased 37increased 88 bps compared to 2016, primarily2019 driven by compressed margins, increaseda lower mix of customer balances at promotional rates, the lower interest rate environment and lower net charge-offs and higher credit card rewards costs.losses. Total U.S. credit card purchase volumes increased $18.3declined $26.3 billion to $244.8 billion,$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 $13.0$23.8 billion to $298.6$384.5 billion, reflecting higher levelsdespite COVID-19 impacts. Debit card purchase volumes improved in the second half of consumer spending.2020 as businesses reopened and spending improved.
Key Statistics – Residential Mortgage Loan Production (1)
(Dollars in millions)20202019
Consumer Banking:
First mortgage$43,197 $49,179 
Home equity6,930 9,755 
Total (2):
First mortgage$69,086 $72,467 
Home equity8,160 11,131 
(1)The loan production amounts represent the unpaid principal balance of loans and, in the case of home equity, the principal amount of the total line of credit.
(2)In addition to loan production in Consumer Banking, there is also first mortgage and home equity loan production in GWIM.
First mortgage loan originations in Consumer Banking and for the total Corporation 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.


Bank of America 201732


Mortgage Banking Income
Mortgage banking income in Consumer Banking includes production income and net servicing income. Production income is comprised primarily of revenue from the fair value gains and losses recognized on our interest rate lock commitments (IRLCs) and loans held-for-sale (LHFS), the related secondary market execution, and costs related to representations and warranties made in the sales transactions along with other obligations incurred in the sales of mortgage loans. Production income decreased $461 million to $202 million in 2017 due to a decision to retain a higher percentage of residential mortgage production in Consumer Banking, as well as the impact of a higher interest rate environment driving lower refinances.
Net servicing income within Consumer Banking includes income earned in connection with servicing activities and MSR valuation adjustments for the core portfolio, net of results from risk management activities used to hedge certain market risks of the MSRs. Net servicing income decreased $18 million to $279 million in 2017 reflecting the decline in the size of the servicing portfolio.
Mortgage Servicing Rights
At December 31, 2017, the core MSR portfolio, held within Consumer Lending, was $1.7 billion compared to $2.1 billion at December 31, 2016. The decrease was primarily driven by the amortization of expected cash flows, which exceeded additions to
the MSR portfolio, partially offset by the impact of changes in fair value from rising interest rates. For more information on MSRs, see Note 20 – Fair Value Measurements to the Consolidated Financial Statements.
    
Key Statistics - Mortgage Banking   
    
(Dollars in millions)2017 2016
Loan production (1):
 
  
Total (2):
   
First mortgage$50,581
 $64,153
Home equity16,924
 15,214
Consumer Banking:   
First mortgage$34,065
 $44,510
Home equity15,199
 13,675
(1)
The loan production amounts represent the unpaid principal balance of loans and in the case of home equity, the principal amount of the total line of credit.
(2)
In addition to loan production in Consumer Banking, there is also first mortgage and home equity loan production in GWIM.
First mortgage loan originations in Consumer Banking and for the total Corporation decreased $10.4 billion and $13.6 billion in 2017, primarily driven by a higher interest rate environment driving lower first-lien mortgage refinances.
Home equity production in Consumer Banking and for the total Corporation increased $1.5 billion and $1.7 billion in 2017 due to a higher demand based on improving housing trends, and improved engagement with customers.
Global Wealth & Investment Management
       
(Dollars in millions)2017 2016 % Change
Net interest income (FTE basis)$6,173
 $5,759
 7%
Noninterest income:     
Investment and brokerage services10,883
 10,316
 5
All other income1,534
 1,575
 (3)
Total noninterest income12,417
 11,891
 4
Total revenue, net of interest expense (FTE basis)18,590
 17,650
 5
      
Provision for credit losses56
 68
 (18)
Noninterest expense13,564
 13,175
 3
Income before income taxes (FTE basis)4,970
 4,407
 13
Income tax expense (FTE basis)1,882
 1,632
 15
Net income$3,088
 $2,775
 11
      
Net interest yield (FTE basis)2.32% 2.09%  
Return on average allocated capital22
 21
  
Efficiency ratio (FTE basis)72.96
 74.65
  
      
Balance Sheet      
    
Average     
Total loans and leases$152,682
 $142,429
 7 %
Total earning assets265,670
 275,799
 (4)
Total assets281,517
 291,478
 (3)
Total deposits245,559
 256,425
 (4)
Allocated capital14,000
 13,000
 8
      
Year end     
Total loans and leases$159,378
 $148,179
 8 %
Total earning assets267,026
 283,151
 (6)
Total assets284,321
 298,931
 (5)
Total deposits246,994
 262,530
 (6)

3339Bank of America 2017




Global Wealth & Investment Management
(Dollars in millions)20202019% Change
Net interest income$5,468 $6,504 (16)%
Noninterest income:
Investment and brokerage services12,270 11,870 
All other income846 1,164 (27)
Total noninterest income13,116 13,034 
Total revenue, net of interest expense18,584 19,538 (5)
Provision for credit losses357 82 n/m
Noninterest expense14,154 13,825 
Income before income taxes4,073 5,631 (28)
Income tax expense998 1,380 (28)
Net income$3,075 $4,251 (28)
Effective tax rate24.5 %24.5 %
Net interest yield1.73 2.33 
Return on average allocated capital21 29 
Efficiency ratio76.16 70.76 
Balance Sheet
Average
Total loans and leases$183,402 $168,910 %
Total earning assets316,008 279,681 13 
Total assets328,384 292,016 12 
Total deposits287,123 256,516 12 
Allocated capital15,000 14,500 
Year end
Total loans and leases$188,562 $176,600 %
Total earning assets356,873 287,201 24 
Total assets369,736 299,770 23 
Total deposits322,157 263,113 22 
n/m = not meaningful
GWIM consists of two primary businesses: Merrill Lynch Global Wealth Management (MLGWM) andU.S. Trust, Bank of America Private Wealth Management (U.S. Trust).Bank.
MLGWM’sMLGWM'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 our clients’clients' needs through a full set of investment management, brokerage, banking and retirement products.
U.S. Trust,Bank of America Private Bank, together with MLGWM’sMLGWM's Private Banking & Investments Group,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’clients' wealth structuring, investment management, trust and banking needs, including specialty asset management services.
Net income for GWIM increased$313 million decreased $1.2 billion to $3.1 billion in 2017 compared to 2016primarily due to lower net interest income, higher revenue, partially offset by an increase in noninterest expense. The operating margin was 27 percent compared to 25 percent a year ago.expense and higher provision for credit losses.
Net interest income increased $414 milliondecreased $1.0 billion to $6.2$5.5 billion drivendue to the impact of lower interest rates, partially offset by higher short-term interest rates. the benefit of strong deposit and loan growth.

Noninterest income, which primarily includes investment and brokerage services income, increased $526$82 million to $12.4 billion. $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 noninterest income wasallocated 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 AUM flows and higher market valuations,lower interest rates, partially offset by the impactbenefits of changing market dynamics on transactional revenue and AUM pricing. Noninterest expense increased $389 million to $13.6 billion primarily driven by higher revenue-related incentive costs.
Return on average allocated capital was 22 percent in 2017, up from 21 percent a year ago, as higher net income was partially offset by an increased capital allocation.
Revenue from MLGWM of $15.3 billion increased six percent in 2017 compared to 2016 due to higher net interest income and asset management fees driven by AUM flows and higher market valuations partially offset by lower transactional revenue and positive AUM pricing. U.S. Trustflows.
Bank of America Private Bank revenue of $3.3 billion increased sevendecreased four percent in 2017 compared to 2016 reflecting higher net interest income and asset management feesprimarily driven by higher market valuations and AUM flows.the impact of lower interest rates.
    
Key Indicators and Metrics   
    
(Dollars in millions, except as noted)2017 2016
Revenue by Business   
Merrill Lynch Global Wealth Management$15,288
 $14,486
U.S. Trust3,295
 3,075
Other (1)
7
 89
Total revenue, net of interest expense (FTE basis)$18,590
 $17,650
    
Client Balances by Business, at year end   
Merrill Lynch Global Wealth Management$2,305,664
 $2,102,175
U.S. Trust446,199
 406,392
Total client balances$2,751,863
 $2,508,567
    
Client Balances by Type, at year end   
Assets under management$1,080,747
 $886,148
Brokerage assets1,125,282
 1,085,826
Assets in custody136,708
 123,066
Deposits246,994
 262,530
Loans and leases (2)
162,132
 150,997
Total client balances$2,751,863
 $2,508,567
    
Assets Under Management Rollforward   
Assets under management, beginning of year$886,148
 $900,863
Net client flows (3)
95,707
 30,582
Market valuation/other (1)
98,892
 (45,297)
Total assets under management, end of year$1,080,747
 $886,148
    
Associates, at year end (4, 5)
   
Number of financial advisors17,355
 16,820
Total wealth advisors, including financial advisors19,238
 18,678
Total primary sales professionals, including financial advisors and wealth advisors20,341
 19,629
    
Merrill Lynch Global Wealth Management Metric (5)
   
Financial advisor productivity (6) (in thousands)
$1,005
 $974
    
U.S. Trust Metric, at year end (5)
   
Primary sales professionals1,714
 1,677
(1)
Amounts for 2016 include the results of BofA Global Capital Management, the cash management division of Bank of America, and certain administrative items. Amounts also reflect the sale to a third party of approximately $80 billion of BofA Global Capital Management’s AUM in 2016.
(2)
Includes margin receivables which are classified in customer and other receivables on the Consolidated Balance Sheet.
(3)
For 2016, net client flows included $8.0 billion of net outflows related to BofA Global Capital Management’s AUM that were sold in 2016.
(4)
Includes financial advisors in the Consumer Banking segment of 2,402 and 2,200 at December 31, 2017 and 2016.
(5)
Associate computation is based on headcount.
(6)
Financial advisor productivity is defined as MLGWM total revenue, excluding the allocation of certain asset and liability management (ALM) activities, divided by the total average number of financial advisors (excluding financial advisors in the Consumer Banking segment).

Bank of America 20173440



Key Indicators and Metrics
(Dollars in millions, except as noted)20202019
Revenue by Business
Merrill Lynch Global Wealth Management$15,292 $16,112 
Bank of America Private Bank3,292 3,426 
Total revenue, net of interest expense$18,584 $19,538 
Client Balances by Business, at year end
Merrill Lynch Global Wealth Management$2,808,340 $2,558,102 
Bank of America Private Bank541,464 489,690 
Total client balances$3,349,804 $3,047,792 
Client Balances by Type, at year end
Assets under management$1,408,465 $1,275,555 
Brokerage and other assets1,479,614 1,372,733 
Deposits322,157 263,103 
Loans and leases (1)
191,124 179,296 
Less: Managed deposits in assets under management(51,556)(42,895)
Total client balances$3,349,804 $3,047,792 
Assets Under Management Rollforward
Assets under management, beginning of year$1,275,555 $1,072,234 
Net client flows19,596 24,865 
Market valuation/other
113,314 178,456 
Total assets under management, end of year$1,408,465 $1,275,555 
Associates, at year end
Number of financial advisors17,331 17,458 
Total wealth advisors, including financial advisors19,373 19,440 
Total primary sales professionals, including financial advisors and wealth advisors21,213 20,586 
Merrill Lynch Global Wealth Management Metric
Financial advisor productivity (2) (in thousands)
$1,126 $1,082 
Bank of America Private Bank Metric, at year end
Primary sales professionals1,759 1,766 
(1)Includes margin receivables which are classified in customer and other receivables on the Consolidated Balance Sheet.
(2)For a definition, see Key Metrics on page 173.
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 and generally range from 50 to 150 bps on their total AUM.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 $243.3$302.0 billion, or 10 percent, in 2017 to nearly $2.8$3.3 trillion at December 31, 2017,2020 compared to December 31, 2019. The increase in client balances was primarily due to AUM which increased $194.6 billion, or 22 percent, due to positive net flows and higher market valuations.valuations and positive client flows.
Net Migration Summary
GWIM results are impacted by the net migration of clients and their corresponding deposit, loan and brokerage balances primarily from Consumer Banking, as presented in the table below. Migrations result from the movement of clients between business segments to better align with client needs.
    
Net Migration Summary (1)
   
    
(Dollars in millions)2017 2016
Total deposits, net – from GWIM
$356
 $1,319
Total loans, net – from GWIM
154
 7
Total brokerage, net – from GWIM
266
 1,972
(1)41 Bank of America
Migration occurs primarily between GWIM and Consumer Banking.


Global Banking
(Dollars in millions)20202019% Change
Net interest income$9,013 $10,675 (16)%
Noninterest income:
Service charges3,238 3,015 
Investment banking fees4,010 3,137 28 
All other income2,726 3,656 (25)
Total noninterest income9,974 9,808 
Total revenue, net of interest expense18,987 20,483 (7)
Provision for credit losses4,897 414 n/m
Noninterest expense9,337 9,011 
Income before income taxes4,753 11,058 (57)
Income tax expense1,283 2,985 (57)
Net income$3,470 $8,073 (57)
Effective tax rate27.0 %27.0 %
Net interest yield1.86 2.75 
Return on average allocated capital8 20 
Efficiency ratio49.17 43.99 
Balance Sheet
Average
Total loans and leases
$382,264 $374,304 %
Total earning assets485,688 388,152 25 
Total assets542,302 443,083 22 
Total deposits456,562 362,731 26 
Allocated capital42,500 41,000 
Year end
Total loans and leases$339,649 $379,268 (10)%
Total earning assets522,650 407,180 28 
Total assets580,561 464,032 25 
Total deposits493,748 383,180 29 
       
(Dollars in millions)2017 2016 % Change
Net interest income (FTE basis)$10,504
 $9,471
 11 %
Noninterest income:     
Service charges3,125
 3,094
 1
Investment banking fees3,471
 2,884
 20
All other income2,899
 2,996
 (3)
Total noninterest income9,495
 8,974
 6
Total revenue, net of interest expense (FTE basis)19,999
 18,445
 8
      
Provision for credit losses212
 883
 (76)
Noninterest expense8,596
 8,486
 1
Income before income taxes (FTE basis)11,191
 9,076
 23
Income tax expense (FTE basis)4,238
 3,347
 27
Net income$6,953
 $5,729
 21
      
Net interest yield (FTE basis)2.93% 2.76%  
Return on average allocated capital17
 15
  
Efficiency ratio (FTE basis)42.98
 46.01
  
      
Balance Sheet      
    
Average     
Total loans and leases$346,089
 $333,820
 4 %
Total earning assets358,302
 342,859
 5
Total assets416,038
 396,737
 5
Total deposits312,859
 304,741
 3
Allocated capital40,000
 37,000
 8
      
Year end     
Total loans and leases$350,668
 $339,271
 3 %
Total earning assets365,560
 350,110
 4
Total assets424,533
 408,330
 4
Total deposits329,273
 307,630
 7
n/m = not meaningful
Global Banking, which includes Global Corporate Banking, Global Commercial Banking, Business Banking and Global Investment Banking, provides a wide range of lending-related products and services, integrated working capital management and treasury solutions, and underwriting and advisory services through our network of offices and client relationship teams. Our lending products and services include commercial loans, leases, commitment facilities, trade finance, commercial real estate lending and asset-based lending. Our treasury solutions business includes treasury management, foreign exchange, and short-term investing options.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. Global Corporate Banking clients generally include large global corporations, financial institutions and leasing clients. Business Banking clients include mid-sized U.S.-based businesses requiring customized and integrated financial advice and solutions.
Net income for Global Banking increased $1.2 decreased $4.6 billion to $7.0$3.5 billion in 2017 compared to 2016primarily driven by higher revenue and lower provision for credit losses.losses as well as lower revenue.
Revenue increased $1.6decreased $1.5 billion to $20.0$19.0 billion in 2017 compared to 2016 driven by higherlower net interest income and noninterest income. Net interest income increased $1.0 decreased $1.7
billion to $10.5$9.0 billion due toprimarily driven by lower interest rates, partially offset by higher loan and deposit-related growth,deposit balances.
Noninterest income of $10.0 billion increased $166 million driven by higher short-

35Bank of America 2017



term ratesinvestment banking fees, partially offset by lower valuation driven adjustments on an increased deposit basethe fair value loan portfolio, debt securities and the impact ofleveraged loans, as well as the allocation of ALM activities, partially offset by credit spread compression. Noninterest income increased $521 million to $9.5 billion largely due to higher investment banking fees.results.
The provision for credit losses decreased$671 millionincreased $4.5 billion to $212 million in 2017$4.9 billion primarily driven by reductions in energy exposures and continued portfolio improvement, partially offset by Global Banking’s portion of a single-name non-U.S. commercial charge-off.due to the weaker economic outlook related to COVID-19. Noninterest expense increased $110$326 million primarily due to $8.6 billion in 2017 primarily driven by highercontinued investments in technology and higher deposit insurance,the business, partially offset by lower litigation costs.revenue-related incentives.
The return on average allocated capital was 17eight percent up from 15in 2020 compared to 20 percent as higherin 2019 due to lower net income was partially offset byand, to a lesser extent, an increased capital allocation.increase in allocated capital. For more information on capital allocated to the business segments, see Business Segment Operations on page 30.36.
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.

Bank of America 42


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 BankingGlobal Corporate, Global Commercial and Business Banking
                
Global Corporate, Global Commercial and Business Banking            
               Global Corporate BankingGlobal Commercial BankingBusiness BankingTotal
 Global Corporate Banking Global Commercial Banking Business Banking Total
(Dollars in millions)(Dollars in millions)2017 2016 2017 2016 2017 2016 2017 2016(Dollars in millions)20202019202020192020201920202019
RevenueRevenue               Revenue
Business LendingBusiness Lending$4,387
 $4,285
 $4,280
 $4,139
 $404
 $376
 $9,071
 $8,800
Business Lending$3,552 $3,994 $3,743 $4,132 $261 $363 $7,556 $8,489 
Global Transaction ServicesGlobal Transaction Services3,322
 2,996
 3,017
 2,718
 849
 740
 7,188
 6,454
Global Transaction Services2,986 3,994 3,169 3,499 893 1,064 7,048 8,557 
Total revenue, net of interest expenseTotal revenue, net of interest expense$7,709
 $7,281
 $7,297
 $6,857
 $1,253
 $1,116
 $16,259
 $15,254
Total revenue, net of interest expense$6,538 $7,988 $6,912 $7,631 $1,154 $1,427 $14,604 $17,046 
               
Balance Sheet                Balance Sheet
                
AverageAverage               Average
Total loans and leasesTotal loans and leases$158,292
 $152,944
 $170,101
 $163,309
 $17,682
 $17,537
 $346,075
 $333,790
Total loans and leases
$179,393 $177,713 $182,212 $181,485 $14,410 $15,058 $376,015 $374,256 
Total depositsTotal deposits148,704
 143,233
 127,720
 126,253
 36,435
 35,256
 312,859
 304,742
Total deposits216,371 177,924 191,813 144,620 48,214 40,196 456,398 362,740 
               
Year endYear end               Year end
Total loans and leasesTotal loans and leases$163,184
 $152,589
 $169,997
 $168,828
 $17,500
 $17,882
 $350,681
 $339,299
Total loans and leases$153,126 $181,409 $164,641 $182,727 $13,242 $15,152 $331,009 $379,288 
Total depositsTotal deposits155,614
 144,016
 137,538
 128,210
 36,120
 35,409
 329,272
 307,635
Total deposits233,484 185,352 207,597 157,322 52,150 40,504 493,231 383,178 
Business Lending revenue increased $271decreased $933 million in 20172020 compared to 20162019. The decrease was primarily driven by the impact of loan and lease-related growth and the allocation of ALM activities, partially offset by credit spread compression.lower interest rates.
Global Transaction Services revenue increased $734 milliondecreased $1.5 billion in 20172020 compared to 20162019 driven by the allocation of ALM results, partially offset by the impact of higher short-term rates on an increased deposit base, as well as the allocation of ALM activities.balances.
Average loans and leases increased four percentwere relatively flat in 20172020 compared to 2016 driven by growth in the commercial and industrial, and leasing portfolios.2019. Average deposits increased three26 percent primarily due to growth with newclient responses to market volatility, government stimulus and existing clients.placement of credit draws.
Global Investment Banking
Client teams and product specialists underwrite and distribute debt, equity and loan products, and provide advisory services and tailored risk management solutions. The economics of certain investment banking and underwriting activities are shared primarily between Global Banking and Global Markets under an internal revenue-sharing arrangement. Global Banking originates certain deal-related transactions with our corporate and commercial clients that are executed and distributed by Global Markets. To provide a complete discussion of our
consolidated investment banking fees, the following table
presents total Corporation investment banking fees and the portion attributable to Global Banking.
Investment Banking Fees
Global BankingTotal Corporation
(Dollars in millions)2020201920202019
Products
Advisory$1,458 $1,336 $1,621 $1,460 
Debt issuance1,555 1,348 3,443 3,107 
Equity issuance997 453 2,328 1,259 
Gross investment banking fees4,010 3,137 7,392 5,826 
Self-led deals(93)(62)(212)(184)
Total investment banking fees$3,917 $3,075 $7,180 $5,642 
        
Investment Banking Fees      
    
 Global Banking Total Corporation
(Dollars in millions)2017 2016 2017 2016
Products       
Advisory$1,557
 $1,156
 $1,691
 $1,269
Debt issuance1,506
 1,407
 3,635
 3,276
Equity issuance408
 321
 940
 864
Gross investment banking fees3,471
 2,884
 6,266
 5,409
Self-led deals(113) (49) (255) (168)
Total investment banking fees$3,358
 $2,835
 $6,011
 $5,241
Total Corporation investment banking fees, excluding self-led deals, of $6.0$7.2 billion, which are primarily included within Global Banking and Global Markets, increased 1527 percent in 2017 compared to 2016primarily driven by higher advisory fees and higher debt and equity issuance fees due to an increase in overall client activity and market fee pools.

fees.

43Bank of America 201736




Global Markets
       
(Dollars in millions)2017 2016 % Change
Net interest income (FTE basis)$3,744
 $4,558
 (18)%
Noninterest income:     
Investment and brokerage services2,049
 2,102
 (3)
Investment banking fees2,476
 2,296
 8
Trading account profits6,710
 6,550
 2
All other income972
 584
 66
Total noninterest income12,207
 11,532
 6
Total revenue, net of interest expense (FTE basis)15,951
 16,090
 (1)
      
Provision for credit losses164
 31
 n/m
Noninterest expense10,731
 10,169
 6
Income before income taxes (FTE basis)5,056
 5,890
 (14)
Income tax expense (FTE basis)1,763
 2,072
 (15)
Net income$3,293
 $3,818
 (14)
      
Return on average allocated capital9% 10%  
Efficiency ratio (FTE basis)67.28
 63.21
  
      
Balance Sheet      
    
Average     
Trading-related assets:     
Trading account securities$216,996
 $185,135
 17 %
Reverse repurchases101,795
 89,715
 13
Securities borrowed82,210
 87,286
 (6)
Derivative assets40,811
 50,769
 (20)
Total trading-related assets (1)
441,812
 412,905
 7
Total loans and leases71,413
 69,641
 3
Total earning assets (1)
449,441
 423,579
 6
Total assets638,674
 585,341
 9
Total deposits32,864
 34,250
 (4)
Allocated capital35,000
 37,000
 (5)
      
Year end     
Total trading-related assets (1)
$419,375
 $380,562
 10 %
Total loans and leases76,778
 72,743
 6
Total earning assets (1)
449,314
 397,022
 13
Total assets629,007
 566,060
 11
Total deposits34,029
 34,927
 (3)
(1)
Global Markets
(Dollars in millions)20202019% Change
Net interest income$4,646 $3,915 19 %
Noninterest income:
Investment and brokerage services1,973 1,738 14 
Investment banking fees2,991 2,288 31 
Market making and similar activities8,471 7,065 20 
All other income685 608 13 
Total noninterest income14,120 11,699 21 
Total revenue, net of interest expense18,766 15,614 20 
Provision for credit losses251 (9)n/m
Noninterest expense11,422 10,728 
Income before income taxes7,093 4,895 45 
Income tax expense1,844 1,395 32 
Net income$5,249 $3,500 50 
Effective tax rate26.0 %28.5 %
Return on average allocated capital15 10 
Efficiency ratio60.86 68.71 
Balance Sheet
Average
Trading-related assets:
Trading account securities$243,519 $246,336 (1)%
Reverse repurchases104,697 116,883 (10)
Securities borrowed87,125 83,216 
Derivative assets47,655 43,273 10 
Total trading-related assets482,996 489,708 (1)
Total loans and leases73,062 71,334 
Total earning assets482,171 476,225 
Total assets685,047 679,300 
Total deposits47,400 31,380 51 
Allocated capital36,000 35,000 
Year end
Total trading-related assets$421,698 $452,499 (7)%
Total loans and leases78,415 72,993 
Total earning assets447,350 471,701 (5)
Total assets616,609 641,809 (4)
Total deposits53,925 34,676 56 
Trading-related assets include derivative assets, which are considered non-earning assets.
n/m = not meaningful
Global Markets offers sales and trading services includingand research services to institutional clients across fixed-income, credit, currency, commodity and equity businesses. Global Markets product coverage includes securities and derivative products in both the primary and secondary markets. Global Markets provides market-making, financing, securities clearing, settlement and custody services globally to our institutional investor clients in support of their investing and trading activities. We also work with our commercial and corporate clients to provide risk management products using interest rate, equity, credit, currency and commodity derivatives, foreign exchange, fixed-income and mortgage-related products. As a result of our market-making activities in these products, we may be required to manage risk in a broad range of financial products including government securities, equity and equity-linked securities, high-grade and high-yield corporate debt securities, syndicated loans, MBS, commodities and asset-backed securities. The economics of certain investment banking and underwriting activities are shared primarily between Global Markets and Global Banking under an 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. For information on investment banking fees on a consolidated basis, see page 36.43.
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 31.
Net income for Global Markets decreased $525 millionincreased $1.7 billion to $3.3 billion in 2017 compared to 2016.$5.2 billion. Net DVA losses were $428$133 million compared to losses of $238$222 million in 2016.2019. Excluding net DVA, net income decreased $408 millionincreased $1.7 billion to $3.6$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 noninterest expense, lower sales and trading revenue and an increase in the provision for credit losses, partially offset by higher investment banking fees.
Sales and trading revenue increased $2.3 billion, and excluding net DVA, decreased $423 million primarily due to weaker performance in rates productsincreased $2.2 billion. These increases were driven by higher revenue across FICC and emerging markets. Equities.
The provision for credit losses increased $133$260 million primarily due to $164 million, reflecting Global Markets’ portion of a single-name non-U.S. commercial charge-off.the weaker economic outlook related to COVID-19. Noninterest expense increased $562$694 million to $10.7 billion primarily due to higher litigation expense and continued investments in technology.
Average trading-related assets increased $28.9 billion to $441.8 billion in 2017 primarily driven by targeted growth in client financing activities in the global equities business. Year-end

37Bank of America 201744




trading-related$11.4 billion driven by higher activity-based expenses for both card and trading.
Average total assets increased $38.8$5.7 billion to $419.4$685.0 billion at December 31, 2017 driven by additionalhigher 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 meet expected client demand as well as targeted growth in client financing activities in the global equities business.stock positions.
The return on average allocated capital decreased to ninewas 15 percent, up from 10 percent, reflecting lowerhigher net income, partially offset by a decreasean increase in average 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, residential mortgage-backed securities, collateralized loan obligations, interest rate and credit derivative contracts), currencies (interest rate and foreign exchange contracts), commodities (primarily futures, forwards, swaps and options) and equities (equity-linked derivatives and cash equity activity). The following table and related discussion present sales and trading revenue, substantially all of which is in Global Markets, with the remainder in Global Banking. In addition, the following table and related discussion present sales and trading revenue,
excluding the impact of net DVA, which is a non-GAAP financial measure. We believeFor more information on net DVA, see Supplemental Financial Data on page 31.
Sales and Trading Revenue (1, 2, 3)
(Dollars in millions)20202019
Sales and trading revenue
Fixed income, currencies and commodities$9,595 $8,189 
Equities5,422 4,493 
Total sales and trading revenue$15,017 $12,682 
Sales and trading revenue, excluding net DVA (4)
Fixed income, currencies and commodities$9,725 $8,397 
Equities5,425 4,507 
Total sales and trading revenue, excluding net DVA$15,150 $12,904 
(1)For more information on sales and trading revenue, see Note 3 – Derivatives to the useConsolidated Financial Statements.
(2)Includes FTE adjustments of this non-GAAP financial measure provides additional useful information to assess the underlying performance$196 million and $187 million for 2020 and 2019.
(3)    Includes Global Banking sales and trading revenue of these businesses$478 million and to allow better comparison of year-over-year operating performance.
$538 million for 2020 and 2019.
    
Sales and Trading Revenue (1, 2)
   
    
(Dollars in millions)2017 2016
Sales and trading revenue   
Fixed-income, currencies and commodities$8,665
 $9,373
Equities4,112
 4,017
Total sales and trading revenue$12,777
 $13,390
    
Sales and trading revenue, excluding net DVA (3)
   
Fixed-income, currencies and commodities$9,059
 $9,611
Equities4,146
 4,017
Total sales and trading revenue, excluding net DVA$13,205
 $13,628
(1)
Includes FTE adjustments of $236 million and $186 million for 2017 and 2016. For more information on sales and trading revenue, see Note 2 – Derivatives to the Consolidated Financial Statements.
(2)
Includes Global Banking sales and trading revenue of $236 million and $406 million for 2017 and 2016.
(3)
(4)    FICC and Equities sales and trading revenue, excluding net DVA, is a non-GAAP financial measure. FICC net DVA losses were $394 million and $238 million for 2017 and 2016. Equities net DVA losses were $34 million and $0 for 2017 and 2016.
The following explanations for year-over-year changes in sales and trading, FICC and Equities revenue, would be the same if net DVA was included. FICC revenue, excluding net DVA, decreased $552is a non-GAAP financial measure. FICC net DVA losses were $130 million from 2016 primarily due to lower revenue in rates products and emerging markets as lower volatility led to reduced client flow. The decline in $208 million for 2020 and 2019. Equities net DVA losses were $3 million and $14 million for 2020 and 2019.
FICC revenue was also impacted by higher funding costs which wereincreased $1.3 billion driven by increases in market interest rates.increased client activity and improved market-making conditions across macro products. Equities revenue excluding net DVA, increased $129$918 million from 2016 due to higher revenue from the growthdriven by increased client activity and a strong trading performance in client financing activities which was partially offset by lower revenue in cash and derivative trading due to lower levels of volatility and client activity. a more volatile market environment.
All Other
(Dollars in millions)20202019% Change
Net interest income$34 $234 (85)%
Noninterest income (loss)(3,606)(2,617)38 
Total revenue, net of interest expense(3,572)(2,383)50 
Provision for credit losses50 (669)(107)
Noninterest expense1,422 3,690 (61)
Loss before income taxes(5,044)(5,404)(7)
Income tax benefit(4,637)(4,048)15 
Net loss$(407)$(1,356)(70)
Balance Sheet
Average
Total loans and leases$28,159 $42,935 (34)%
Total assets (1)
228,783 210,689 
Total deposits18,247 21,359 (15)
Year end
Total loans and leases$21,301 $37,156 (43)%
Total assets (1)
264,141 224,375 18 
Total deposits12,998 23,089 (44)
       
(Dollars in millions)2017 2016 % Change
Net interest income (FTE basis)$864
 $918
 (6)%
Noninterest income:     
Card income69
 189
 (63)
Mortgage banking income (loss)(263) 889
 (130)
Gains on sales of debt securities255
 490
 (48)
All other loss(1,709) (1,801) (5)
Total noninterest income (loss)(1,648) (233) n/m
Total revenue, net of interest expense (FTE basis)(784) 685
 n/m
      
Provision for credit losses(561) (100) n/m
Noninterest expense4,065
 5,599
 (27)
Loss before income taxes (FTE basis)(4,288) (4,814) (11)
Income tax expense (benefit) (FTE basis)(979) (3,142) (69)
Net loss$(3,309) $(1,672) 98
       
Balance Sheet (1)
      
       
Average      
Total loans and leases$82,489
 $108,735
 (24)%
Total assets (1)
206,998
 248,287
 (17)
Total deposits25,194
 27,494
 (8)
       
Year end      
Total loans and leases (2)
$69,452
 $96,713
 (28)%
Total assets (1)
194,048
 212,413
 (9)
Total deposits22,719
 23,061
 (1)
(1)
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. Allocated assets were $515.6 billion and $500.0 billion for 2017 and 2016, and $520.4 billion and $518.7 billion at December 31, 2017 and 2016.
(2)
Included $9.2 billion of non-U.S. credit card loans at December 31, 2016, which were included in assets of business held for sale on the Consolidated Balance Sheet. In 2017, the Corporation sold its non-U.S. consumer credit card business.
n/m = not meaningful

(1)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.
Bank of America 201738


All Other consists of ALM activities, equity investments, non-core mortgage loans and servicing activities, the net impact of periodic revisions to the MSR valuation model for both core and non-core MSRs and the related economic hedge results and ineffectiveness, liquidating businesses and residual expense allocations.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,activities. Substantially all of the impact of certain allocation methodologies and accounting hedge ineffectiveness. The results of certain ALM activities are allocated to our business segments. For more information on our ALM activities, see Note
23 – Business Segment Informationto the Consolidated Financial Statements. Equity investments include our merchant services joint venture as well as Global Principal Investments which is comprised of a portfolio of equity, real estate and other alternative investments. For more information on our merchant services joint venture, see Note 12 – Commitments and Contingenciesto the Consolidated Financial Statements. Income tax is generally recorded in the business segments at the statutory rate; the initial impact of the Tax Act was recorded in All Other.
In 2017, the Corporation sold its non-U.S. consumer credit card business. For more information on the sale, see Note 1 – Summary of Significant Accounting Principles to the Consolidated Financial Statements.
The Corporation classifies consumer real estate loans as core or non-core based on loan and customer characteristics such as origination date, product type, LTV, FICO score and delinquency status. For more information on the core and non-core portfolios, see Consumer Portfolio Credit Risk Management on page 54. 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. For more information on our interest rate and liquidity risk management activities, see Liquidity Risk on page 49 and Interest Rate Risk Management for the Banking Book on page 81. During 2017,2020, residential mortgage loans held for ALM activities decreased $6.1$12.7 billion to $28.5$9.0 billion at December 31, 2017due primarily as a result of payoffs and paydowns outpacing new originations.to loan sales. Non-core residential mortgage and home equity loans, which are principally run-offrunoff portfolios, including certain loans accounted for under the fair value option and MSRs pertaining to non-core loans serviced for others, are also held in All
45 Bank of America


Other. During 2017,2020, total non-core loans decreased $11.8$3.0 billion to $41.3$12.6 billion at December 31, 2017 due primarily to payoffs and paydowns, as well as Federal Housing Administration (FHA) loan sales.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 62.
The net loss for All Other increased $1.6 billion decreased $949 million to a net loss of $3.3 billion, driven by an estimated charge of $2.9 billion$407 million, primarily due to enactmenta $2.1 billion pretax impairment charge related to the notice of termination of the Tax Act. For more information, see Financial Highlights on page 21. The pre-tax loss for 2017 compared to 2016 decreased $526 million reflectingmerchant services joint venture in 2019, partially offset by lower noninterest expenserevenue and a larger benefit in thehigher provision for credit losses, partially offset by a decline in revenue.losses.
Revenue declined $1.5 billion primarily due to lower mortgage banking income. Mortgage banking income declineddecreased $1.2 billion primarily due to less favorable valuationsextinguishment losses on MSRs,certain structured liabilities, higher client-driven ESG investment activity, resulting in higher partnership losses on these tax-advantaged investments, and lower net of related hedges, and an increase in the provision for representations and warranties. All other noninterest loss decreased marginally and includedinterest income, partially offset by a pre-tax gain of $793 million on the sale of the non-
U.S. credit card business and a downward valuation adjustment of $946 million on tax-advantaged energy investments in connection with the Tax Act. Gains on sales of loans included in all other loss, including nonperforming and other delinquent loans, were $134 million compared to gains of $232 million in the same period in 2016.mortgage loans.
The benefit in the provision for credit losses increased $461$719 millionto$50 million from a provision benefit of $561$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 continued runoffthe impact of the non-core portfolio, loan sale recoveries and the sale of the non-U.S. consumer credit card business.
Noninterest expense decreased $1.5 billion to $4.1 billion driven by lower litigation expense, lower personnel expenseU.K. tax law change and a decline in non-core mortgage servicing costs,higher level of income tax credits related to our ESG investment activity, partially offset by a $316 million impairment charge related to certain data centersthe positive impact from the resolution of various tax controversy matters in the process of being sold.
The income tax benefit was $1.0 billion in 2017 compared to a benefit of $3.1 billion in 2016. The decrease in the tax benefit was driven by the impacts of the Tax Act, including an estimated income tax expense of $1.9 billion related primarily to a lower valuation of certain deferred tax assets and liabilities.2019. Both periods includeyears included income tax benefit adjustments to eliminate the FTE treatment of certain tax credits recorded in Global Banking.
Off-Balance Sheet Arrangements and Contractual Obligations
We have contractual obligations to make future payments on debt and lease agreements. Additionally, in the normal course of business, we enter into contractual arrangements whereby we
commit to future purchases of products or services from unaffiliated parties. Purchase obligations are defined as obligations that are legally binding agreements whereby we agree to purchase products or services with a specific minimum quantity at a fixed, minimum or variable price over a specified period of time. Included in purchase obligations are vendor contracts, the most significant of which include communication services, processing services and software contracts. Debt, lease and other obligations are more fully discussed in Note 11 – Long-term Debt and Note 12 – Commitments and Contingencies to the Consolidated Financial Statements.
Other long-term liabilities include our contractual funding obligations related to the Qualified Pension Plan, Non-U.S. Pension Plans and Nonqualified and Other Pension Plans and Postretirement Health and Life Plans (collectively,(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 20172020 and 2016,2019, we contributed $514$115 million and $256$135 million to the Plans, and we expect to make $128$136 million of contributions during 2018.2021. The Plans are more fully discussed in Note 17 – Employee Benefit Plans to the Consolidated Financial Statements.
We enter into commitments to extend credit such as loan commitments, standby letters of credit (SBLCs) and commercial letters of credit to meet the financing needs of our customers. For a summary of the total unfunded, or off-balance sheet, credit extension commitment amounts by expiration date, see Credit Extension Commitments in Note 12 – Commitments and Contingencies to the Consolidated Financial Statements.


39Bank of America 2017



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 1110 includes certain contractual obligations at December 31, 20172020 and 2016.2019.
            
Table 11Contractual Obligations    
Table 10Table 10Contractual Obligations
            
 December 31, 2017 December 31
2016
December 31, 2020December 31
2019
(Dollars in millions)(Dollars in millions)Due in One
Year or Less
 Due After
One Year Through
Three Years
 Due After
Three Years Through
Five Years
 Due After
Five Years
 Total Total(Dollars in millions)Due in One
Year or Less
Due After
One Year Through
Three Years
Due After
Three Years Through
Five Years
Due After
Five Years
TotalTotal
Long-term debtLong-term debt$42,057
 $42,145
 $30,879
 $112,321
 $227,402
 $216,823
Long-term debt$20,352 $50,824 $48,568 $143,190 $262,934 $240,856 
Operating lease obligationsOperating lease obligations2,256
 4,072
 3,023
 5,169
 14,520
 13,620
Operating lease obligations1,927 3,169 2,395 4,609 12,100 11,794 
Purchase obligationsPurchase obligations1,317
 1,426
 458
 1,018
 4,219
 5,742
Purchase obligations551 700 80 103 1,434 3,530 
Time depositsTime deposits61,038
 4,990
 1,543
 273
 67,844
 74,944
Time deposits50,661 3,206 426 1,563 55,856 74,673 
Other long-term liabilitiesOther long-term liabilities1,681
 1,234
 862
 1,195
 4,972
 4,567
Other long-term liabilities1,656 1,092 953 781 4,482 4,099 
Estimated interest expense on long-term debt and time deposits (1)
Estimated interest expense on long-term debt and time deposits (1)
5,590
 8,796
 6,909
 27,828
 49,123
 39,447
Estimated interest expense on long-term debt and time deposits (1)
4,542 8,123 6,958 30,924 50,547 44,385 
Total contractual obligationsTotal contractual obligations$113,939
 $62,663
 $43,674
 $147,804
 $368,080
 $355,143
Total contractual obligations$79,689 $67,114 $59,380 $181,170 $387,353 $379,337 
(1)
(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.
Represents forecasted net interest expense on long-term debt and time deposits based on interest rates at December 31, 2017. Forecasts are based on the contractual maturity dates of each liability, and are net of derivative hedges, where applicable.
Representations and Warranties Obligations
For background information on representations and warranties see Note 7 – Representations and Warranties Obligations and Corporate Guarantees to the Consolidated Financial Statements. Breaches of representations and warranties madeobligations in connection with the sale of mortgage loans, have resulted in and may continue to result in the requirement to repurchase mortgage loans or to otherwise make whole or provide other remedies to investors, securitization trusts, guarantors, insurers or other parties (collectively, repurchases).
At December 31, 2017 and 2016, we had $17.6 billion and $18.3 billion of unresolved repurchase claims, predominately related to subprime and pay option first-lien loans and home equity loans originated primarily between 2004 and 2008.
In addition to unresolved repurchase claims, we have received notifications indicating that we may have indemnity obligations with respect to specific loans for which we have not received a repurchase request. These notifications were received prior to 2015, and totaled $1.3 billion at both December 31, 2017 and 2016. During 2017, we reached agreements with certain parties requesting indemnity. One such agreement is subject to acceptance by a securitization trustee. The impact of these agreements is included in the provision and reserve for representations and warranties.
The reserve for representations and warranties and corporate guarantees is included in accrued expenses and other liabilities on the Consolidated Balance Sheet and the related provision is included in mortgage banking income. At December 31, 2017 and 2016, the reserve for representations and warranties was $1.9 billion and $2.3 billion. The representations and warranties provision was $393 million for 2017 compared to $106 million for 2016 with the increase resulting from settlements or advanced negotiations with certain counterparties where we believe we will reach settlements on several outstanding legacy matters.
In addition, we currently estimate that the range of possible loss for representations and warranties exposures could be up to $1 billion over existing accruals at December 31, 2017. This estimate is lower than the estimate at December 31, 2016 due
to recent reductions in risk as we reach settlements with counterparties. The estimated range of possible loss represents
a reasonably possible loss, but does not represent a probable loss, and is based on currently available information, significant judgment and a number of assumptions that are subject to change.
Future provisions and/or ranges of possible loss associated with obligations under representations and warranties may be significantly impacted if future experiences are different from historical experience or our understandings, interpretations or assumptions. Adverse developments with respect to one or more of the assumptions underlying the reserve for representations and warranties and the corresponding estimated range of possible loss, such as counterparties successfully challenging or avoiding the application of the relevant statute of limitations, could result in significant increases to future provisions and/or the estimated range of possible loss. For more information on representations and warranties, see Note 7 – Representations and Warranties Obligations and Corporate Guarantees to the Consolidated Financial Statements and, for more information related to the sensitivity of the assumptions used to estimate our liability for representations and warranties, see Complex Accounting Estimates – Representations and Warranties Liability on page 86.
Other Mortgage-related Matters
We continue to be subject to mortgage-related litigation and disputes, as well as governmental and regulatory scrutiny and investigations, related to our past and current origination, servicing, transfer of servicing and servicing rights, servicing compliance obligations, foreclosure activities, indemnification obligations, and mortgage insurance and captive reinsurance practices with mortgage insurers. The ongoing environment of regulatory scrutiny, heightened regulatory compliance obligations, and enhanced regulatory enforcement, combined with ongoing uncertainty related to the continuing evolution of the regulatory environment, has resulted in increased operational and compliance costs and may limit our ability to continue providing certain products and services. For more information on management’s estimate of the aggregate range of possible loss for certain litigation matters and on regulatory investigations, see Note 12 – Commitments and Contingencies to the Consolidated Financial Statements.


Bank of America 20174046



Managing Risk
Overview
Risk is inherent in all our business activities. Sound risk management enables us to serve our customers and deliver for our shareholders. If not managed well, risks can result in financial loss, regulatory sanctions and penalties, and damage to our reputation, each of which may adversely impact our ability to execute our business strategies. We take a comprehensive approach to risk management with a defined Risk Framework and an articulated Risk Appetite Statement, which are approved annually by the Enterprise Risk Committee (ERC)ERC and the Board.
The seven key types of risk faced by the Corporation are strategic, credit, market, liquidity, compliance, operational and reputational risks.reputational.
Strategic risk is the risk resulting from incorrect assumptions about external or internal factors, inappropriate business plans, ineffective business strategy execution, or failure to respond in a timely manner to changes in the regulatory, macroeconomic or competitive environments in the geographic locations in which we operate.
Credit risk is the risk of loss arising from the inability or failure of a borrower or counterparty to meet its obligations.
Market risk is the risk that changes in market conditions may adversely impact the value of assets or liabilities, or otherwise negatively impact earnings.
Liquidity risk is the inability to meet expected or unexpected cash flow and collateral needs while continuing to support our businesses and customers under a range of economic conditions.
Compliance risk is the risk of legal or regulatory sanctions, material financial loss or damage to the reputation of the Corporation arising from the failure of the Corporation to comply with the requirements of applicable laws, rules, regulations and related self-regulatory organizations’ standards and codes of conduct.
Operational risk is the risk of loss resulting from inadequate or failed internal 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.
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 otherwise negatively impact earnings. Market risk is composed of price risk and interest rate 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 operating principles.delivering responsible growth. It requires us to focus on risk in all activities and encourages the necessary mindset and behavior to enable effective risk management, and promotes sound risk-taking within our risk appetite. Sustaining a culture of managing risk well throughout the organization is critical to our success and is a clear expectation of our executive management team and the Board.
Our Risk Framework serves as the foundation for the consistent and effective management of risks facing the Corporation. The
Risk Framework sets forth clear roles, responsibilities and accountability for the management of risk and provides a blueprint for how the Board, through delegation of authority to committees and executive officers, establishes risk appetite and associated limits for our activities.
Executive management assesses, with Board oversight, the risk-adjusted returns of each business. Management reviews and approves the strategic and financial operating plans, as well as the capital plan and Risk Appetite Statement, and recommends them annually to the Board for approval. Our strategic plan takes into consideration return objectives and financial resources, which must align with risk capacity and risk appetite. Management sets financial objectives for each business by allocating capital and setting a target for return on capital for each business. Capital allocations and operating limits are regularly evaluated as part of our overall governance processes as the businesses and the economic environment in which we operate continue to evolve. For more information regarding capital allocations,see Business Segment Operationsonpage 30.36.
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.
For a more detailed discussion of our risk management activities, see the discussion below and pages 44 through 84.
Our overall capacity to take risk is limited; therefore, we prioritize the risks we take in order to maintain a strong and flexible financial
position so we can withstand challenging economic conditions and take advantage of organic growth opportunities. Therefore, we set objectives and targets for capital and liquidity that are intended to permit us to continue to operate in a safe and sound manner, including during periods of stress.
Our lines of business operate with risk limits (which may include credit, market and/or operational limits, as applicable) that are based onalign with the amount of capital, earnings or liquidity we are willing to put atCorporation’s risk to achieve our strategic objectives and business plans.appetite. Executive management is responsible for tracking and reporting performance measurements as well as any exceptions to guidelines or limits. The Board, and its committees when appropriate, overseesoversee financial performance, execution of the strategic and financial operating plans, adherence to risk appetite limits and the adequacy of internal controls.
For a more detailed discussion of our risk management activities, see the discussion below and pages 50 through 85.
For more information about the Corporation's risks related to the pandemic, see Part I. Item 1A. Risk Factors on page 7. 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.

4147Bank of America 2017




The chart below illustrates the inter-relationship among the Board, Board committees and management committees that have the majority of risk oversight responsibilities for the Corporation.
(1) This presentation does not include committees for other legal entities.
(2) Reports to the CEO and CFO with oversight by the Audit Committee.bac-20201231_g2.jpg
Board of Directors and Board Committees
The Board is comprisedcomposed of 1517 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 managementIndependent Risk Management (IRM) and/or Corporate Audit to execute its responsibilities. The Board committees discussed below have the principal responsibility for enterprise-wide oversight of our risk management activities. Through these activities, the Board and applicable committees are provided with information on our risk profile and oversee executive management addressing key risks we face. Other Board committees, as described below, provide additional oversight of specific risks.
Each of the committees shown on the above chart regularly reports to the Board on risk-related matters within the committee’s responsibilities, which is intended to collectively provide the Board with integrated insight about our management of enterprise-wide risks.
Audit Committee
The Audit Committee oversees the qualifications, performance and independence of the Independent Registered Public Accounting Firm, the performance of our corporate audit function, the integrity of our consolidated financial statements, our compliance with legal and regulatory requirements, and makes inquiries of management or the Corporate General Auditor (CGA)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.face and of the Corporation’s overall risk appetite. It approves the Risk Framework
and the Risk Appetite Statement and further recommends these documents to the Board for approval. The ERC oversees senior management’s responsibilities for the identification, measurement, monitoring and control of key risks we face. The
ERC may consult with other Board committees on risk-related matters.
Other Board Committees
Our Corporate Governance, ESG, and Sustainability Committee oversees our Board’s governance processes, identifies and reviews the qualifications of potential Board members, recommends nominees for election to our Board, recommends committee appointments for Board approval and reviews our Environmental, Social and Government (ESG)Governance and stockholder engagement activities.
Our Compensation and BenefitsHuman 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, anddirectors; reviewing and approving all of our executive officers’ compensation, as well as compensation for non-management directors.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-levelmanagement 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. The MRC providesThis 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.


Bank of America 201742


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 more detail below.this section.
Bank of America 48


Executive Officers
Executive officers lead various functions representing the functional roles. Authority for functional roles may be delegated to executive officers from the Board, Board committees or management-level committees. Executive officers, in turn, may further delegate responsibilities, as appropriate, to management-levelmanagement level committees, management routines or individuals. Executive officers review our activities for consistency with our Risk Framework, Risk Appetite Statement and applicable strategic, capital and financial operating plans, as well as applicable policies, standards, procedures and processes. Executive officers and other employees make decisions individually on a day-to-day basis, consistent with the authority they have been delegated. Executive officers and other employees may also serve on committees and participate in committee decisions.
Front Line Units
FLUs, which include the lines of business as well as the Global Technology and Operations Group, and are responsible for appropriately assessing and effectively managing all of the risks
associated with their activities.
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, Global MarketingGroup; second, Environmental, Social and Corporate Affairs (GM&CA)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 and Global Compliance.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, CFO Group and GM&CA.Group. IRM, led by the Chief Risk Officer (CRO), is responsible for independently assessing and overseeing risks within FLUs and other control functions. IRM establishes written enterprise policies and procedures that include concentration risk limits, where appropriate. Such policies and procedures outline how aggregate risks are identified, measured, monitored and controlled.
The CRO has the stature, authority and independence to develop and implement a meaningful risk management framework. The CRO has unrestricted access to the Board and reports directly to both the ERC and to the CEO. Global Risk Management is organized into horizontal risk teams FLUthat cover a specific risk teamsarea and control function riskvertical CRO teams that cover a particular front line unit or control function. These teams work collaboratively in executing their respective duties.
Within IRM, Global Compliance independently assesses compliance risk, and evaluates adherence to applicable laws, rules and regulations, including identifying compliance issues and risks, performing monitoring and testing, and reporting on the state of compliance activities across the Corporation. Additionally, Global Compliance works with FLUs and control functions so that day-to-day activities operate in a compliant manner.
Corporate Audit
Corporate Audit and the CGACAE maintain their independence from the FLUs, IRM and other control functions by reporting directly to the Audit Committee or the Board. The CGACAE administratively reports to the CEO. Corporate Audit provides independent assessment and validation through testing of key processes and controls across the Corporation. Corporate Audit includes Credit Review which periodically tests and examines credit portfolios and processes.
Risk Management Processes
The Risk Framework requires that strong risk management practices are integrated in key strategic, capital and financial planning processes and in day-to-day business processes across the Corporation, with a goal of ensuring risks are
appropriately considered, evaluated and responded to in a timely manner.
We employ aour risk management process, referred to as Identify, Measure, Monitor and Control, as part of our daily activities.
IdentifyTo 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.
MeasureOnce a risk is identified, it must be prioritized and accurately measured through a systematic risk quantification process including quantitative and qualitative components. Risk is measured at various levels including, but not limited to, risk type, FLU, legal entity and on an aggregate basis. This
risk quantification process helps to capture changes in our risk profile due to changes in strategic direction, concentrations, portfolio quality and the overall economic environment. Senior management considers how risk exposures might evolve under a variety of stress scenarios.
MonitorWe 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).
ControlWe 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.

43Bank of America 2017



The formal processes used to manage risk represent a part of our overall risk management process. We instill a strong and comprehensive culture of managing risk well through communications, training, policies, procedures and organizational roles and responsibilities. Establishing a culture reflective of our purpose to help make our customers’ financial lives better and delivering our responsible growth strategy areis 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.
49 Bank of America


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 Funding Plan and Recovery Plan, which provide monitoring, escalation, actions and routines designed to enable us to increase capital, access funding sources and reduce risk through consideration of potential options that include asset sales, business sales, capital or debt issuances, or other de-risking strategies. We also maintain a Resolution Plan to limit adverse systemic impacts that could be associated with a potential resolution of Bank of America.
Strategic Risk Management
Strategic risk is embedded in every business and is one of the major risk categories along with credit, market, liquidity, compliance, operational and reputational risks. This risk results from incorrect assumptions about external or internal factors, inappropriate business plans, ineffective business strategy execution, or failure to respond in a timely manner to changes in the regulatory, macroeconomic or competitive environments in the geographic locations in which we operate, such as competitor actions, changing customer preferences, product obsolescence and technology developments. Our strategic plan is consistent with our risk appetite, capital plan and liquidity requirements and specifically addresses strategic risks.
On an annual basis, the Board reviews and approves the strategic plan, capital plan, financial operating plan and Risk Appetite Statement. With oversight by the Board, executive management directs the lines of business to execute our strategic plan consistent with our core operating principles and risk appetite. The executive management team monitors business performance throughout the year and provides the Board with regular progress reports on whether strategic objectives and timelines are being met, including reports on strategic risks and if additional or alternative actions need to be considered or implemented. The regular executive reviews focus on assessing forecasted earnings and returns on capital, the current risk profile, current capital and liquidity requirements, staffing levels and changes required to support the strategic plan, stress testing results, and other qualitative factors such as market growth rates and peer analysis.
Significant strategic actions, such as capital actions, material acquisitions or divestitures, and resolution plans are reviewed and approved by the Board. At the business level, processes are in place to discuss the strategic risk implications of new, expanded or modified businesses, products or services and other strategic initiatives, and to provide formal review and
approval where required. With oversight by the Board and the ERC, executive management performs similar analyses throughout the year and evaluates changes to the financial forecast or the risk, capital or liquidity positions as deemed appropriate to balance and optimize achieving the targeted risk appetite, shareholder returns and maintaining the targeted financial strength. Proprietary models are used to measure the capital requirements for credit, country, market, operational and strategic risks. The allocated capital assigned to each business is based on its unique risk profile. With oversight by the Board, executive management assesses the risk-adjusted returns of each business in approving strategic and financial operating plans. The businesses use allocated capital to define business strategies and price products and transactions.



Bank of America 201744


Capital Management
The Corporation manages its capital position so that its capital is more than adequate to support its business activities and to maintain capital,aligns with risk, and risk appetite commensurate with one another.and strategic planning. Additionally, we seek to maintain safety and soundness at all times, even under adverse scenarios, take advantage of organic growth opportunities, meet obligations to creditors and counterparties, maintain ready access to financial markets, continue to serve as a credit intermediary, remain a source of strength for our subsidiaries, and satisfy current and future regulatory capital requirements. Capital management is integrated into our risk and governance processes, as capital is a key consideration in the development of our strategic plan, risk appetite and risk limits.
We conduct an Internal Capital Adequacy Assessment Process (ICAAP) on a periodic basis. The ICAAP is a forward-looking assessment of our projected capital needs and resources, incorporating earnings, balance sheet and risk forecasts under baseline and adverse economic and market conditions. We utilize periodic stress tests to assess the potential impacts to our balance sheet, earnings, regulatory capital and liquidity under a variety of stress scenarios. We perform qualitative risk assessments to identify and assess material risks not fully captured in our forecasts or stress tests. We assess the potential capital impacts of proposed changes to regulatory capital requirements. Management assesses ICAAP results and provides documented quarterly assessments of the adequacy of our capital guidelines and capital position to the Board or its committees.
We periodically review capital allocated to our businesses and allocate capital annually during the strategic and capital planning processes. For more information, see Business Segment Operations on page 30.36.
CCAR and Capital Planning
The Federal Reserve requires BHCs to submit a capital plan and requests forplanned capital actions on an annual basis, consistent with the rules governing the CCAR capital plan.
On June 28, 2017, followingBased 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.
Bank of America 50


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 non-objectionupdated 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 2017 CCAR capital plan,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 $12.0$2.9 billion in common stock from July 1, 2017 through June 30, 2018,March 31, 2021, plus repurchases expected to be approximately $900 million to offset the effect ofshares awarded under equity-based compensation plans during the same period. On December 5, 2017, following approvalperiod, estimated to be approximately $300 million. This authorization equals the maximum amount allowed by the Federal Reserve for the Board authorized the repurchase of an additional $5.0 billion of common stock through June 30, 2018. The commonperiod.
Our stock repurchase authorizations include both common stock and warrants. During 2017, pursuant to the Board’s authorizations, including those related to our 2016 CCAR capital plan that expired June 30, 2017, we repurchased $12.8 billion of common stock, which includes common stock repurchases to offset equity-based compensation awards. At December 31, 2017, our remaining stock repurchase authorization was $10.1 billion.
The timing and amount of common stock repurchases will beprogram 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. The common stockSuch repurchases may be effected through open market purchases or privately negotiated transactions, including repurchase plans that satisfy the conditions of Rule 10b5-1 of the Securities Exchange Act of 1934. As a “well-capitalized” BHC, we may notify the Federal Reserve of our intention to make additional capital distributions not to exceed 0.25 percent of Tier 1 capital, and which were not
contemplated in our capital plan, subject to the Federal Reserve’s non-objection.1934, as amended (Exchange Act).
Regulatory Capital
As a financial services holding company, we are subject to regulatory capital rules, including Basel 3, issued by U.S. banking regulators includingregulators. Basel 3 which includes certain transition provisions through January 1, 2019. The Corporation and its primary affiliated banking entity, BANA, are Basel 3 Advanced approaches institutions.
Basel 3 Overview
Basel 3 updated the composition of capital and established a Common equity tier 1 capital ratio. Common equity tier 1 capital primarily includes common stock, retained earnings and accumulated other comprehensive income (OCI), net of deductions and adjustments primarily related to goodwill, deferred tax assets, intangibles and defined benefit pension assets. Under the Basel 3 regulatory capital transition provisions, certain deductions and adjustments to Common equity tier 1 capital were phased in through January 1, 2018. In 2017, under the transition provisions, 80 percent of these deductions and adjustments was recognized. Basel 3 also revised minimum capital ratios and buffer requirements added a supplementary leverage ratio (SLR), and addressed the adequately capitalized minimum requirements under the Prompt Corrective Action (PCA) framework. Finally, Basel 3 establishedoutlined two methods of
calculating risk-weighted assets (RWA), the Standardized approach and the Advanced approaches. The Standardized approach relies primarily on supervisory risk weights based on exposure type, and the Advanced approaches determine risk weights based on internal models. During
The Corporation's depository institution subsidiaries are also subject to the fourth quarter of 2017, we obtained approval from U.S.Prompt Corrective Action (PCA) framework. The Corporation and its primary affiliated banking regulators to use our Internal Models Methodology (IMM) to calculate counterparty credit risk-weighted assets for derivatives under the Advanced approaches.
As anentity, BANA, are Advanced approaches institution, weinstitutions under Basel 3 and are required to report regulatory risk-based capital ratios and risk-weighted assetsRWA under both the Standardized and Advanced approaches. The approach that yields the lower ratio is used to assess capital adequacy including under the PCA framework. As of December 31, 2020, the CET1, Tier 1 capital and Total capital ratios for the Corporation were lower under the Standardized approach.
Minimum Capital Requirements
MinimumIn order to avoid restrictions on capital requirementsdistributions and related buffers are being phased in from January 1, 2014 through January 1, 2019. The PCA framework establishes categories of capitalization including “well capitalized,” based ondiscretionary bonus payments, the Basel 3 regulatory ratio requirements. U.S. banking regulators are required to take certain mandatory actions depending on the category of capitalization, with no mandatory actions required for “well-capitalized” banking organizations, which included BANA at December 31, 2017.
We are subject to a capital conservation buffer, a countercyclical capital buffer and a global systemically important bank (G-SIB) surcharge that are being phased in over a three-year period ending January 1, 2019. Once fully phased in, the Corporation’sCorporation must meet risk-based capital ratio requirements willthat include a capital conservation buffer greater than 2.5 percent, plus any applicable countercyclical capital buffer and a G-SIB surcharge in order to avoid restrictions onsurcharge. On October 1, 2020, the capital distributions and discretionary bonus payments.conservation buffer was replaced by the SCB for the Corporation’s Standardized approach ratio requirements. The buffers and surcharge must be comprised solely of Common equity tier 1CET1 capital. Under the phase-in provisions, we were
The Corporation is also required to maintain a capital conservation buffer greater than 1.25minimum supplementary leverage ratio (SLR) of 3.0 percent plus a G-SIB surchargeleverage buffer of 1.52.0 percent in 2017. The countercyclicalorder to avoid certain restrictions on capital buffer is currently set at zero. We estimate that our fully phased-in G-SIB surcharge will

45Bank of America 2017



distributions and discretionary bonus payments. Our insured depository institution subsidiaries are required to maintain a minimum 6.0 percent SLR to be 2.5 percent. The G-SIB surcharge may differ from this estimate over time. For more information onconsidered well capitalized under the Corporation’s transition and fully phased-in capital ratios and regulatory requirements, see Table 12.
Supplementary Leverage Ratio
Basel 3 requires Advanced approaches institutions to disclose an SLR.PCA framework. The numerator of the SLR is quarter-end Basel 3 Tier 1 capital. The denominator is total leverage exposure based on the daily average of the sum of on-balance sheet exposures less permitted Tier 1 deductions 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. Effective January 1, 2018, the Corporation will be required to maintain a minimum SLR of 3.0 percent, plus a leverage buffer of 2.0 percent in order to avoid certain restrictionsFor more information, see Capital Management – Regulatory Developments on capital distributions and discretionary bonus payments. Insured
depository institution subsidiaries of BHCs will be required to maintain a minimum 6.0 percent SLR to be considered “well capitalized” under the PCA framework.page 55.
Capital Composition and Ratios
Table 1211 presents Bank of America Corporation’s transition and fully phased-in capital ratios and related information in accordance with Basel 3 Standardized and Advanced approaches as measured at December 31, 20172020 and 2016. Fully phased-in estimates are non-GAAP financial measures that2019. For the Corporation considers to be useful measures in evaluating compliance with new regulatory capital requirements that are not yet effective. For reconciliations to GAAP financial measures, see Table 15. As of December 31, 2017 and 2016,periods presented herein, the Corporation met the definition of “well capitalized”well capitalized under current regulatory requirements.
             
Table 12
Bank of America Corporation Regulatory Capital under Basel 3 (1, 2)
    
   
  Transition Fully Phased-in
 
Standardized
Approach
 
Advanced
Approaches (3)
 
Regulatory Minimum (4)
 
Standardized
Approach
 
Advanced
Approaches (3)
 
Regulatory Minimum (5)
(Dollars in millions, except as noted)December 31, 2017
Risk-based capital metrics:           
Common equity tier 1 capital$171,063
 $171,063
   $168,461
 $168,461
  
Tier 1 capital191,496
 191,496
   190,189
 190,189
  
Total capital (6)
227,427
 218,529
   224,209
 215,311
  
Risk-weighted assets (in billions)1,434
 1,449
   1,443
 1,459
  
Common equity tier 1 capital ratio11.9% 11.8% 7.25% 11.7% 11.5% 9.5%
Tier 1 capital ratio13.4
 13.2
 8.75
 13.2
 13.0
 11.0
Total capital ratio15.9
 15.1
 10.75
 15.5
 14.8
 13.0
             
Leverage-based metrics:           
Adjusted quarterly average assets (in billions) (7)
$2,224
 $2,224
   $2,223
 $2,223
  
Tier 1 leverage ratio8.6% 8.6% 4.0
 8.6% 8.6% 4.0
            
SLR leverage exposure (in billions)        $2,756
  
SLR        6.9% 5.0
             
  December 31, 2016
Risk-based capital metrics:           
Common equity tier 1 capital$168,866
 $168,866
   $162,729
 $162,729
  
Tier 1 capital190,315
 190,315
   187,559
 187,559
  
Total capital (6)
228,187
 218,981
   223,130
 213,924
  
Risk-weighted assets (in billions)1,399
 1,530
   1,417
 1,512
  
Common equity tier 1 capital ratio12.1% 11.0% 5.875% 11.5% 10.8% 9.5%
Tier 1 capital ratio13.6
 12.4
 7.375
 13.2
 12.4
 11.0
Total capital ratio16.3
 14.3
 9.375
 15.8
 14.2
 13.0
             
Leverage-based metrics:           
Adjusted quarterly average assets (in billions) (7)
$2,131
 $2,131
   $2,131
 $2,131
  
Tier 1 leverage ratio8.9% 8.9% 4.0
 8.8% 8.8% 4.0
             
SLR leverage exposure (in billions)        $2,702
  
SLR        6.9% 5.0
(1)51 Bank of America
As an Advanced approaches institution, we are required to report regulatory capital risk-weighted assets and ratios under both the Standardized and Advanced approaches. The approach that yields the lower ratio is to be used to assess capital adequacy and was the Advanced approaches method at December 31, 2017 and 2016.
(2)


Table 11Bank of America Corporation Regulatory Capital under Basel 3
Standardized
Approach
(1, 2)
Advanced
Approaches
(1)
Regulatory
Minimum
(3)
(Dollars in millions, except as noted)December 31, 2020
Risk-based capital metrics:
Common equity tier 1 capital$176,660 $176,660 
Tier 1 capital200,096 200,096 
Total capital (4)
237,936 227,685 
Risk-weighted assets (in billions)1,480 1,371 
Common equity tier 1 capital ratio11.9 %12.9 %9.5 %
Tier 1 capital ratio13.5 14.6 11.0 
Total capital ratio16.1 16.6 13.0 
Leverage-based metrics:
Adjusted quarterly average assets (in billions) (5)
$2,719 $2,719 
Tier 1 leverage ratio7.4 %7.4 %4.0 
Supplementary leverage exposure (in billions) (6)
$2,786 
Supplementary leverage ratio7.2 %5.0 
December 31, 2019
Risk-based capital metrics:
Common equity tier 1 capital$166,760 $166,760 
Tier 1 capital188,492 188,492 
Total capital (4)
221,230 213,098 
Risk-weighted assets (in billions)1,493 1,447 
Common equity tier 1 capital ratio11.2 %11.5 %9.5 %
Tier 1 capital ratio12.6 13.0 11.0 
Total capital ratio14.8 14.7 13.0 
Leverage-based metrics:
Adjusted quarterly average assets (in billions) (5)
$2,374 $2,374 
Tier 1 leverage ratio7.9 %7.9 %4.0 
Supplementary leverage exposure (in billions)$2,946 
Supplementary leverage ratio6.4 %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.
Under the applicable bank regulatory rules, we are not required to and, accordingly, will not restate previously-filed regulatory capital metrics and ratios in connection with the change in accounting method under GAAP for stock-based compensation awards granted to retirement-eligible employees. Therefore, the December 31, 2016 amounts in the table are as originally reported. The cumulative impact of the change in accounting method resulted in an insignificant pro forma change to our capital metrics and ratios. For more information, see Note 1 – Summary of Significant Accounting Principles to the Consolidated Financial Statements.
(3)
During the fourth quarter of 2017, we obtained approval from U.S. banking regulators to use our IMM to calculate counterparty credit risk-weighted assets for derivatives under the Advanced approaches. Fully phased-in estimates for prior periods assumed approval.
(4)
The December 31, 2017 and 2016 amounts include a transition capital conservation buffer of 1.25 percent and 0.625 percent and a transition G-SIB surcharge of 1.5 percent and 0.75 percent. The countercyclical capital buffer for both periods is zero.
(5)
Fully phased-in regulatory minimums assume a capital conservation buffer of 2.5 percent and estimated G-SIB surcharge of 2.5 percent. The estimated fully phased-in countercyclical capital buffer is zero. We will be subject to fully phased-in regulatory minimums on January 1, 2019. The fully phased-in SLR minimum assumes a leverage buffer of 2.0 percent and is applicable on January 1, 2018.
(6)
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.
(7)
Reflects adjusted average total assets for the three months ended December 31, 2017 and 2016.

Bank of America 20174652



Table 12Capital Composition under Basel 3
December 31
(Dollars in millions)20202019
Total common shareholders’ equity$248,414 $241,409 
CECL transitional amount (1)
4,213 — 
Goodwill, net of related deferred tax liabilities(68,565)(68,570)
Deferred tax assets arising from net operating loss and tax credit carryforwards(5,773)(5,193)
Intangibles, other than mortgage servicing rights, net of related deferred tax liabilities(1,617)(1,328)
Defined benefit pension plan net assets(1,164)(1,003)
Cumulative unrealized net (gain) loss related to changes in fair value of financial liabilities attributable to own creditworthiness,
net-of-tax
1,753 1,278 
Other(601)167 
Common equity tier 1 capital176,660 166,760 
Qualifying preferred stock, net of issuance cost23,437 22,329 
Other(1)(597)
Tier 1 capital200,096 188,492 
Tier 2 capital instruments22,213 22,538 
Qualifying allowance for credit losses (2)
15,649 10,229 
Other(22)(29)
Total capital under the Standardized approach237,936 221,230 
Adjustment in qualifying allowance for credit losses under the Advanced approaches (2)
(10,251)(8,132)
Total capital under the Advanced approaches$227,685 $213,098 
Common equity tier(1)The CECL transitional amount includes the impact of the Corporation's adoption of the new CECL accounting standard on January 1, capital under Basel 3 Advanced – Transition was $171.1 billion2020 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, 2017, an increase2020 includes the impact of $2.2 billion compared to December 31, 2016 driven by earnings and the exercise of warrants associated with the Series T preferred stock, partially offset by common stock repurchases, dividends and the phase-in under Basel 3 transition provisions of deductions, primarily related to deferred tax assets. During 2017, total capital decreased $452 million primarily driven by common stock repurchases, dividends, lower eligible credit reserves and tier 2
the new CECL accounting standard.
capital instruments, in addition to the phase-in of Basel 3 transition provisions, partially offset by earnings.
Risk-weighted assets decreased $81 billion during 2017 to $1,449 billion primarily due to the implementation of Internal Models Methodology (IMM) for derivatives, improvements in credit risk capital models, the sale of the non-U.S. consumer credit card business and continued run-off of non-core assets.
Table 13 shows the capital compositioncomponents of RWA as measured under Basel 3 – Transition at December 31, 20172020 and 2016.
2019.
Table 13Risk-weighted Assets under Basel 3
Standardized Approach (1)
Advanced Approaches
Standardized Approach (1)
Advanced Approaches
December 31
(Dollars in billions)20202019
Credit risk$1,420 $896 $1,437 $858 
Market risk60 60 56 55 
Operational risk (2)
n/a372 n/a500 
Risks related to credit valuation adjustmentsn/a43 n/a34 
Total risk-weighted assets$1,480 $1,371 $1,493 $1,447 
     
Table 13
Capital Composition under Basel 3 – Transition (1, 2)
   
     
  December 31
(Dollars in millions)2017 2016
Total common shareholders’ equity$244,823
 $241,620
Goodwill(68,576) (69,191)
Deferred tax assets arising from net operating loss and tax credit carryforwards(5,244) (4,976)
Adjustments for amounts recorded in accumulated OCI attributed to AFS Securities and defined benefit postretirement plans879
 1,899
Adjustments for amounts recorded in accumulated OCI attributed to certain cash flow hedges831
 895
Intangibles, other than mortgage servicing rights and goodwill(1,395) (1,198)
Defined benefit pension fund assets(910) (512)
DVA related to liabilities and derivatives957
 413
Other(302) (84)
Common equity tier 1 capital171,063
 168,866
Qualifying preferred stock, net of issuance cost22,323
 25,220
Deferred tax assets arising from net operating loss and tax credit carryforwards(1,311) (3,318)
Defined benefit pension fund assets(228) (341)
DVA related to liabilities and derivatives under transition239
 276
Other(590) (388)
Total Tier 1 capital191,496
 190,315
Long-term debt qualifying as Tier 2 capital22,938
 23,365
Eligible credit reserves included in Tier 2 capital2,272
 3,035
Nonqualifying capital instruments subject to phase out from Tier 2 capital1,893
 2,271
Other(70) (5)
Total Basel 3 Capital$218,529
 $218,981
(1)
See Table 12, footnotes 1 and 2.
(2)
Deductions from and adjustments to regulatory capital subject to transition provisions under Basel 3 are generally recognized in 20 percent annual increments, and are fully recognized as of January 1, 2018. Any assets that are a direct deduction from the computation of capital are excluded from risk-weighted assets and adjusted average total assets.

Table 14 shows(1) Derivative exposure amounts are calculated using the components of risk-weighted assets as measured under Basel 3 – Transitionstandardized approach for measuring counterparty credit risk at December 31, 20172020 and 2016.the current exposure method at December 31, 2019.
         
Table 14Risk-weighted Assets under Basel 3 – Transition       
         
 Standardized Approach Advanced Approaches Standardized Approach Advanced Approaches
 December 31
(Dollars in billions)

2017 2016
Credit risk$1,375
 $857
 $1,334
 $903
Market risk59
 58
 65
 63
Operational riskn/a
 500
 n/a
 500
Risks related to CVAn/a
 34
 n/a
 64
Total risk-weighted assets$1,434
 $1,449
 $1,399
 $1,530
(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

4753Bank of America 2017



Table 15 presents a reconciliation of regulatory capital in accordance with Basel 3 Standardized – Transition to the Basel 3 Standardized approach fully phased-in estimates and Basel 3 Advanced approaches fully phased-in estimates at December 31, 2017 and 2016.
     
Table 15
Regulatory Capital Reconciliations between Basel 3 Transition to Fully Phased-in (1)
    
 December 31
(Dollars in millions)2017 2016
Common equity tier 1 capital (transition)$171,063
 $168,866
Deferred tax assets arising from net operating loss and tax credit carryforwards phased in during transition(1,311) (3,318)
Accumulated OCI phased in during transition(879) (1,899)
Intangibles phased in during transition(348) (798)
Defined benefit pension fund assets phased in during transition(228) (341)
DVA related to liabilities and derivatives phased in during transition239
 276
Other adjustments and deductions phased in during transition(75) (57)
Common equity tier 1 capital (fully phased-in)168,461
 162,729
Additional Tier 1 capital (transition)20,433
 21,449
Deferred tax assets arising from net operating loss and tax credit carryforwards phased out during transition1,311
 3,318
Defined benefit pension fund assets phased out during transition228
 341
DVA related to liabilities and derivatives phased out during transition(239) (276)
Other transition adjustments to additional Tier 1 capital(5) (2)
Additional Tier 1 capital (fully phased-in)21,728
 24,830
Tier 1 capital (fully phased-in)190,189
 187,559
Tier 2 capital (transition)27,033
 28,666
Nonqualifying capital instruments phased out during transition(1,893) (2,271)
Other adjustments to Tier 2 capital8,880
 9,176
Tier 2 capital (fully phased-in)34,020
 35,571
Basel 3 Standardized approach Total capital (fully phased-in)224,209
 223,130
Change in Tier 2 qualifying allowance for credit losses(8,898) (9,206)
Basel 3 Advanced approaches Total capital (fully phased-in)$215,311
 $213,924
    
Risk-weighted assets – As reported to Basel 3 (fully phased-in)   
Basel 3 Standardized approach risk-weighted assets as reported$1,433,517
 $1,399,477
Changes in risk-weighted assets from reported to fully phased-in9,204
 17,638
Basel 3 Standardized approach risk-weighted assets (fully phased-in)$1,442,721
 $1,417,115
    
Basel 3 Advanced approaches risk-weighted assets as reported$1,449,222
 $1,529,903
Changes in risk-weighted assets from reported to fully phased-in9,757
 (18,113)
Basel 3 Advanced approaches risk-weighted assets (fully phased-in)$1,458,979
 $1,511,790
(1)


See Table 12, footnotes 1, 2 and 4.
Bank of America, N.A. Regulatory Capital
Table 1614 presents transition regulatory capital information for BANA in accordance with Basel 3 Standardized and Advanced approaches as measured at December 31, 20172020 and 2016. As of December 31, 2017,2019. BANA met the definition of “well capitalized”well capitalized under the PCA framework for both periods.
Table 14Bank of America, N.A. Regulatory Capital under Basel 3
Standardized
Approach
(1, 2)
Advanced
Approaches
(1)
Regulatory
Minimum 
(3)
(Dollars in millions, except as noted)December 31, 2020
Risk-based capital metrics:
Common equity tier 1 capital$164,593 $164,593 
Tier 1 capital164,593 164,593 
Total capital (4)
181,370 170,922 
Risk-weighted assets (in billions)1,221 1,014 
Common equity tier 1 capital ratio13.5 %16.2 %7.0 %
Tier 1 capital ratio13.5 16.2 8.5 
Total capital ratio14.9 16.9 10.5 
Leverage-based metrics:
Adjusted quarterly average assets (in billions) (5)
$2,143 $2,143 
Tier 1 leverage ratio7.7 %7.7 %5.0 
Supplementary leverage exposure (in billions)$2,525 
Supplementary leverage ratio6.5 %6.0 




December 31, 2019
Risk-based capital metrics:
Common equity tier 1 capital$154,626 $154,626 
Tier 1 capital154,626 154,626 
Total capital (4)
166,567 158,665 
Risk-weighted assets (in billions)1,241 991 
Common equity tier 1 capital ratio12.5 %15.6 %7.0 %
Tier 1 capital ratio12.5 15.6 8.5 
Total capital ratio13.4 16.0 10.5 
Leverage-based metrics:
Adjusted quarterly average assets (in billions) (5)
$1,780 $1,780 
Tier 1 leverage ratio8.7 %8.7 %5.0 
Supplementary leverage exposure (in billions)$2,177 
Supplementary leverage ratio7.1 %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)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.
Total Loss-Absorbing Capacity Requirements
Total loss-absorbing capacity (TLAC) consists of the Corporation’s Tier 1 capital and eligible long-term debt issued directly by the Corporation. Eligible long-term debt for TLAC ratios is comprised of unsecured debt that has a remaining maturity of at least one year and satisfies additional requirements as prescribed in the TLAC final rule. As with the
             
Table 16Bank of America, N.A. Regulatory Capital under Basel 3  
             
  Standardized Approach Advanced Approaches
 Ratio Amount 
Minimum
Required
 (1)
 Ratio Amount 
Minimum
Required 
(1)
(Dollars in millions)

December 31, 2017
Common equity tier 1 capital12.5% $150,552
 6.5% 14.9% $150,552
 6.5%
Tier 1 capital12.5
 150,552
 8.0
 14.9
 150,552
 8.0
Total capital13.6
 163,243
 10.0
 15.4
 154,675
 10.0
Tier 1 leverage9.0
 150,552
 5.0
 9.0
 150,552
 5.0
             
  December 31, 2016
Common equity tier 1 capital12.7% $149,755
 6.5% 14.3% $149,755
 6.5%
Tier 1 capital12.7
 149,755
 8.0
 14.3
 149,755
 8.0
Total capital13.9
 163,471
 10.0
 14.8
 154,697
 10.0
Tier 1 leverage9.3
 149,755
 5.0
 9.3
 149,755
 5.0
(1)
risk-based capital ratios and SLR, the Corporation is required to maintain TLAC ratios in excess of minimum requirements plus applicable buffers to avoid restrictions on capital distributions and discretionary bonus payments. Table 15 presents the Corporation's TLAC and long-term debt ratios and related information as of December 31, 2020 and 2019.
Percent required to meet guidelines to be considered “well capitalized” under the PCA framework.

Bank of America 20174854



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

TLAC (1)
Regulatory Minimum (2)
Long-term
Debt
Regulatory Minimum (3)
(Dollars in millions)December 31, 2020
Total eligible balance$405,153 $196,997 
Percentage of risk-weighted assets (4)
27.4 %22.0 %13.3 %8.5 %
Percentage of supplementary leverage exposure (5, 6)
14.5 9.5 7.1 4.5 
December 31, 2019
Total eligible balance$367,449 $171,349 
Percentage of risk-weighted assets (4)
24.6 %22.0 %11.5 %8.5 %
Percentage of supplementary leverage exposure (6)
12.5 9.5 5.8 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
MinimumRevisions 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
plan. The Corporation is instead subject to automatic distribution limitations if its capital ratios fall below its buffer requirements, which include the SCB.
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 25 and Note 1 – Summary of Significant Accounting Principles to the Consolidated Financial Statements.
55 Bank of America


Standardized Approach for Measuring Counterparty Credit Risk
On June 30, 2020 the Corporation adopted 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 Loss-Absorbing Capacitycapital 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 the interconnectedness between G-SIBs and 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.
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 has 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 final rule effectiveBHC 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, 2019, which includes minimum external total loss-absorbing capacity (TLAC) requirements2020, G-SIBs must calculate SCCL on a daily basis by dividing the aggregate net credit exposure to improvea given counterparty by the resolvability G-SIB’s Tier 1 capital, ensuring that exposures to other G-SIBs
and resiliency of large, interconnected BHCs. We estimate our minimum required external TLAC would benonbank financial institutions regulated by the greater of 22.5Federal Reserve do not breach 15 percent of risk-weighted assets or 9.5Tier 1 capital and exposures to most other counterparties do not breach 25 percent of SLR leverage exposure. In addition, U.S. G-SIBs must meet a minimum long-term debt requirement. Our minimum required long-term debt is estimated to be the greater of 8.5 percent of risk-weighted assets or 4.5 percent of SLR leverage exposure. As of December 31, 2017, the Corporation’s TLAC and long-term debt exceeded our estimated 2019 minimum requirements.
Revisions to Approaches for Measuring Risk-weighted Assets
On December 7, 2017, the Basel Committee on Banking Supervision (Basel Committee) finalized several key methodologies for measuring risk-weighted assets. The revisions include a standardized approach for credit risk, standardized approach for operational risk, revisionsTier 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 valuation adjustment (CVA) risk framework and constraints on the use of internal models. The Basel Committee had also previously finalized a revised standardized model for counterparty credit risk, revisions to the securitization framework and its fundamental review of the trading book, which updates both modeled and standardized approaches for market risk measurement. The revisions also include a capital floor set at 72.5 percent of total risk-weighted assets based on the revised standardized approaches to limit the extent to which banks can reduce risk-weighted asset levels through the use of internal models. U.S. banking regulators may update the U.S. Basel 3 rules to incorporate the Basel Committee revisions.limits.
Revisions to the G-SIB Assessment Framework
On March 30, 2017, the Basel Committee issued a consultative document with proposed revisions to the G-SIB surcharge assessment framework. The proposed revisions would include removing the cap on the substitutability category, expanding the scope of consolidation to include insurance subsidiaries in three
categories (size, interconnectedness and complexity) and modifying the substitutability category weights with the introduction of a new trading volume indicator. The Basel Committee has also requested feedback on a new short-term wholesale funding indicator, which would be included in the interconnectedness category. The U.S. banking regulators may update the U.S. G-SIB surcharge rule to incorporate the Basel Committee revisions.
Broker-dealer 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) and. The Corporation's principal European broker-dealer subsidiaries are Merrill Lynch Professional Clearing Corp (MLPCC). MLPCC is a fully-guaranteed subsidiary of MLPF&SInternational (MLI) and provides clearing and settlement services. Both entitiesBofA Securities Europe SA (BofASE).
The U.S. broker-dealer subsidiaries are subject to the net capital requirements of SecuritiesRule 15c3-1 under the Exchange Act. BofAS computes its minimum capital requirements as an alternative net capital broker-dealer under Rule 15c3-1e, and Exchange Commission (SEC)MLPCC and MLPF&S compute their minimum capital requirements in accordance with the alternative standard under Rule 15c3-1. Both entitiesBofAS and MLPCC are also registered as futures commission merchants and are subject to the Commodity Futures Trading CommissionCFTC 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.
MLPF&S has elected to compute the minimum capital requirementBofAS provides institutional services, and in accordance with the Alternative Net Capital Requirement as permitted by SEC Rule 15c3-1. At December 31, 2017, MLPF&S’s regulatoryalternative net capital as defined by Rule 15c3-1 was $12.4 billion and exceeded the minimum requirement of $1.7 billion by $10.7 billion. MLPCC’s net capital of $3.4 billion exceeded the minimum requirement of $543 million by $2.9 billion.
In accordance with the Alternative Net Capital Requirements, MLPF&Srequirements, is required to maintain tentative net capital in excess of $1.0 billion and net capital in excess of the greater of $500 million andor a certain percentage of its reserve requirement. BofAS must also notify the SECSecurities 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, 2017, MLPF&S2020, BofAS had tentative net capital andof $16.8 billion. BofAS also had regulatory net capital in excess of $14.1 billion, which exceeded the minimum requirement of $2.9 billion.
MLPCC is a fully-guaranteed subsidiary of BofAS and notification requirements.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.
Merrill Lynch International (MLI),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 Financial Conduct Authority,FCA and is subject to certain regulatory capital requirements. At December 31, 2017,2020, MLI’s capital resources were $35.1$34.1 billion, which exceeded the minimum Pillar 1 requirement of $16.5$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 is subject to certain 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.
Bank of America 56


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 Part I. Item 1A. Risk Factors – Coronavirus Disease on page 7 and Executive Summary – Recent Developments – COVID-19 Pandemic on page 25.
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 businessline-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 approves the contingency funding plan, including establishingestablishes our liquidity risk tolerance levels. The MRC monitors our liquidity position and reviews the impact of strategic decisions on our liquidity. 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 scenarios and results, and reviews and approves certain liquidity risk limits.limits and reviews the impact of strategic decisions on our liquidity. For more information, see Managing Risk on page 41.47. 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,

49Bank of America 2017



including those that we may experience during stressed market conditions; diversifying funding sources, considering our asset profile and legal entity structure; and performing contingency planning.
NB Holdings Corporation
In 2016, we entered intoWe have intercompany arrangements with certain key subsidiaries under which we transferred certain assets of ourBank of America Corporation, as the parent company, assets,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 in stressed conditions, through repurchase agreements or outright sales. We hold our GLS in legal entities that allow us to meet the liquidity requirements of our global businesses, and we consider the impact of potential regulatory, tax, legal and other restrictions that could limit the transferability of funds among entities.
For the three months ended December 31, 2017 and 2016, ourTable 16 presents average GLS were $522 billion and $515 billion, as shown in Table 17.
     
Table 17Average Global Liquidity Sources
     
  Three Months Ended December 31
(Dollars in billions)2017 2016
Parent company and NB Holdings$79
 $77
Bank subsidiaries394
 389
Other regulated entities49
 49
Total Average Global Liquidity Sources$522
 $515
Parent company and NB Holdings average liquidity was $79 billion and $77 billion for the three months ended December 31, 20172020 and 2016. The increase in parent company and2019.
Table 16Average Global Liquidity Sources
Three Months Ended
December 31
(Dollars in billions)20202019
Bank entities$773 $454 
Nonbank and other entities (1)
170 122 
Total Average Global Liquidity Sources$943 $576 
(1) Nonbank includes Parent, NB Holdings average liquidity was primarily due to debt issuances outpacing maturities. Typically, parent company and NB Holdings liquidity is in the form of cash deposited with BANA.other regulated entities.
Average liquidity held at our bank subsidiaries was $394 billion and $389 billion for the three months ended December 31, 2017 and 2016. Our bank subsidiaries’ liquidity is primarily driven by deposit and lending activity, as well as securities valuation and net debt activity. Liquidity at bank subsidiaries excludes the cash deposited by the parent company and NB Holdings. Our bankBank 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 $308$306 billion and $310$372 billion at December 31, 20172020 and 2016, with the decrease due to FHLB borrowings, which reduced available borrowing capacity, and adjustments to our valuation model.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.
Average
57 Bank of America


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 at ourin other regulated entities, comprised primarily of broker-dealer subsidiaries, was $49 billion for both the three months ended December 31, 2017 and 2016. Our other regulated entities also held unencumbered investment-grade securities and equities that we believe could be used to generate additional liquidity. Liquidity held in an other regulated entity 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.

Bank of America 201750


Table 1817 presents the composition of average GLS for the three months ended December 31, 20172020 and 2016.2019.
Table 17Table 17Average Global Liquidity Sources Composition
Three Months Ended
December 31
    
Table 18Average Global Liquidity Sources Composition
(Dollars in billions)(Dollars in billions)20202019
  
 Three Months Ended December 31
(Dollars in billions)2017 2016
Cash on depositCash on deposit$118
 $118
Cash on deposit$322 $103 
U.S. Treasury securitiesU.S. Treasury securities62
 58
U.S. Treasury securities141 98 
U.S. agency securities and mortgage-backed securities330
 322
U.S. agency securities, mortgage-backed securities, and other investment-grade securitiesU.S. agency securities, mortgage-backed securities, and other investment-grade securities462 358 
Non-U.S. government securitiesNon-U.S. government securities12
 17
Non-U.S. government securities18 17 
Total Average Global Liquidity SourcesTotal Average Global Liquidity Sources$522
 $515
Total Average Global Liquidity Sources$943 $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. For the three months ended December 31, 2017, ourOur average consolidated HQLA, on a net basis, was $439$584 billion and $464 billion for the three months ended December 31, 2020 and 2019. For the same periods, the average consolidated LCR was 125122 percent and 116 percent. Our LCR will fluctuatefluctuates due to normal business flows from customer activity.
Liquidity Stress Analysis and Time-to-required Funding
We utilize liquidity stress analysis to assist us in determining the appropriate amounts of liquidity to maintain at the parent company and our subsidiaries. The liquidity stress testing process is an integral part of analyzing our potentialsubsidiaries to meet contractual and contingent cash outflows. We evaluate the liquidity requirementsoutflows under a range of scenarios with varying levels of severity and time horizons.scenarios. The scenarios we consider and utilize incorporate market-wide and Corporation-specific events, including potential credit rating downgrades for the parent company and our subsidiaries, and more severe events including potential resolution scenarios. The scenarios are based on our historical experience, experience of distressed and failed financial institutions, regulatory guidance, and both expected and unexpected future events.
The types of potential contractual and contingent cash outflows we consider in our scenarios may include, but are not limited to, upcoming contractual maturities of unsecured debt and reductions in new debt issuance;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.
We use a variety of metrics to determine the appropriate amounts of liquidity to maintain at the parent company and our subsidiaries. One metric we use to evaluate the appropriate level of liquidity at the parent company and NB Holdings is “time-to-required funding” (TTF). This debt coverage measure indicates the number of months the parent company can continue to meet its unsecured contractual obligations as they come due using only the parent company and NB Holdings’ liquidity sources without issuing any new debt or accessing any additional liquidity sources. We define unsecured contractual obligations for purposes of this metric as maturities of senior or subordinated debt issued or guaranteed by Bank of America Corporation. These include certain unsecured debt instruments, primarily structured liabilities, which we may be required to settle for cash prior to maturity. TTF was 49 months at December 31, 2017 compared to 35 months at December 31, 2016. The increase in TTF was driven by debt issuances outpacing maturities.
Net Stable Funding Ratio Final Rule
On October 20, 2020, the U.S. banking regulators issued a proposal for aAgencies finalized the Net Stable Funding Ratio (NSFR) requirement applicable, a rule requiring large banks to U.S. financial institutions followingmaintain a minimum level of stable funding over a one-year period. The final rule is intended to support the Basel Committee’sability 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 standard.rule is effective July 1, 2021. The proposed U.S. NSFR would apply to the Corporation on a consolidated basis and to our insured depository institutions. While the final requirement remains pending and is subject to change, if finalized as proposed, we expectThe Corporation expects to be in compliance within the final NSFR rule in the regulatory timeline. The standard is intendedtimeline provided and does not expect any significant impacts to reduce funding risk over a longer time horizon. The NSFR is designed to provide an appropriate amount of stable funding, generally capital and liabilities maturing beyond one year, given the mix of assets and off-balance sheet items.Corporation.
Diversified Funding SourcesContingency Planning
We fundhave 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 assets primarilyCapital 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 mixpotential resolution of depositsBank of America.
Strategic Risk Management
Strategic risk is embedded in every business and securedis one of the major risk categories along with credit, market, liquidity, compliance, operational and unsecured liabilities throughreputational 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 centralized, globally coordinated funding approach diversified acrosstimely 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 programs, markets, currenciesor services and investor groups.other strategic initiatives, and to provide formal review and
approval where required. With oversight by the Board and the ERC, executive management performs similar analyses throughout the year and evaluates changes to the financial forecast or the risk, capital or liquidity positions as deemed appropriate to balance and optimize achieving the targeted risk appetite, shareholder returns and maintaining the targeted financial strength. Proprietary models are used to measure the capital requirements for credit, country, market, operational and strategic risks. The allocated capital assigned to each business is based on its unique risk profile. With oversight by the Board, executive management assesses the risk-adjusted returns of each business in approving strategic and financial operating plans. The businesses use allocated capital to define business strategies and price products and transactions.
Capital Management
The primary benefitsCorporation manages its capital position so that its capital is more than adequate to support its business activities and aligns with risk, risk appetite and strategic planning. Additionally, we seek to maintain safety and soundness at all times, even under adverse scenarios, take advantage of organic growth opportunities, meet obligations to creditors and counterparties, maintain ready access to financial markets, continue to serve as a credit intermediary, remain a source of strength for our subsidiaries, and satisfy current and future regulatory capital requirements. Capital management is integrated into our risk and governance processes, as capital is a key consideration in the development of our centralized funding approach include greater control, reduced funding costs, wider name recognition by investorsstrategic plan, risk appetite and greater flexibility to meet the variable funding requirements of subsidiaries. Where regulations, time zone differences or other business considerations make parent company funding impractical, certain other subsidiaries may issue their own debt.risk limits.
We fundconduct an Internal Capital Adequacy Assessment Process (ICAAP) on a substantial portionperiodic basis. The ICAAP is a forward-looking assessment of our lending activitiesprojected 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 36.
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.
Bank of America 50


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 our deposits, whichMarch 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 transactions, including repurchase plans that satisfy the conditions of Rule 10b5-1 of the Securities Exchange Act of 1934, as amended (Exchange Act).
Regulatory Capital
As a financial services holding company, we are subject to regulatory capital rules, including Basel 3, issued by U.S. banking regulators. Basel 3 established minimum capital ratios and buffer requirements and outlined two methods of
calculating risk-weighted assets (RWA), the Standardized approach and the Advanced approaches. The Standardized approach relies primarily on supervisory risk weights based on exposure type, and the Advanced approaches determine risk weights based on internal models.
The Corporation's depository institution subsidiaries are also subject to the Prompt Corrective Action (PCA) framework. The Corporation and its primary affiliated banking entity, BANA, are Advanced approaches institutions under Basel 3 and are required to report regulatory risk-based capital ratios and RWA under both the Standardized and Advanced approaches. The approach that yields the lower ratio is used to assess capital adequacy including under the PCA framework. As of December 31, 2020, the CET1, Tier 1 capital and Total capital ratios for the Corporation were $1.31 trillionlower under the Standardized approach.
Minimum Capital Requirements
In order to avoid restrictions on capital distributions and $1.26 trilliondiscretionary bonus payments, the Corporation must meet risk-based capital ratio requirements that include a capital conservation buffer greater than 2.5 percent, plus any 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.
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, see Capital Management – Regulatory Developments on page 55.
Capital Composition and Ratios
Table 11 presents Bank of America Corporation’s capital ratios and related information in accordance with Basel 3 Standardized and Advanced approaches as measured at December 31, 20172020 and 2016. Deposits are primarily generated by our Consumer Banking, GWIM and Global Banking segments. These deposits are diversified by clients, product type and geography, and2019. For the majorityperiods presented herein, the Corporation met the definition 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, the Federal Housing Administration (FHA) and private-label investors, as well as FHLB loans.capitalized under current regulatory requirements.


51 Bank of America


Table 11Bank of America Corporation Regulatory Capital under Basel 3
Standardized
Approach
(1, 2)
Advanced
Approaches
(1)
Regulatory
Minimum
(3)
(Dollars in millions, except as noted)December 31, 2020
Risk-based capital metrics:
Common equity tier 1 capital$176,660 $176,660 
Tier 1 capital200,096 200,096 
Total capital (4)
237,936 227,685 
Risk-weighted assets (in billions)1,480 1,371 
Common equity tier 1 capital ratio11.9 %12.9 %9.5 %
Tier 1 capital ratio13.5 14.6 11.0 
Total capital ratio16.1 16.6 13.0 
Leverage-based metrics:
Adjusted quarterly average assets (in billions) (5)
$2,719 $2,719 
Tier 1 leverage ratio7.4 %7.4 %4.0 
Supplementary leverage exposure (in billions) (6)
$2,786 
Supplementary leverage ratio7.2 %5.0 
December 31, 2019
Risk-based capital metrics:
Common equity tier 1 capital$166,760 $166,760 
Tier 1 capital188,492 188,492 
Total capital (4)
221,230 213,098 
Risk-weighted assets (in billions)1,493 1,447 
Common equity tier 1 capital ratio11.2 %11.5 %9.5 %
Tier 1 capital ratio12.6 13.0 11.0 
Total capital ratio14.8 14.7 13.0 
Leverage-based metrics:
Adjusted quarterly average assets (in billions) (5)
$2,374 $2,374 
Tier 1 leverage ratio7.9 %7.9 %4.0 
Supplementary leverage exposure (in billions)$2,946 
Supplementary leverage ratio6.4 %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.
Bank of America 201752



Table 12Capital Composition under Basel 3
December 31
(Dollars in millions)20202019
Total common shareholders’ equity$248,414 $241,409 
CECL transitional amount (1)
4,213 — 
Goodwill, net of related deferred tax liabilities(68,565)(68,570)
Deferred tax assets arising from net operating loss and tax credit carryforwards(5,773)(5,193)
Intangibles, other than mortgage servicing rights, net of related deferred tax liabilities(1,617)(1,328)
Defined benefit pension plan net assets(1,164)(1,003)
Cumulative unrealized net (gain) loss related to changes in fair value of financial liabilities attributable to own creditworthiness,
net-of-tax
1,753 1,278 
Other(601)167 
Common equity tier 1 capital176,660 166,760 
Qualifying preferred stock, net of issuance cost23,437 22,329 
Other(1)(597)
Tier 1 capital200,096 188,492 
Tier 2 capital instruments22,213 22,538 
Qualifying allowance for credit losses (2)
15,649 10,229 
Other(22)(29)
Total capital under the Standardized approach237,936 221,230 
Adjustment in qualifying allowance for credit losses under the Advanced approaches (2)
(10,251)(8,132)
Total capital under the Advanced approaches$227,685 $213,098 
(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 13Risk-weighted Assets under Basel 3
Standardized Approach (1)
Advanced Approaches
Standardized Approach (1)
Advanced Approaches
December 31
(Dollars in billions)20202019
Credit risk$1,420 $896 $1,437 $858 
Market risk60 60 56 55 
Operational risk (2)
n/a372 n/a500 
Risks related to credit valuation adjustmentsn/a43 n/a34 
Total risk-weighted assets$1,480 $1,371 $1,493 $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.
(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
53 Bank of America


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 14Bank of America, N.A. Regulatory Capital under Basel 3
Standardized
Approach
(1, 2)
Advanced
Approaches
(1)
Regulatory
Minimum 
(3)
(Dollars in millions, except as noted)December 31, 2020
Risk-based capital metrics:
Common equity tier 1 capital$164,593 $164,593 
Tier 1 capital164,593 164,593 
Total capital (4)
181,370 170,922 
Risk-weighted assets (in billions)1,221 1,014 
Common equity tier 1 capital ratio13.5 %16.2 %7.0 %
Tier 1 capital ratio13.5 16.2 8.5 
Total capital ratio14.9 16.9 10.5 
Leverage-based metrics:
Adjusted quarterly average assets (in billions) (5)
$2,143 $2,143 
Tier 1 leverage ratio7.7 %7.7 %5.0 
Supplementary leverage exposure (in billions)$2,525 
Supplementary leverage ratio6.5 %6.0 




December 31, 2019
Risk-based capital metrics:
Common equity tier 1 capital$154,626 $154,626 
Tier 1 capital154,626 154,626 
Total capital (4)
166,567 158,665 
Risk-weighted assets (in billions)1,241 991 
Common equity tier 1 capital ratio12.5 %15.6 %7.0 %
Tier 1 capital ratio12.5 15.6 8.5 
Total capital ratio13.4 16.0 10.5 
Leverage-based metrics:
Adjusted quarterly average assets (in billions) (5)
$1,780 $1,780 
Tier 1 leverage ratio8.7 %8.7 %5.0 
Supplementary leverage exposure (in billions)$2,177 
Supplementary leverage ratio7.1 %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)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.
Total Loss-Absorbing Capacity Requirements
Total loss-absorbing capacity (TLAC) consists of the Corporation’s Tier 1 capital and eligible long-term debt issued directly by the Corporation. Eligible long-term debt for TLAC ratios is comprised of unsecured debt that has a remaining maturity of at least one year and satisfies additional requirements as prescribed in the TLAC final rule. As with the
risk-based capital ratios and SLR, the Corporation is required to maintain TLAC ratios in excess of minimum requirements plus applicable buffers to avoid restrictions on capital distributions and discretionary bonus payments. Table 15 presents the Corporation's TLAC and long-term debt ratios and related information as of December 31, 2020 and 2019.
Bank of America 54


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

TLAC (1)
Regulatory Minimum (2)
Long-term
Debt
Regulatory Minimum (3)
(Dollars in millions)December 31, 2020
Total eligible balance$405,153 $196,997 
Percentage of risk-weighted assets (4)
27.4 %22.0 %13.3 %8.5 %
Percentage of supplementary leverage exposure (5, 6)
14.5 9.5 7.1 4.5 
December 31, 2019
Total eligible balance$367,449 $171,349 
Percentage of risk-weighted assets (4)
24.6 %22.0 %11.5 %8.5 %
Percentage of supplementary leverage exposure (6)
12.5 9.5 5.8 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
plan. The Corporation is instead subject to automatic distribution limitations if its capital ratios fall below its buffer requirements, which include the SCB.
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 25 and Note 1 – Summary of Significant Accounting Principles to the Consolidated Financial Statements.
55 Bank of America


Standardized Approach for Measuring Counterparty Credit Risk
On June 30, 2020 the Corporation adopted 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 the interconnectedness between G-SIBs and 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.
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
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 tradingEuropean 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 is subject to certain 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.
Bank of America 56


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 Part I. Item 1A. Risk Factors – Coronavirus Disease on page 7 and Executive Summary – Recent Developments – COVID-19 Pandemic on page 25.
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 47. Under this governance framework, we have developed certain funding and liquidity risk management practices which include: maintaining liquidity at the parent company and selected subsidiaries, including our bank subsidiaries and other regulated entities; determining what amounts of liquidity are appropriate for these entities based on analysis of debt maturities and other potential cash outflows, including those that we may experience during stressed market conditions; diversifying funding sources, considering our asset profile and legal entity structure; and performing contingency planning.
NB Holdings Corporation
We have intercompany arrangements with certain key subsidiaries under which we transferred certain assets of Bank of America Corporation, as the parent company, which is a separate and distinct legal entity from our 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 in stressed conditions, through repurchase agreements or outright sales. We hold our GLS in legal entities that allow us to meet the liquidity requirements of our global businesses, and we consider the impact of potential regulatory, tax, legal and other restrictions that could limit the transferability of funds among entities.
Table 16 presents average GLS for the three months ended December 31, 2020 and 2019.
Table 16Average Global Liquidity Sources
Three Months Ended
December 31
(Dollars in billions)20202019
Bank entities$773 $454 
Nonbank and other entities (1)
170 122 
Total Average Global Liquidity Sources$943 $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.
57 Bank of America


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 17Average Global Liquidity Sources Composition
Three Months Ended
December 31
(Dollars in billions)20202019
Cash on deposit$322 $103 
U.S. Treasury securities141 98 
U.S. agency securities, mortgage-backed securities, and other investment-grade securities462 358 
Non-U.S. government securities18 17 
Total Average Global Liquidity Sources$943 $576 
Our GLS are primarily fundedsubstantially 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 securednet basis, through securities lendingwas $584 billion and repurchase agreements$464 billion for the three months ended December 31, 2020 and these2019. For the same periods, the average consolidated LCR was 122 percent and 116 percent. Our LCR fluctuates due to normal business flows from customer activity.
Liquidity Stress Analysis
We utilize liquidity stress analysis to assist us in determining the appropriate amounts will varyof 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 customer activityour historical experience, experience of distressed and market conditions. We believe funding these activitiesfailed financial institutions, regulatory guidance, and both expected and unexpected future events.
The types of potential contractual and contingent cash outflows we consider in theour 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 is more cost-efficientmarkets; potential deposit withdrawals; increased draws on loan commitments, liquidity facilities and less sensitive to changes inletters of credit; additional collateral that counterparties could call if our credit ratings than unsecured financing. Repurchase agreements are generallywere 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 often overnight. Disruptionsto our insured depository institutions. The Corporation expects to be in secured financing markets for financial institutions have occurred in prior market cycles which resulted in adverse changes in terms or significant reductionscompliance within the final NSFR rule 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 collateralregulatory timeline provided and pursuing longer durations, when appropriate. For more information on secured financing agreements, see Note 10 – Federal Funds Sold or Purchased, Securities Financing Agreements and Short-term Borrowingsdoes not expect any significant impacts to the Consolidated Financial Statements.Corporation.
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.
During 2017, we issued $53.3 billion of long-term debt consisting of $37.7 billion for Bank of America Corporation, substantially all of which was TLAC compliant, $8.2 billion for Bank of America, N.A. and $7.4 billion of other debt.
In December 2017, pursuant to a private offering, we exchanged $11.0 billion of outstanding long-term debt for new fixed/floating-rate senior notes, subject to certain terms and conditions, to extend maturities and improve the structure of this debt for TLAC purposes. Based on the attributes of the exchange transactions, the newly issued securities are not considered substantially different, for accounting purposes, from the exchanged securities. Therefore, there was no impact to our results of operations as any amounts paid to debt holders were capitalized, and the premiums or discounts on the outstanding long-term debt were carried over to the new securities and will be amortized over their contractual lives using a revised effective interest rate.
Table 19 presents our long-term debt by major currency at December 31, 2017 and 2016.
     
Table 19Long-term Debt by Major Currency
   
  December 31
(Dollars in millions)2017 2016
U.S. dollar$175,623
 $172,082
Euro35,481
 28,236
British pound7,016
 6,588
Australian dollar3,046
 2,900
Japanese yen2,993
 3,919
Canadian dollar1,966
 1,049
Other1,277
 2,049
Total long-term debt$227,402
 $216,823
Total long-term debt increased $10.6 billion, or five percent, in 2017, primarily due to issuances outpacing maturities. We may, from time to time, purchase outstanding debt instruments in various transactions, depending on prevailing market conditions, liquidity and other factors. In addition, our other regulated entities
may make markets in our debt instruments to provide liquidity for investors.
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 81.
We may also issue unsecured debt in the form of structured notes for client purposes, certain of which qualify as TLAC eligible debt. During 2017, we issued $5.4 billion of structured notes, which are debt obligations that pay investors returns linked to other debt or equity securities, indices, currencies or commodities. We typically hedge the returns we are obligated to pay on these liabilities with derivatives and/or investments in the underlying instruments, so that from a funding perspective, the cost is similar to our other unsecured long-term debt. We could be required to settle certain structured note obligations for cash or other securities prior to maturity under certain circumstances, which we consider for liquidity planning purposes. We believe, however, that a portion of such borrowings will remain outstanding beyond the earliest put or redemption date.
Substantially all of our senior and subordinated debt obligations contain no provisions that could trigger a requirement for an early repayment, require additional collateral support, result in changes to terms, accelerate maturity or create additional financial obligations upon an adverse change in our credit ratings, financial ratios, earnings, cash flows or stock price. For more information on long-term debt funding, see Note 11 – Long-term Debt to the Consolidated Financial Statements.
Contingency Planning
We have developed and maintain contingency plans that are designed to prepare us in advance to respond in the event of potential adverse economic, financial or market stress. These contingency plans include our Capital Contingency Plan and Financial Contingency and Recovery Plan, which provide monitoring, escalation, actions and routines designed to enable us to increase capital, access funding sources and reduce risk through consideration of potential options that include asset sales, business sales, capital or debt issuances, or other de-risking strategies. We also maintain a Resolution Plan to limit adverse systemic impacts that could be associated with a potential resolution of Bank of America.
Strategic Risk Management
Strategic risk is embedded in every business and is one of the major risk categories along with credit, market, liquidity, compliance, operational and reputational risks. This risk results from incorrect assumptions about external or internal factors, inappropriate business plans, ineffective business strategy execution, or failure to respond in a timely manner to changes in the regulatory, macroeconomic or competitive environments in the geographic locations in which we operate, such as competitor actions, changing customer preferences, product obsolescence and technology developments. Our strategic plan is consistent with our risk appetite, capital plan and liquidity requirements and specifically addresses strategic risks.
On an annual basis, the Board reviews and approves the strategic plan, capital plan, financial operating plan and Risk Appetite Statement. With oversight by the Board, executive management directs the lines of business to execute our strategic plan consistent with our core operating principles and risk appetite. The executive management team monitors business performance throughout the year and provides the Board with regular progress reports on whether strategic objectives and timelines are being met, including reports on strategic risks and if additional or alternative actions need to be considered or implemented. The regular executive reviews focus on assessing forecasted earnings and returns on capital, the current risk profile, current capital and liquidity requirements, staffing levels and changes required to support the strategic plan, stress testing results, and other qualitative factors such as market growth rates and peer analysis.
Significant strategic actions, such as capital actions, material acquisitions or divestitures, and resolution plans are reviewed and approved by the Board. At the business level, processes are in place to discuss the strategic risk implications of new, expanded or modified businesses, products or services and other strategic initiatives, and to provide formal review and
approval where required. With oversight by the Board and the ERC, executive management performs similar analyses throughout the year and evaluates changes to the financial forecast or the risk, capital or liquidity positions as deemed appropriate to balance and optimize achieving the targeted risk appetite, shareholder returns and maintaining the targeted financial strength. Proprietary models are used to measure the capital requirements for credit, country, market, operational and strategic risks. The allocated capital assigned to each business is based on its unique risk profile. With oversight by the Board, executive management assesses the risk-adjusted returns of each business in approving strategic and financial operating plans. The businesses use allocated capital to define business strategies and price products and transactions.
Capital Management
The Corporation manages its capital position so that its capital is more than adequate to support its business activities and aligns with risk, risk appetite and strategic planning. Additionally, we seek to maintain safety and soundness at all times, even under adverse scenarios, take advantage of organic growth opportunities, meet obligations to creditors and counterparties, maintain ready access to financial markets, continue to serve as a credit intermediary, remain a source of strength for our subsidiaries, and satisfy current and future regulatory capital requirements. Capital management is integrated into our risk and governance processes, as capital is a key consideration in the development of our strategic plan, risk appetite and risk limits.
We conduct an Internal Capital Adequacy Assessment Process (ICAAP) on a periodic basis. The ICAAP is a forward-looking assessment of our projected capital needs and resources, incorporating earnings, balance sheet and risk forecasts under baseline and adverse economic and market conditions. We utilize periodic stress tests to assess the potential impacts to our balance sheet, earnings, regulatory capital and liquidity under a variety of stress scenarios. We perform qualitative risk assessments to identify and assess material risks not fully captured in our forecasts or stress tests. We assess the potential capital impacts of proposed changes to regulatory capital requirements. Management assesses ICAAP results and provides documented quarterly assessments of the adequacy of our capital guidelines and capital position to the Board or its committees.
We periodically review capital allocated to our businesses and allocate capital annually during the strategic and capital planning processes. For more information, see Business Segment Operations on page 36.
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.
Bank of America 50


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 transactions, including repurchase plans that satisfy the conditions of Rule 10b5-1 of the Securities Exchange Act of 1934, as amended (Exchange Act).
Regulatory Capital
As a financial services holding company, we are subject to regulatory capital rules, including Basel 3, issued by U.S. banking regulators. Basel 3 established minimum capital ratios and buffer requirements and outlined two methods of
calculating risk-weighted assets (RWA), the Standardized approach and the Advanced approaches. The Standardized approach relies primarily on supervisory risk weights based on exposure type, and the Advanced approaches determine risk weights based on internal models.
The Corporation's depository institution subsidiaries are also subject to the Prompt Corrective Action (PCA) framework. The Corporation and its primary affiliated banking entity, BANA, are Advanced approaches institutions under Basel 3 and are required to report regulatory risk-based capital ratios and RWA under both the Standardized and Advanced approaches. The approach that yields the lower ratio is used to assess capital adequacy including under the PCA framework. As of December 31, 2020, the CET1, Tier 1 capital and Total capital ratios for the Corporation were lower under the Standardized approach.
Minimum Capital Requirements
In order to avoid restrictions on capital distributions and discretionary bonus payments, the Corporation must meet risk-based capital ratio requirements that include a capital conservation buffer greater than 2.5 percent, plus any 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.
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, see Capital Management – Regulatory Developments on page 55.
Capital Composition and Ratios
Table 11 presents Bank of America Corporation’s capital ratios and related information in accordance with Basel 3 Standardized and Advanced approaches as measured at December 31, 2020 and 2019. For the periods presented herein, the Corporation met the definition of well capitalized under current regulatory requirements.
51 Bank of America


Table 11Bank of America Corporation Regulatory Capital under Basel 3
Standardized
Approach
(1, 2)
Advanced
Approaches
(1)
Regulatory
Minimum
(3)
(Dollars in millions, except as noted)December 31, 2020
Risk-based capital metrics:
Common equity tier 1 capital$176,660 $176,660 
Tier 1 capital200,096 200,096 
Total capital (4)
237,936 227,685 
Risk-weighted assets (in billions)1,480 1,371 
Common equity tier 1 capital ratio11.9 %12.9 %9.5 %
Tier 1 capital ratio13.5 14.6 11.0 
Total capital ratio16.1 16.6 13.0 
Leverage-based metrics:
Adjusted quarterly average assets (in billions) (5)
$2,719 $2,719 
Tier 1 leverage ratio7.4 %7.4 %4.0 
Supplementary leverage exposure (in billions) (6)
$2,786 
Supplementary leverage ratio7.2 %5.0 
December 31, 2019
Risk-based capital metrics:
Common equity tier 1 capital$166,760 $166,760 
Tier 1 capital188,492 188,492 
Total capital (4)
221,230 213,098 
Risk-weighted assets (in billions)1,493 1,447 
Common equity tier 1 capital ratio11.2 %11.5 %9.5 %
Tier 1 capital ratio12.6 13.0 11.0 
Total capital ratio14.8 14.7 13.0 
Leverage-based metrics:
Adjusted quarterly average assets (in billions) (5)
$2,374 $2,374 
Tier 1 leverage ratio7.9 %7.9 %4.0 
Supplementary leverage exposure (in billions)$2,946 
Supplementary leverage ratio6.4 %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.
Bank of America 52


Table 12Capital Composition under Basel 3
December 31
(Dollars in millions)20202019
Total common shareholders’ equity$248,414 $241,409 
CECL transitional amount (1)
4,213 — 
Goodwill, net of related deferred tax liabilities(68,565)(68,570)
Deferred tax assets arising from net operating loss and tax credit carryforwards(5,773)(5,193)
Intangibles, other than mortgage servicing rights, net of related deferred tax liabilities(1,617)(1,328)
Defined benefit pension plan net assets(1,164)(1,003)
Cumulative unrealized net (gain) loss related to changes in fair value of financial liabilities attributable to own creditworthiness,
net-of-tax
1,753 1,278 
Other(601)167 
Common equity tier 1 capital176,660 166,760 
Qualifying preferred stock, net of issuance cost23,437 22,329 
Other(1)(597)
Tier 1 capital200,096 188,492 
Tier 2 capital instruments22,213 22,538 
Qualifying allowance for credit losses (2)
15,649 10,229 
Other(22)(29)
Total capital under the Standardized approach237,936 221,230 
Adjustment in qualifying allowance for credit losses under the Advanced approaches (2)
(10,251)(8,132)
Total capital under the Advanced approaches$227,685 $213,098 
(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 13Risk-weighted Assets under Basel 3
Standardized Approach (1)
Advanced Approaches
Standardized Approach (1)
Advanced Approaches
December 31
(Dollars in billions)20202019
Credit risk$1,420 $896 $1,437 $858 
Market risk60 60 56 55 
Operational risk (2)
n/a372 n/a500 
Risks related to credit valuation adjustmentsn/a43 n/a34 
Total risk-weighted assets$1,480 $1,371 $1,493 $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.
(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
53 Bank of America


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 14Bank of America, N.A. Regulatory Capital under Basel 3
Standardized
Approach
(1, 2)
Advanced
Approaches
(1)
Regulatory
Minimum 
(3)
(Dollars in millions, except as noted)December 31, 2020
Risk-based capital metrics:
Common equity tier 1 capital$164,593 $164,593 
Tier 1 capital164,593 164,593 
Total capital (4)
181,370 170,922 
Risk-weighted assets (in billions)1,221 1,014 
Common equity tier 1 capital ratio13.5 %16.2 %7.0 %
Tier 1 capital ratio13.5 16.2 8.5 
Total capital ratio14.9 16.9 10.5 
Leverage-based metrics:
Adjusted quarterly average assets (in billions) (5)
$2,143 $2,143 
Tier 1 leverage ratio7.7 %7.7 %5.0 
Supplementary leverage exposure (in billions)$2,525 
Supplementary leverage ratio6.5 %6.0 




December 31, 2019
Risk-based capital metrics:
Common equity tier 1 capital$154,626 $154,626 
Tier 1 capital154,626 154,626 
Total capital (4)
166,567 158,665 
Risk-weighted assets (in billions)1,241 991 
Common equity tier 1 capital ratio12.5 %15.6 %7.0 %
Tier 1 capital ratio12.5 15.6 8.5 
Total capital ratio13.4 16.0 10.5 
Leverage-based metrics:
Adjusted quarterly average assets (in billions) (5)
$1,780 $1,780 
Tier 1 leverage ratio8.7 %8.7 %5.0 
Supplementary leverage exposure (in billions)$2,177 
Supplementary leverage ratio7.1 %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)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.
Total Loss-Absorbing Capacity Requirements
Total loss-absorbing capacity (TLAC) consists of the Corporation’s Tier 1 capital and eligible long-term debt issued directly by the Corporation. Eligible long-term debt for TLAC ratios is comprised of unsecured debt that has a remaining maturity of at least one year and satisfies additional requirements as prescribed in the TLAC final rule. As with the
risk-based capital ratios and SLR, the Corporation is required to maintain TLAC ratios in excess of minimum requirements plus applicable buffers to avoid restrictions on capital distributions and discretionary bonus payments. Table 15 presents the Corporation's TLAC and long-term debt ratios and related information as of December 31, 2020 and 2019.
Bank of America 54


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

TLAC (1)
Regulatory Minimum (2)
Long-term
Debt
Regulatory Minimum (3)
(Dollars in millions)December 31, 2020
Total eligible balance$405,153 $196,997 
Percentage of risk-weighted assets (4)
27.4 %22.0 %13.3 %8.5 %
Percentage of supplementary leverage exposure (5, 6)
14.5 9.5 7.1 4.5 
December 31, 2019
Total eligible balance$367,449 $171,349 
Percentage of risk-weighted assets (4)
24.6 %22.0 %11.5 %8.5 %
Percentage of supplementary leverage exposure (6)
12.5 9.5 5.8 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
plan. The Corporation is instead subject to automatic distribution limitations if its capital ratios fall below its buffer requirements, which include the SCB.
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 25 and Note 1 – Summary of Significant Accounting Principles to the Consolidated Financial Statements.
55 Bank of America


Standardized Approach for Measuring Counterparty Credit Risk
On June 30, 2020 the Corporation adopted 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 the interconnectedness between G-SIBs and 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.
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
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 is subject to certain 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.
Bank of America 56


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 Part I. Item 1A. Risk Factors – Coronavirus Disease on page 7 and Executive Summary – Recent Developments – COVID-19 Pandemic on page 25.
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 47. Under this governance framework, we have developed certain funding and liquidity risk management practices which include: maintaining liquidity at the parent company and selected subsidiaries, including our bank subsidiaries and other regulated entities; determining what amounts of liquidity are appropriate for these entities based on analysis of debt maturities and other potential cash outflows, including those that we may experience during stressed market conditions; diversifying funding sources, considering our asset profile and legal entity structure; and performing contingency planning.
NB Holdings Corporation
We have intercompany arrangements with certain key subsidiaries under which we transferred certain assets of Bank of America Corporation, as the parent company, which is a separate and distinct legal entity from our 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 in stressed conditions, through repurchase agreements or outright sales. We hold our GLS in legal entities that allow us to meet the liquidity requirements of our global businesses, and we consider the impact of potential regulatory, tax, legal and other restrictions that could limit the transferability of funds among entities.
Table 16 presents average GLS for the three months ended December 31, 2020 and 2019.
Table 16Average Global Liquidity Sources
Three Months Ended
December 31
(Dollars in billions)20202019
Bank entities$773 $454 
Nonbank and other entities (1)
170 122 
Total Average Global Liquidity Sources$943 $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.
57 Bank of America


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 17Average Global Liquidity Sources Composition
Three Months Ended
December 31
(Dollars in billions)20202019
Cash on deposit$322 $103 
U.S. Treasury securities141 98 
U.S. agency securities, mortgage-backed securities, and other investment-grade securities462 358 
Non-U.S. government securities18 17 
Total Average Global Liquidity Sources$943 $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 same periods, the average consolidated LCR was 122 percent and 116 percent. Our LCR fluctuates due to normal business flows from customer activity.
Liquidity Stress Analysis
We utilize liquidity stress analysis to assist us in determining the appropriate amounts of liquidity to maintain at the parent company and our subsidiaries to meet contractual and contingent cash outflows under a range of scenarios. The scenarios we consider and utilize incorporate market-wide and Corporation-specific events, including potential credit rating downgrades for the parent company and our subsidiaries, and more severe events including potential resolution scenarios. The scenarios are based on our historical experience, experience of distressed and failed financial institutions, regulatory guidance, and both expected and unexpected future events.
The types of potential contractual and contingent cash outflows we consider in our scenarios may include, but are not limited to, upcoming contractual maturities of unsecured debt and reductions in new debt 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 variable funding requirements of subsidiaries. Where regulations, time zone differences or other business considerations make parent company funding impractical, certain other subsidiaries may issue their own debt.
We fund a substantial portion of our lending activities through our deposits, which were $1.80 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
Bank of America 58


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.
Substantially all of our senior and subordinated debt obligations contain no provisions that could trigger a requirement for an early repayment, require additional collateral support, result in changes to terms, accelerate maturity or create additional financial obligations upon an adverse change in our credit ratings, financial ratios, earnings, cash flows or stock price. For more information on long-term debt funding, including issuances and maturities and redemptions, see Note 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 82.
Contingency Planning
We maintain contingency funding plans that outline our potential responses to liquidity stress events at various levels of severity. These policies and plans are based on stress scenarios and include potential funding strategies and communication and notification procedures that we would implement in the event we experienced stressed liquidity conditions. We periodically review and test the contingency funding plans to validate efficacy and assess readiness.
Our U.S. bank subsidiaries can access contingency funding through the Federal Reserve Discount Window. Certain non-U.S. subsidiaries have access to central bank facilities in the jurisdictions in which they operate. While we do not rely on these sources in our liquidity modeling, we maintain the policies, procedures and governance processes that would enable us to access these sources if necessary.
Credit Ratings
Our borrowing costs and ability to raise funds are impacted by our credit ratings. In addition, credit ratings may be important to customers or counterparties when we compete in certain markets and when we seek to engage in certain transactions, including over-the-counter (OTC) derivatives. Thus, it is our objective to maintain high-quality credit ratings, and management maintains an active dialogue with the major rating agencies.
Credit ratings and outlooks are opinions expressed by rating agencies on our creditworthiness and that of our obligations or securities, including long-term debt, short-term borrowings, preferred stock and other securities, including asset securitizations. Our credit ratings are subject to ongoing review by the rating agencies, and they consider a number of factors, including our own financial strength, performance, prospects and operations as well as factors not under our control. The rating agencies could make adjustments to our ratings at any time, and

Bank of America 201752


they provide no assurances that they will maintain our ratings at current levels.
Other factors that influence our credit ratings include changes to the rating agencies’ methodologies for our industry or certain security types; the rating agencies’ assessment of the general operating environment for financial services companies; our relative positions in the markets in which we compete; our various risk exposures and risk management policies and activities; pending litigation and other contingencies or potential tail risks; our reputation; our liquidity position, diversity of funding sources and funding costs; the current and expected level and volatility of our earnings; our capital position and capital management practices; our corporate governance; the sovereign credit ratings of the U.S. government; current or future regulatory and legislative
59 Bank of America


initiatives; and the agencies’ views on whether the U.S. government would provide meaningful support to the Corporation or its subsidiaries in a crisis.
On December 6, 2017, Moody’s Investors Services, Inc. (Moody’s) upgraded the long-term ratings of Bank of America Corporation and certain subsidiaries, including BANA, by one notch, moving their senior debt ratings to A3 and Aa3, respectively. The upgrade was based on the agency’s expectations for continued improvement in the Corporation’s profitability and management’s continued commitment to a conservative risk profile. At the same time, Moody’s affirmed all the short-term ratings for Bank of America Corporation and its rated subsidiaries. Moody’s concurrently moved the outlook on the ratings to stable. This action
concluded the review for upgrade that Moody’s initiated on September 12, 2017.
On NovemberApril 22, 2017, Standard & Poor’s Global Ratings (S&P) upgraded Bank of America Corporation’s long-term senior debt rating to A- from BBB+ following the agency’s periodic review of our ratings. S&P cited the improvement in the Corporation’s risk profile, while continuing to improve profitability metrics, as the driver for the upgrade, including tightening underwriting standards, reducing exposure to market risk, growing conservatively, and resolving legacy legal issues. S&P concurrently affirmed the ratings of the Corporation’s rated core operating subsidiaries, including BANA, MLPF&S, MLI and Bank of America Merrill Lynch International Limited. Those entities were affirmed rather than upgraded since their ratings had reached an inflection point under S&P’s methodology where the one notch S&P added to its assessment of our intrinsic creditworthiness (called an Unsupported Group Credit Profile, or UGCP) resulted in the subsidiaries receiving one less notch of support uplift under the agency’s Additional Loss Absorbing Capacity framework, thus leaving those entities’ ratings unchanged. S&P retained a stable outlook on the ratings of Bank of America Corporation and its core operating subsidiaries following the upgrade.
On September 28, 2017,2020, Fitch Ratings (Fitch) completed its latest review of 12 large, complex securities trading and universal banks in the U.S., including Bank of America.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 for the Corporation and upgraded its long-term and short-term senior debt ratings of BankMLI 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
changes under criteria observation are the sole result of Americabank 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 its rating for the subordinated debt of BANA at A. This rating had remained under criteria observation following Fitch’s broader rating actions.
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 rated subsidiaries including BANA, and maintained its stable outlook on those ratings.from Standard & Poor’s Global Ratings also did not change during 2020.
Table 2018 presents the Corporation’s current long-term/short-term senior debt ratings and outlooks expressed by the rating agencies.
Table 18
Table 20Senior Debt Ratings
MoodysMoody’s Investors Service
Standard & PoorsPoor’s Global Ratings
Fitch Ratings
Long-termShort-termOutlookLong-termShort-termOutlookLong-termShort-termOutlook
Bank of America CorporationA3         A2P-2        P-1StableA-A-2StableA         A+F1Stable
Bank of America, N.A.Aa3        Aa2P-1StableA+A-1StableA+        AA-F1        F1+Stable
Bank of America Europe Designated Activity Company         NR        NR        NR        A+        A-1      Stable        AA-        F1+      Stable
Merrill Lynch, Pierce, Fenner & Smith IncorporatedNRNRNRA+A-1StableA+        AA-F1        F1+Stable
BofA Securities, Inc.         NR        NR        NR        A+        A-1      Stable        AA-        F1+      Stable
Merrill Lynch InternationalNRNRNRA+A-1StableA        AA-F1        F1+Stable
BofA Securities Europe SA         NR        NR        NR        A+        A-1      Stable        AA-        F1+      Stable
NR = not rated
A reduction in certain of our credit ratings or the ratings of certain asset-backed securitizations may have a material adverse effect on our liquidity, potential loss of access to credit markets, the related cost of funds, our businesses and on certain trading revenues, particularly in those businesses where counterparty creditworthiness is critical. In addition, under the terms of certain OTC derivative contracts and other trading agreements, in the event of downgrades of our or our rated subsidiaries’ credit ratings, the counterparties to those agreements may require us to provide additional collateral, or to terminate these contracts or agreements, which could cause us to sustain losses and/or adversely impact our liquidity. If the short-term credit ratings of our parent company, bank or broker-dealer subsidiaries were downgraded by one or more levels, the potential loss of access to short-term funding sources such as repo financing and the effect on our incremental cost of funds could be material.

While certain potential impacts are contractual and quantifiable, the full scope of the consequences of a credit rating downgrade to a financial institution is inherently uncertain, as it
depends upon numerous dynamic, complex and inter-related factors and assumptions, including whether any downgrade of a company’s long-term credit ratings precipitates downgrades to its short-term credit ratings, and assumptions about the potential behaviors of various customers, investors and counterparties. For more information on potential impacts of credit rating downgrades, see Liquidity Risk – Time-to-required Funding and Liquidity Stress Analysis on page 51.58.
For more information on the additional collateral and termination payments that could be required in connection with certain OTCover-the-counter derivative contracts and other trading agreements as a resultin the event of such a credit rating downgrade, see Note 23 – Derivatives to the Consolidated Financial Statements.Statements and Part I. Item 1A. Risk Factors.

Bank of America 60


Common Stock Dividends
For a summary of our declared quarterly cash dividends on common stock during 20172020 and through February 22, 2018,24, 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.
BofA Finance and each of the Trusts are finance subsidiaries, have no independent assets, revenues or 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, Item 1. Business – Insolvency and the Orderly Liquidation Authority on page 5 and Part I. Item 1A. Risk Factors – Liquidity on page 9.



53Bank of America 2017



Credit Risk Management
Credit risk is the risk of loss arising from the inability or failure of a borrower or counterparty to meet its obligations. Credit risk can also arise from operational failures that result in an erroneous advance, commitment or investment of funds. We define the credit exposure to a borrower or counterparty as the loss potential arising from all product classifications including loans and leases, deposit overdrafts, derivatives, assets held-for-sale and unfunded lending commitments which include loan commitments, letters of credit and financial guarantees. Derivative positions are recorded at fair value and assets held-for-sale are recorded at either fair value or the lower of cost or fair value. Certain loans and unfunded commitments are accounted for under the fair value option. Credit risk for categories of assets carried at fair value is not accounted for as part of the allowance for credit losses but as part of the fair value adjustments recorded in earnings. For derivative positions, our credit risk is measured as the net cost in the event the counterparties with contracts in which we are in a gain position fail to perform under the terms of those contracts. We use the current fair value to represent credit exposure without giving consideration to future mark-to-market changes. The credit risk amounts take into consideration the effects of legally enforceable master netting agreements and cash collateral. Our consumer and commercial credit extension and review procedures encompass funded and unfunded credit exposures. For more information on derivatives and credit extension commitments, see Note 23 – Derivatives and Note 12 – Commitments and Contingencies to the Consolidated Financial Statements.
We manage credit risk based on the risk profile of the borrower or counterparty, repayment sources, the nature of underlying collateral, and other support given current events, conditions and expectations. We classify our portfolios as either consumer or commercial and monitor credit risk in each as discussed below.
We refine our underwriting and credit risk management practices as well as credit standards to meet the changing economic environment. To mitigate losses and enhance customer support in our consumer businesses, we have in place collection programs and loan modification and customer assistance infrastructures. We utilize a number of actions to mitigate losses in the commercial businesses including increasing the frequency and intensity of portfolio monitoring, hedging activity and our practice of transferring management of deteriorating commercial exposures to independent special asset officers as credits enter criticized categories.categories.
For more information on our credit risk management activities, see Consumer Portfolio Credit Risk Management below, Commercial Portfolio Credit Risk Management on page 63, 68, Non-U.S. Portfolio on page 70, Provision for Credit Losses on page 72, 74, Allowance for Credit Losses on page 72,76, and Note 45 – Outstanding Loans and Leases andNote 5 – Allowance for Credit Lossesto the Consolidated Financial Statements.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.
61 Bank of America


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.
To support our customers, we implemented various loan modification programs and other forms of support beginning in March 2020, including offering 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 2017, hurricanes2020.
However, economic recovery remains uneven, with certain sectors of the economy more significantly impacted from the southern United Statespandemic (e.g., travel and entertainment). As a result, we have experienced increases in commercial reservable criticized utilized exposures driven by industries most heavily impacted by COVID-19. Also, we have seen modest increases 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.
The pandemic and its full impact on the Caribbean, bringing widespread floodingglobal 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 wind damage to communities across the region. In the weeks after these storms, we supported our customersduration of this health crisis. However, ongoing virus containment efforts and clients in these communities by providing mobile financial centers and ATMs. In addition, we provided support for the recovery efforts including proactive fee refunds in affected areas,vaccination progress, as well as home loanthe 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 25 and other credit assistance, including payment deferrals, for impacted individuals and businesses. We do not believe that these storms will have a material financial impactPart I. Item 1A. Risk Factors – Coronavirus Disease on the Corporation.page 7.


Consumer Portfolio Credit Risk Management
Credit risk management for the consumer portfolio begins with initial underwriting and continues throughout a borrower’s credit cycle. Statistical techniques in conjunction with experiential judgment are used in all aspects of portfolio management including underwriting, product pricing, risk appetite, setting credit limits, and establishing operating processes and metrics to quantify and balance risks and returns. Statistical models are built using detailed behavioral information from external sources such as credit bureaus and/or internal historical experience and are a component of our consumer credit risk management process. These models are used in part to assist in making both new and ongoing credit decisions, as well as portfolio management strategies, including authorizations and line management, collection practices and strategies, and determination of the allowance for loan and lease losses and allocated capital for credit risk.
Consumer Credit Portfolio
Improvement in the U.S. unemployment rateWhile COVID-19 is severely impacting economic activity, and home prices continuedis contributing to increasing nonperforming loans within certain consumer portfolios, it did not have a significant impact on consumer portfolio charge-offs during 2017 resulting in improved2020 due to payment deferrals and government stimulus benefits. However, COVID-19 could lead to adverse impacts to credit quality andmetrics 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 losses in the consumer real estate portfolio, partially offset by seasoning and loan growth in the U.S. credit card portfolio compared to 2016.losses.
Improved credit quality, the sale of the non-U.S. consumer credit card business in 2017, continued loan balance run-off and sales in the consumer real estate portfolio drove a $839 million decrease in theThe consumer allowance for loan and lease losses increased $5.5 billion in 20172020 to $5.4$10.1 billion at December 31, 2017.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 72.76.
For more information on our accounting policies regarding delinquencies, nonperforming status, charge-offs, and troubled debt restructurings (TDRs)TDRs for the consumer portfolio, including thoseas well as interest accrual policies and delinquency status for loan modifications related to bankruptcy and repossession,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 2119 presents our outstanding consumer loans and leases, consumer nonperforming loans and accruing consumer loans past due 90 days or more. Nonperforming
Bank of America 62


Table 19Consumer Credit Quality
 OutstandingsNonperformingAccruing Past Due
90 Days or More
December 31
(Dollars in millions)202020192020201920202019
Residential mortgage (1)
$223,555 $236,169 $2,005 $1,470 $762 $1,088 
Home equity 34,311 40,208 649 536  — 
Credit card78,708 97,608 n/an/a903 1,042 
Direct/Indirect consumer (2)
91,363 90,998 71 47 33 33 
Other consumer124 192  —  — 
Consumer loans excluding loans accounted for under the fair value option$428,061 $465,175 $2,725 $2,053 $1,698 $2,163 
Loans accounted for under the fair value option (3)
735 594 
Total consumer loans and leases$428,796 $465,769 
Percentage of outstanding consumer loans and leases (4)
n/an/a0.64 %0.44 %0.40 %0.47 %
Percentage of outstanding consumer loans and leases, excluding fully-insured loan portfolios (4)
n/an/a0.65 0.46 0.22 0.24 
(1)Residential mortgage loans do not include past due consumer credit card loans, other unsecured loans and in general, consumer loans not secured by real estate (bankruptcy loans are included) as these loans are typically charged off no later than the end of the month in which the loan becomes 180 days past due. Real estate-secured past due consumer loans that are insured by the FHA or individually insured under long-term standby agreements with Fannie Mae (FNMA) and Freddie Mac (FHLMC) (collectively, the fully-insured loan portfolio) are reported as accruing as opposed to nonperforming since the principal repayment is insured. Fully-insured loans included in accruing past due 90 days or more are 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 from our repurchases of delinquent FHA loans pursuant to our servicing agreements with the Government National Mortgage Association (GNMA). Additionally, nonperforminginclude auto and specialty lending loans and accruing balances past due 90 days or more do not include the PCI loan portfolio orleases 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 even though the customer may be contractually past due.
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 PCI loans,the fair value option, see Consumer Portfolio Credit Risk ManagementNote 21Purchased Credit-impaired Loan Portfolio on page 60 and Note 4 – Outstanding Loans and LeasesFair Value Option to the Consolidated Financial Statements.


Bank of America 201754


             
Table 21Consumer Credit Quality           
             
 Outstandings Nonperforming 
Accruing Past Due
90 Days or More
 December 31
(Dollars in millions)2017 2016 2017 2016 2017 2016
Residential mortgage (1)
$203,811
 $191,797
 $2,476
 $3,056
 $3,230
 $4,793
Home equity 57,744
 66,443
 2,644
 2,918
 
 
U.S. credit card96,285
 92,278
 n/a
 n/a
 900
 782
Non-U.S. credit card
 9,214
 n/a
 n/a
 
 66
Direct/Indirect consumer (2)
93,830
 94,089
 46
 28
 40
 34
Other consumer (3)
2,678
 2,499
 
 2
 
 4
Consumer loans excluding loans accounted for under the fair value option$454,348
 $456,320
 $5,166
 $6,004
 $4,170
 $5,679
Loans accounted for under the fair value option (4)
928
 1,051
        
Total consumer loans and leases (5)
$455,276
 $457,371
        
Percentage of outstanding consumer loans and leases (6)
n/a
 n/a
 1.14% 1.32% 0.92% 1.24%
Percentage of outstanding consumer loans and leases, excluding PCI and fully-insured loan portfolios (6)
n/a
 n/a
 1.23
 1.45
 0.22
 0.21
(1)
Residential mortgage loans accruing past due 90 days or more are fully-insured loans. At December 31, 2017 and 2016, residential mortgage includes $2.2 billion and $3.0 billion of loans on which interest had been curtailed by the FHA, and therefore were no longer accruing interest, although principal was still insured, and $1.0 billion and $1.8 billion of loans on which interest was still accruing.
(2)
Outstandings include auto and specialty lending loans of $49.9 billion and $48.9 billion, unsecured consumer lending loans of $469 million and $585 million, U.S. securities-based lending loans of $39.8 billion and $40.1 billion, non-U.S. consumer loans of $3.0 billion for both periods, student loans of $0 and $497 million and other consumer loans of $684 million and $1.1 billion at December 31, 2017 and 2016.
(3)
Outstandings include consumer leases of $2.5 billion and $1.9 billion, consumer overdrafts of $163 million and $157 million and consumer finance loans of $0 and $465 million at December 31, 2017 and 2016.
(4)
Consumer loans accounted for under the fair value option include residential mortgage loans of $567 million and $710 million and home equity loans of $361 million and $341 million at December 31, 2017 and 2016. For more information on the fair value option, see Note 21 – Fair Value Option to the Consolidated Financial Statements.
(5)
Includes $9.2 billion of non-U.S. credit card loans, which were included in assets of business held for sale on the Consolidated Balance Sheet at December 31, 2016. In 2017, the Corporation sold its non-U.S. consumer credit card business.
(6) Balances exclude(4)Excludes consumer loans accounted for under the fair value option. At December 31, 20172020 and 2016, $262019, $11 million and $48$6 million of loans accounted for under the fair value option were past due 90 days or more and not accruing interest.
n/a = not applicable
Table 2220 presents net charge-offs and related ratios for consumer loans and leases.
Table 20Consumer Net Charge-offs and Related Ratios
Net Charge-offs
Net Charge-off Ratios (1)
(Dollars in millions)2020201920202019
Residential mortgage$(30)$(47)(0.01)%(0.02)%
Home equity(73)(358)(0.19)(0.81)
Credit card2,349 2,948 2.76 3.12 
Direct/Indirect consumer122 209 0.14 0.23 
Other consumer284 234 n/mn/m
Total$2,652 $2,986 0.59 0.66 
         
Table 22Consumer Net Charge-offs and Related Ratios      
         
  
Net Charge-offs (1)
 
Net Charge-off Ratios (1, 2)
(Dollars in millions)2017 2016 2017 2016
Residential mortgage$(100) $131
 (0.05)% 0.07%
Home equity213
 405
 0.34
 0.57
U.S. credit card2,513
 2,269
 2.76
 2.58
Non-U.S. credit card75
 175
 1.91
 1.83
Direct/Indirect consumer211
 134
 0.23
 0.15
Other consumer166
 205
 6.35
 8.95
Total$3,078
 $3,319
 0.68
 0.74
(1)
Net charge-offs exclude write-offs in the PCI loan portfolio. For more information, see Consumer Portfolio Credit Risk Management – Purchased Credit-impaired Loan Portfolio on page 60.
(2)
Net charge-off ratios are calculated as net charge-offs divided by average outstanding loans and leases excluding loans accounted for under the fair value option.
Net charge-offs, as shown in Tables 22 and 23, exclude write-offs in the PCI loan portfolio of $131 million and $144 million in residential mortgage and $76 million and $196 million in home equity for 2017 and 2016. (1)Net charge-off ratios includingare calculated as net charge-offs divided by average outstanding loans and leases excluding loans accounted for under the PCI write-offs were 0.02 percent and 0.15 percent for residential mortgage and 0.47 percent and 0.84 percent for home equity in 2017 and 2016. For more information on PCI write-offs, see Consumer Portfolio Credit Risk Management – Purchased Credit-impaired Loan Portfolio on page 60.fair value option.
n/m = not meaningful
Table 2321 presents outstandings, nonperforming balances, net charge-offs, allowance for loan and leasecredit losses and provision for loan and leasecredit 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, LTV, FICOloan-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 government-sponsored enterpriseGSE 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 run-offrunoff portfolios. Core loans as reported in Table 2321 include loans held in the Consumer Banking and GWIM segments, as well as loans held for ALM activities in All Other. For more information, see Note 4 – Outstanding Loans and Leases to the Consolidated Financial Statements.

55Bank of America 2017



As shown in Table 23,21, outstanding core consumer real estate loans increased $15.0decreased $15.4 billion during 20172020 driven by an increasea decrease of $20.1$10.5 billion in residential mortgage partially offset byand a $5.1$4.9 billion decrease in home equity.
             
Table 23
Consumer Real Estate Portfolio (1)
    
       
  Outstandings Nonperforming 
Net Charge-offs (2)
  December 31 
(Dollars in millions)2017 2016 2017 2016 2017 2016
Core portfolio 
  
  
  
    
Residential mortgage$176,618
 $156,497
 $1,087
 $1,274
 $(45) $(29)
Home equity44,245
 49,373
 1,079
 969
 100
 113
Total core portfolio220,863
 205,870
 2,166
 2,243
 55
 84
Non-core portfolio   
  
  
    
Residential mortgage27,193
 35,300
 1,389
 1,782
 (55) 160
Home equity13,499
 17,070
 1,565
 1,949
 113
 292
Total non-core portfolio40,692
 52,370
 2,954
 3,731
 58
 452
Consumer real estate portfolio 
  
  
  
    
Residential mortgage203,811
 191,797
 2,476
 3,056
 (100) 131
Home equity57,744
 66,443
 2,644
 2,918
 213
 405
Total consumer real estate portfolio$261,555
 $258,240
 $5,120
 $5,974
 $113
 $536
             
      
Allowance for Loan
and Lease Losses
 
Provision for Loan
and Lease Losses
      December 31 
      2017 2016 2017 2016
Core portfolio           
Residential mortgage    $218
 $252
 $(79) $(98)
Home equity    367
 560
 (91) 10
Total core portfolio    585
 812
 (170) (88)
Non-core portfolio     
  
    
Residential mortgage    483
 760
 (201) (86)
Home equity    652
 1,178
 (339) (84)
Total non-core portfolio    1,135
 1,938
 (540) (170)
Consumer real estate portfolio     
  
    
Residential mortgage    701
 1,012
 (280) (184)
Home equity    1,019
 1,738
 (430) (74)
Total consumer real estate portfolio    $1,720
 $2,750
 $(710) $(258)
(1)63 Bank of America
Outstandings and nonperforming loans exclude loans accounted for under the fair value option. Consumer loans accounted for under the fair value option included residential mortgage loans of $567 million and $710 million and home equity loans of $361 million and $341 million at December 31, 2017 and 2016. For more information, see Note 21 – Fair Value Option to the Consolidated Financial Statements.
(2)


Table 21
Consumer Real Estate Portfolio (1)
OutstandingsNonperforming
December 31Net Charge-offs
(Dollars in millions)202020192020201920202019
Core portfolio    
Residential mortgage$215,273 $225,770 $1,390 $883 $(25)$
Home equity30,328 35,226 462 363 (6)51 
Total core portfolio245,601 260,996 1,852 1,246 (31)58 
Non-core portfolio   
Residential mortgage8,282 10,399 615 587 (5)(54)
Home equity3,983 4,982 187 173 (67)(409)
Total non-core portfolio12,265 15,381 802 760 (72)(463)
Consumer real estate portfolio    
 Residential mortgage223,555 236,169 2,005 1,470 (30)(47)
 Home equity34,311 40,208 649 536 (73)(358)
Total consumer real estate portfolio$257,866 $276,377 $2,654 $2,006 $(103)$(405)
Allowance for Loan
and Lease Losses
Provision for Loan
and Lease Losses
December 31
2020201920202019
Core portfolio
Residential mortgage$374 $229 $136 $22 
Home equity599 120 135 (58)
Total core portfolio973 349 271 (36)
Non-core portfolio  
Residential mortgage85 96 75 (134)
 Home equity (2)
(63)101 (21)(510)
Total non-core portfolio22 197 54 (644)
Consumer real estate portfolio  
 Residential mortgage459 325 211 (112)
 Home equity (3)
536 221 114 (568)
Total consumer real estate portfolio$995 $546 $325 $(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.
Net charge-offs exclude write-offs in the PCI loan portfolio. For more information, see Consumer Portfolio Credit Risk Management – Purchased Credit-impaired Loan Portfolio on page 60.
We believe that the presentation of information adjusted to exclude the impact of the PCI loan portfolio, the fully-insured loan portfolio and loans accounted for under the fair value option is more representative of the ongoing operations and credit quality of the business. As a result, in the following tables and discussions of the residential mortgage and home equity portfolios, we exclude loans accounted for under the fair value option and provide information that excludes the impact of the PCI loan portfolio, the fully-insured loan portfolio and loans accounted for under the fair value option in certain credit quality statistics. We separately disclose information on the PCI loan portfolio on page 60.
Residential Mortgage
The residential mortgage portfolio makesmade up the largest percentage of our consumer loan portfolio at 4552 percent of consumer loans and leases at December 31, 2017.2020. Approximately 3752 percent of the residential mortgage portfolio iswas in Consumer Banking and approximately 3540 percent iswas in GWIM. The remaining portion iswas in All Other and iswas comprised of originated loans, purchased loans used in our overall ALM activities, delinquent FHA loans
repurchased pursuant to our servicing agreements with GNMAthe Government National Mortgage Association as well as loans repurchased related to our representations and warranties.
Outstanding balances in the residential mortgage portfolio excluding loans accounted for under the fair value option, increased $12.0decreased $12.6 billion in 20172020 as retention of new originations wasboth loan sales and paydowns were partially offset by loan sales of $3.9 billion, and run-off.originations.
At December 31, 20172020 and 2016,2019, the residential mortgage portfolio included $23.7$11.8 billion and $28.7$18.7 billion of outstanding fully-insured loans. On this portionloans, of the residential mortgage portfolio, we are protected against principal loss as a result of either FHA insurance or long-term standby agreements that provide for the transfer of credit risk to FNMA and FHLMC. At December 31, 2017 and 2016, $17.4which $2.8 billion and $22.3$11.2 billion had FHA insurance, with the remainder protected by Fannie Mae long-term standby agreements. At December 31, 2017 and 2016, $5.2 billion and $7.4 billionThe decline was primarily driven by sales of the FHA-insured loan population were repurchases of delinquentloans with FHA loans pursuant to our servicing agreements with GNMA.insurance during 2020.
Table 2422 presents certain residential mortgage key credit statistics on both a reported basis excluding loans accounted for under the fair value option, and excluding the PCI loan portfolio, the fully-insured loan portfolio and loans accounted for under the fair value option. Additionally, in the “Reported Basis” columns in the following table, accruing balances past due and nonperforming loans do not include the PCI loan portfolio, in accordance with our accounting policies, even though the customer may be contractually past due. As such, theportfolio. The following discussion presents the residential mortgage portfolio excluding the PCI loan portfolio, the fully-insured loan portfolio.
Bank of America 64


Table 22Residential Mortgage – Key Credit Statistics
Reported Basis (1)
Excluding Fully-insured Loans (1)
December 31
(Dollars in millions)2020201920202019
Outstandings$223,555 $236,169 $211,737 $217,479 
Accruing past due 30 days or more2,314 3,108 1,224 1,296 
Accruing past due 90 days or more762 1,088  — 
Nonperforming loans (2)
2,005 1,470 2,005 1,470 
Percent of portfolio    
Refreshed LTV greater than 90 but less than or equal to 1002 %%1 %%
Refreshed LTV greater than 1001 1 
Refreshed FICO below 6202 1 
2006 and 2007 vintages (3)
3 3 
(1)Outstandings, accruing past due, nonperforming loans and percentages of portfolio andexclude loans accounted for under the fair value option. For more information on our interest accrual policies and delinquency status for loan modifications related to the PCI loan portfolio,pandemic, see page 60.
Note 1 – Summary of Significant Accounting Principles to the Consolidated Financial Statements.

(2)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.
Bank of America 201756


          
Table 24Residential Mortgage – Key Credit Statistics        
          
   
Reported Basis (1)
 Excluding Purchased
Credit-impaired and
Fully-insured Loans
   December 31
(Dollars in millions) 2017 2016 2017 2016
Outstandings $203,811
 $191,797
 $172,069
 $152,941
Accruing past due 30 days or more 5,987
 8,232
 1,521
 1,835
Accruing past due 90 days or more 3,230
 4,793
 
  —
Nonperforming loans 2,476
 3,056
 2,476
 3,056
Percent of portfolio  
  
  
  
Refreshed LTV greater than 90 but less than or equal to 100 3 % 5% 2 % 3%
Refreshed LTV greater than 100 2
 4
 1
 3
Refreshed FICO below 620 6
 9
 3
 4
2006 and 2007 vintages (2)
 10
 13
 8
 12
          
   2017 2016 2017 2016
Net charge-off ratio (3)
 (0.05)% 0.07% (0.06)% 0.09%
(1)
Outstandings, accruing past due, nonperforming loans and percentages of portfolio exclude loans accounted for under the fair value option.
(2)
These vintages of loans accounted for $825 million, or 33(3)These vintages of loans accounted for $503 million and $365 million, or 25 percent,, and $931 million, or 31 percent, of nonperforming residential mortgage loans at December 31, 2017 and 2016.
(3)
Net charge-off ratios are calculated as net charge-offs divided by average outstanding loans excluding loans accounted for under the fair value option.
Nonperforming residential mortgage loans decreased $580at both December 31, 2020 and 2019.
Nonperforming outstanding balances in the residential mortgage portfolio increased $535 million in 20172020 primarily driven by COVID-19 deferral activity, as outflows, including saleswell as the inclusion of $460 million and net transfers to held-for-salecertain loans that, upon adoption of $132 million, outpacedthe new inflowscredit loss standard, became accounted for on an individual basis, which included the addition of $140 million of nonperforming loans aspreviously had been accounted for under a result of clarifying regulatory guidance related to bankruptcy loans.pool basis. Of the nonperforming residential mortgage loans at December 31, 2017, $8602020, $892 million, or 3545 percent, were current on contractual payments. Loans accruing past due 30 days or more decreased $314 million due in part to the timing impact of a consumer real estate servicer conversion that occurred during the fourth quarter of 2016.$72 million.
Net charge-offs decreased $231increased $17 million to $100a net recovery of $30 million of net recoveries in 20172020 compared to $131 milliona net recovery of net charge-offs in 2016. This decrease in net charge-offs was primarily driven by net recoveries of $105 million related to loan sales in 2017, compared to loan sale-related net charge-offs of $26$47 million in 2016. Additionally, net charge-offs declined2019. This increase is due largely to favorable portfolio trends and decreased write-downs on loans greater than 180 days past due driven by improvement in home prices andlower recoveries from the U.S. economy.
Loans with a refreshed LTV greater than 100 percent represented one percent and three percentsales of the residential mortgage loan portfolio at December 31, 2017 and 2016. Of the loans with a refreshed LTV greater than 100 percent, 98 percent were performing at both December 31, 2017 and 2016. Loans with a refreshed LTV greater than 100 percent reflect loans where the outstanding carrying value of the loan is greater than the most recent valuation of the property securing the loan. The majority of these loans have a refreshed LTV greater than 100 percent primarily due to home price deterioration since 2006, partially offset by subsequent appreciation.previously charged-off loans.
Of the $172.1$211.7 billion in total residential mortgage loans outstanding at December 31, 2017,2020, as shown in Table 25, 33
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 $10.4$5.9 billion, or 1810 percent, at December 31, 2017.2020. 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, 2017, $2832020, $113 million, or threetwo percent of outstanding interest-only residential mortgages that had entered
the amortization period were accruing past due 30 days or more compared to $1.5$1.2 billion, or less than one percent, for the entire residential mortgage portfolio. In addition, at December 31, 2017, $5092020, $356 million, or fivesix percent, of outstanding interest-only residential mortgage loans that had entered the amortization period were nonperforming, of which $253$96 million were contractually current, compared to $2.5$2.0 billion, or one percent, for the entire residential mortgage portfolio, of which $860 million were contractually current.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. More than 80Approximately 98 percent of these loans that have yet to enter the amortization period will not be required to make a fully-amortizing payment until 20202022 or later.
Table 2523 presents outstandings, nonperforming loans and net charge-offs by certain state concentrations for the residential mortgage portfolio. The Los Angeles-Long Beach-Santa Ana Metropolitan Statistical Area (MSA) within California represented 16 percent and 15 percent of outstandings at both December 31, 20172020 and 2016.2019. In the New York area, the New York-Northern New Jersey-Long Island MSA made up 1314 percent and 1213 percent of outstandings at December 31, 20172020 and 2016.2019.

Table 23Residential Mortgage State Concentrations
Outstandings (1)
Nonperforming (1)
December 31Net Charge-offs
(Dollars in millions)202020192020201920202019
California$83,185 $88,998 $570 $274 $(18)$(22)
New York23,832 22,385 272 196 3 
Florida13,017 12,833 175 143 (5)(12)
Texas8,868 8,943 78 65  
New Jersey8,806 8,734 98 77 (1)(4)
Other74,029 75,586 812 715 (9)(15)
Residential mortgage loans$211,737 $217,479 $2,005 $1,470 $(30)$(47)
Fully-insured loan portfolio11,818 18,690   
Total residential mortgage loan portfolio$223,555 $236,169   
(1)Outstandings and nonperforming loans exclude loans accounted for under the fair value option.
57Bank of America 2017



             
Table 25Residential Mortgage State Concentrations   
             
  
Outstandings (1)
 
Nonperforming (1)
 
Net Charge-offs (2)
 December 31 
(Dollars in millions)2017 2016 2017 2016 2017 2016
California$68,455
 $58,295
 $433
 $554
 $(103) $(70)
New York (3)
17,239
 14,476
 227
 290
 (2) 18
Florida (3)
10,880
 10,213
 280
 322
 (13) 20
Texas7,237
 6,607
 126
 132
 1
 9
New Jersey (3)
6,099
 5,307
 130
 174
 
 25
Other U.S./Non-U.S.62,159
 58,043
 1,280
 1,584
 17
 129
Residential mortgage loans (4)
$172,069
 $152,941
 $2,476
 $3,056
 $(100) $131
Fully-insured loan portfolio23,741
 28,729
  
  
    
Purchased credit-impaired residential mortgage loan portfolio (5)
8,001
 10,127
  
  
    
Total residential mortgage loan portfolio$203,811
 $191,797
  
  
    
(1)
Outstandings and nonperforming loans exclude loans accounted for under the fair value option.
(2)
Net charge-offs excluded $131 million and $144 million of write-offs in the residential mortgage PCI loan portfolio in 2017 and 2016. For more information on PCI write-offs, see Consumer Portfolio Credit Risk Management – Purchased Credit-impaired Loan Portfolio on page 60.
(3)
In these states, foreclosure requires a court order following a legal proceeding (judicial states).
(4)
Amounts exclude the PCI residential mortgage and fully-insured loan portfolios.
(5)
At December 31, 2017 and 2016, 47 percent and 48 percent of PCI residential mortgage loans were in California. There were no other significant single state concentrations.
Home Equity
At December 31, 2017,2020, the home equity portfolio made up 13eight percent of the consumer portfolio and iswas comprised of home equity lines of credit (HELOCs), home equity loans and reverse mortgages.
At December 31, 2017, our HELOC portfolio had an outstanding balance of $51.2 billion, or 89 percent of the total home equity portfolio compared to $58.6 billion, or 88 percent, at December 31, 2016. HELOCs generally have an initial draw period of 10 years, and after the initial draw period ends, the loans generally
convert to 15-year15- or 20-year amortizing loans.
At December 31, 2017, our home equity loan portfolio had an outstanding balance of $4.4 billion, or seven percent of the total home equity portfolio compared to $5.9 billion, or nine percent, at December 31, 2016. Home equity loans are almost all fixed-rate loans with amortizing payment terms of 10 to 30 years and of the $4.4 billion at December 31, 2017, 57 percent have 25- to 30-year terms. At December 31, 2017, our reverse mortgage portfolio had an outstanding balance, excluding loans accounted for under the fair value option, of $2.1 billion, or four percent of the total home equity portfolio compared to $1.9 billion, or three percent, at December 31, 2016. We no longer originate home equity loans or reverse mortgages.
At December 31, 2017, approximately 692020, 80 percent of the home equity portfolio was in Consumer Banking, 2312 percent was in All Other and the remainder of the portfolio was primarily in GWIM. Outstanding balances in the home equity portfolio excluding loans accounted for under the fair value option, decreased $8.7
65 Bank of America


$5.9 billion in 20172020 primarily due to paydowns and charge-offs outpacing new
originations and draws on existing lines. Of the total home equity portfolio at December 31, 20172020 and 2016, $18.7 billion and $19.62019, $13.8 billion, or 3240 percent, and 29$15.0 billion, or 37 percent, were in first-lien positions (34 percent and 31 percent excluding the PCI home equity portfolio).positions. At December 31, 2017,2020, 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 $9.4
$5.9 billion, or 17 percent, of our total home equity portfolio excluding the PCI loan portfolio.
Unused HELOCs totaled $44.2$42.3 billion and $47.2$43.6 billion at December 31, 20172020 and 2016. The decrease was primarily due to accounts reaching the end of their draw period, which automatically eliminates open line exposure, and customers choosing to close accounts. Both of these more than offset the impact of new production.2019. The HELOC utilization rate was 5443 percent and 5546 percent at December 31, 20172020 and 2016.2019.
Table 2624 presents certain home equity portfolio key credit statistics on both a reported basis excluding loans accounted for under the fair value option, and excluding the PCI loan portfolio and loans accounted for under the fair value option. Additionally, in the “Reported Basis” columns in the following table,statistics.
Table 24
Home Equity – Key Credit Statistics (1)
December 31
(Dollars in millions)20202019
Outstandings$34,311 $40,208 
Accruing past due 30 days or more (2)
186 218 
Nonperforming loans (2, 3)
649 536 
Percent of portfolio
Refreshed CLTV greater than 90 but less than or equal to 1001 %%
Refreshed CLTV greater than 1001 
Refreshed FICO below 6203 
2006 and 2007 vintages (4)
16 18 
(1)Outstandings, accruing balances past due, 30 days or more and nonperforming loans do not includeand percentages of the PCI loan portfolio in accordance with our accounting policies, even though the customer may be contractually past due. As such, the following discussion presents the home equity portfolio excluding the PCI loan portfolio andexclude loans accounted for under the fair value option. For more information on our interest accrual policies and delinquency status for loan modifications related to the PCI loan portfolio,pandemic, see page 60.
Note 1 – Summary of Significant Accounting Principles to the Consolidated Financial Statements.

Bank of America 201758


          
Table 26Home Equity – Key Credit Statistics
          
   
Reported Basis (1)
 Excluding Purchased
Credit-impaired Loans
   December 31
(Dollars in millions) 2017 2016 2017 2016
Outstandings $57,744
 $66,443
 $55,028
 $62,832
Accruing past due 30 days or more (2)
 502
 566
 502
 566
Nonperforming loans (2)
 2,644
 2,918
 2,644
 2,918
Percent of portfolio        
Refreshed CLTV greater than 90 but less than or equal to 100 3% 5% 3% 4%
Refreshed CLTV greater than 100 5
 8
 4
 7
Refreshed FICO below 620 6
 7
 6
 6
2006 and 2007 vintages (3)
 29
 37
 27
 34
         
  2017 2016 2017 2016
Net charge-off ratio (4)
 0.34% 0.57% 0.36% 0.60%
(1)
Outstandings, accruing past due, nonperforming loans and percentages of the portfolio exclude loans accounted for under the fair value option.
(2)
Accruing past due 30 days or more included $67 million and $81 million and nonperforming loans included $344 million and $340 million of loans where we serviced the underlying first-lien at December 31, 2017 and 2016.
(3)
These vintages of loans have higher refreshed combined loan-to-value (CLTV) ratios and accounted for 52 percent and 50 percent of nonperforming home equity loans at December 31, 2017 and 2016, and 91 percent and 54 percent of net charge-offs in 2017 and 2016.
(4)
Net charge-off ratios are calculated as net charge-offs divided by average outstanding loans excluding loans accounted for under the fair value option.
Nonperforming outstanding balances in the home equity portfolio decreased $274(2)Accruing past due 30 days or more include $25 million in 2017 as outflows, including $66and $30 million and nonperforming loans include $88 million and $57 million of net transfers to held-for-sale and $51 million of sales, outpaced new inflows, which includedloans where we serviced the addition of $135 million of nonperforming loans as a result of clarifying regulatory guidance related to bankruptcy loans. Of the nonperforming home equity portfoliounderlying first lien at December 31, 2017, $1.4 billion, or 54 percent, were current on contractual payments. Nonperforming2020 and 2019.
(3)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-lienfirst 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, $693$237 million, or 2636 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 $64$32 million in 2017.2020.
In some cases, the junior-lien home equity outstanding balance that we hold is performing, but the underlying first-lien is not. For outstanding balances in the home equity portfolio on which we service the first-lien loan, we are able to track whether the first-lien loan is in default. For loans where the first-lien is serviced by a third party, we utilize credit bureau data to estimate the delinquency status of the first-lien. Given that the credit bureau database we use does not include a property address for the mortgages, we are unable to identify with certainty whether a reported delinquent first-lien mortgage pertains to the same property for which we hold a junior-lien loan. For certain loans, we
utilize a third-party vendor to combine credit bureau and public record data to better link a junior-lien loan with the underlying first-lien mortgage. At December 31, 2017, we estimate that $814 million of current and $141 million of 30 to 89 days past due junior-lien loans were behind a delinquent first-lien loan. We service the first-lien loans on $184 million of these combined amounts, with the remaining $771 million serviced by third parties. Of the $955 million of current to 89 days past due junior-lien loans, based on available credit bureau data and our own internal servicing data, we estimate that approximately $330 million had first-lien loans that were 90 days or more past due.
Net charge-offs decreased $192increased $285 million to $213a net recovery of $73 million in 20172020 compared to $405a net recovery of $358 million in 2016 driven by favorable portfolio trends due in part to improvement in home prices and2019 as the U.S. economy, partially offset by $32 million of charge-offs as a result of clarifying regulatory guidance related to bankruptcy loans.
Outstanding balances with a refreshed CLTV greater than 100 percent comprised four percent and seven percent of the home equity portfolio at December 31, 2017 and 2016. Outstanding balances with a refreshed CLTV greater than 100 percent reflect loans where our loan and available line of credit combined with any outstanding senior liens against the property are equal to or greater than the most recent valuation of the property securing the loan. Depending on the value of the property, there may be collateral in excess of the first-lien that is available to reduce the severity of loss on the second-lien. Of those outstanding balances with a refreshed CLTV greater than 100 percent, 95 percent of the customers were current on theirprior-year period included recoveries from non-core home equity loan and 91 percent of second-lien loans with a refreshed CLTV greater than 100 percent were current on both their second-lien and underlying first-lien loans at December 31, 2017.sales.
Of the $55.0$34.3 billion in total home equity portfolio outstandings at December 31, 2017,2020, as shown in Table 27, 3024, 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 $18.4$9.2 billion at December 31, 2017.2020. 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, 2017, $3432020, $121 million, or twoone percent of outstanding HELOCs that had entered the amortization period were accruing past due 30
days or more. In addition, at December 31, 2017, $2.1 billion,2020, $477 million, or 11five percent, of outstanding HELOCswere 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 were nonperforming, of which $1.1 billion were contractually current. Loans in our HELOC portfolio generally have an initial draw period of 10 years and 10 percent of these loans will enter the amortization period during 2018 and will be required to make fully-amortizing payments.period. We communicate to contractually current customers more than a year


59Bank of America 2017



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 (i.e., customers may draw on and repay their line of credit, but are generally only required to pay interest on a monthly basis).period. During 2017, approximately 192020, nine percent of these customers with an outstanding balance did not pay any principal on their HELOCs.
Table 2725 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, 20172020 and 2016. Loans within this MSA contributed 27 percent and 17 percent of net charge-offs in 2017 and 2016 within the home equity portfolio.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, 20172020 and 2016. Loans within this MSA contributed net recoveries of $20 million and $2 million within the home equity portfolio in 2017 and 2016.2019.
Table 25Home Equity State Concentrations
Outstandings (1)
Nonperforming (1)
December 31Net Charge-offs
(Dollars in millions)202020192020201920202019
California$9,488 $11,232 $143 $101 $(26)$(117)
Florida3,715 4,327 80 71 (11)(74)
New Jersey2,749 3,216 67 56 (3)(8)
New York2,495 2,899 103 85 (1)(1)
Massachusetts1,719 2,023 32 29 (1)(5)
Other14,145 16,511 224 194 (31)(153)
Total home equity loan portfolio$34,311 $40,208 $649 $536 $(73)$(358)
             
Table 27Home Equity State Concentrations   
             
  
Outstandings (1)
 
Nonperforming (1)
 
Net Charge-offs (2)
  December 31 
(Dollars in millions)2017 2016 2017 2016 2017 2016
California$15,145
 $17,563
 $766
 $829
 $(37) $7
Florida (3)
6,308
 7,319
 411
 442
 38
 76
New Jersey (3)
4,546
 5,102
 191
 201
 44
 50
New York (3)
4,195
 4,720
 252
 271
 35
 45
Massachusetts2,751
 3,078
 92
 100
 9
 12
Other U.S./Non-U.S.22,083
 25,050
 932
 1,075
 124
 215
Home equity loans (4)
$55,028
 $62,832
 $2,644
 $2,918
 $213
 $405
Purchased credit-impaired home equity portfolio (5)
2,716
 3,611
  
  
    
Total home equity loan portfolio$57,744
 $66,443
  
  
    
(1)
(1)Outstandings and nonperforming loans exclude loans accounted for under the fair value option.
(2)
Net charge-offs excluded $76 million and $196 million of write-offs in the home equity PCI loan portfolio in 2017 and 2016. For more information on PCI write-offs, see Consumer Portfolio Credit Risk Management – Purchased Credit-impaired Loan Portfolio.
(3)
In these states, foreclosure requires a court order following a legal proceeding (judicial states).
(4)
Amount excludes the PCI home equity portfolio.
(5)
At December 31, 2017 and 2016, 28 percent and 29 percent of PCI home equity loans were in California. There were no other significant single state concentrations.
Purchased Credit-impaired Loan Portfolio
Loans acquired with evidence of credit quality deterioration since origination and for which it is probable at purchase that we will be unable to collect all contractually required payments are accounted for under the accounting standards for PCI loans. For more information, see Note 1 – Summary of Significant Accountingfair value option.

Principles and Note 4 – Outstanding Loans and Leases to the Consolidated Financial Statements.
Table 28 presents the unpaid principal balance, carrying value, related valuation allowance and the net carrying value as a percentage of the unpaid principal balance for the PCI loan portfolio.
           
Table 28Purchased Credit-impaired Loan Portfolio
           
 Unpaid
Principal
Balance
 Gross Carrying
Value
 Related
Valuation
Allowance
 Carrying Value Net of Valuation Allowance Percent of Unpaid Principal Balance
(Dollars in millions)December 31, 2017
Residential mortgage (1)
$8,117
 $8,001
 $117
 $7,884
 97.13%
Home equity2,787
 2,716
 172
 2,544
 91.28
Total purchased credit-impaired loan portfolio$10,904
 $10,717
 $289
 $10,428
 95.63
           
  December 31, 2016
Residential mortgage (1)
$10,330
 $10,127
 $169
 $9,958
 96.40%
Home equity3,689
 3,611
 250
 3,361
 91.11
Total purchased credit-impaired loan portfolio$14,019
 $13,738
 $419
 $13,319
 95.01
(1)
At December 31, 2017 and 2016, pay option loans had an unpaid principal balance of $1.4 billion and $1.9 billion and a carrying value of $1.4 billion and $1.8 billion. This includes $1.2 billion and $1.6 billion of loans that were credit-impaired upon acquisition and $141 million and $226 million of loans that were 90 days or more past due at December 31, 2017 and 2016. The total unpaid principal balance of pay option loans with accumulated negative amortization was $160 million and $303 million, including $9 million and $16 million of negative amortization at December 31, 2017 and 2016.

Bank of America 20176066



The total PCI unpaid principal balance decreased $3.1 billion, or 22 percent, in 2017 primarily driven by payoffs, paydowns, write-offs and PCI loan sales with a carrying value of $803 million compared to $549 million in 2016.
Of the unpaid principal balance of $10.9 billion at December 31, 2017, $9.6 billion, or 88 percent, was current based on the contractual terms, $752 million, or seven percent, was in early stage delinquency, and $364 million was 180 days or more past due, including $302 million of first-lien mortgages and $62 million of home equity loans.
The PCI residential mortgage loan and home equity portfolios represented 75 percent and 25 percent of the total PCI loan portfolio at December 31, 2017. Those loans to borrowers with a refreshed FICO score below 620 represented 24 percent and 17 percent of the PCI residential mortgage loan and home equity portfolios at December 31, 2017. Residential mortgage and home equity loans with a refreshed LTV or CLTV greater than 90 percent, after consideration of purchase accounting adjustments and the related valuation allowance, represented 14 percent and 34 percent of their respective PCI loan portfolios and 16 percent and
37 percent based on the unpaid principal balance at December 31, 2017.
U.S. Credit Card
At December 31, 2017,2020, 97 percent of the U.S. credit card portfolio was managed in Consumer Banking with the remainder in GWIM.
Outstandings in the U.S. credit card portfolio increased $4.0 billion to $96.3decreased $18.9 billion in 2017 as2020 to $78.7 billion due to lower retail volumes outpacedspending and higher payments. Net charge-offs increased $244decreased $599 million to $2.5$2.3 billion during 2020 compared to net charge-offs of $2.9 billion in 20172019 due to portfolio seasoninggovernment stimulus benefits and loan growth. U.S. creditpayment deferrals associated with COVID-19. Credit card loans 30 days
or more past due and still accruing interest increased $252decreased $346 million, and loans 90 days or more past due and still accruing interest increased $118decreased $139 million primarily due to government stimulus benefits and declines in 2017, driven by portfolio seasoning and loan growth.balances.
Unused lines of credit for U.S. credit card totaled $326.3 billion and $321.6increased to $342.4 billion at December 31, 2017 and 2016. The increase was driven by account growth and lines of credit increases.2020 from $336.9 billion in 2019.
Table 2926 presents certain state concentrations for the U.S. credit card portfolio.
Table 26Credit Card State Concentrations
Outstandings
Accruing Past Due
90 Days or More (1)
December 31Net Charge-offs
(Dollars in millions)202020192020201920202019
California$12,543 $16,135 $166 $178 $419 $526 
Florida7,666 9,075 135 135 306 363 
Texas6,499 7,815 87 93 202 241 
New York4,654 5,975 76 80 188 243 
Washington3,685 4,639 21 26 56 71 
Other43,661 53,969 418 530 1,178 1,504 
Total credit card portfolio$78,708 $97,608 $903 $1,042 $2,349 $2,948 
             
Table 29U.S. Credit Card State Concentrations   
             
  Outstandings Accruing Past Due
90 Days or More
 Net Charge-offs
  December 31 
(Dollars in millions)2017 2016 2017 2016 2017 2016
California$15,254
 $14,251
 $136
 $115
 $412
 $360
Florida8,359
 7,864
 94
 85
 259
 245
Texas7,451
 7,037
 76
 65
 194
 164
New York5,977
 5,683
 91
 60
 218
 161
Washington4,350
 4,128
 20
 18
 56
 56
Other U.S.54,894
 53,315
 483
 439
 1,374
 1,283
Total U.S. credit card portfolio$96,285
 $92,278
 $900
 $782
 $2,513
 $2,269
(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 and Other Consumer
At December 31, 2017, approximately 542020, 51 percent of the direct/indirect portfolio was included in Consumer Banking (consumer auto and specialty lending – automotive, marine, aircraft, recreational vehicle loanslending) and consumer personal loans) and 4649 percent was included in GWIM (principally securities-based lending loans). At December 31, 2017, approximately 94 percent of the $2.7 billion other consumer portfolio was consumer auto leases included in Consumer Banking.Outstandings
Outstandings in the direct/indirect portfolio remained relatively unchanged at $93.8 billion at December 31, 2017. Net charge-offs increased $77 million to $211$365 million in 20172020 to $91.4 billion primarily due largely to portfolio seasoning and clarifying regulatory guidance related to bankruptcy and repossession.increases in securities-based lending offset by lower originations in Auto.
Table 3027 presents certain state concentrations for the direct/indirect consumer loan portfolio.
Table 27Direct/Indirect State Concentrations
Outstandings
Accruing Past Due
90 Days or More
(1)
December 31Net Charge-offs
(Dollars in millions)202020192020201920202019
California$12,248 $11,912 $6 $$20 $49 
Florida10,891 10,154 4 20 27 
Texas8,981 9,516 6 20 29 
New York6,609 6,394 2 9 12 
New Jersey3,572 3,468  2 
Other49,062 49,554 15 18 51 88 
Total direct/indirect loan portfolio$91,363 $90,998 $33 $33 $122 $209 
             
Table 30Direct/Indirect State Concentrations   
             
  Outstandings Accruing Past Due
90 Days or More
 Net Charge-offs
  December 31 
(Dollars in millions)2017 2016 2017 2016 2017 2016
California$11,165
 $11,300
 $3
 $3
 $21
 $13
Florida10,946
 9,418
 5
 3
 42
 29
Texas10,623
 9,406
 5
 5
 38
 21
New York6,058
 5,253
 2
 1
 6
 3
Georgia3,502
 3,255
 4
 4
 15
 9
Other U.S./Non-U.S.51,536
 55,457
 21
 18
 89
 59
Total direct/indirect loan portfolio$93,830
 $94,089
 $40
 $34
 $211
 $134
(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.

61Bank of America 2017



Nonperforming Consumer Loans, Leases and Foreclosed Properties Activity
Table 3128 presents nonperforming consumer loans, leases and foreclosed properties activity during 20172020 and 2016. For more information on nonperforming loans, see Note 1 – Summary of Significant Accounting Principles and Note 4 – Outstanding Loans and Leases to the Consolidated Financial Statements.2019. During 2017,2020, nonperforming consumer loans declined $838increased $672 million to $5.2$2.7 billion primarily driven in part by loan salesCOVID-19 deferral activity, as well as the inclusion of $511 million and net transfers of loans to held-for-sale of $198 million. Additionally, nonperforming loans declined as outflows outpaced new inflows, which included the addition of $295$144 million of nonperformingcertain loans that were previously classified as purchased credit-impaired loans and accounted for under a result of clarifying regulatory guidance related to bankruptcy loans.pool basis.
At December 31, 2017, $1.9 billion,2020, $892 million, or 3433 percent of nonperforming consumer real estate loans were 180 days or more past due and foreclosed properties had been written down to their estimated property value less costs to sell, including $1.6 billion of nonperforming loans 180 days or more past due and $236 million of foreclosed properties.sell. In addition, at December 31, 2017, $2.32020, $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 $127$106 million in 20172020 to $123 million as liquidations outpaced additions. PCI loans are excluded from nonperforming loans as these loans were written down to fair value at the acquisition date; however, once we acquire the underlying real estate uponCorporation has paused formal loan foreclosure of the delinquent PCI loan, it is included in foreclosed properties. Not included in foreclosedproceedings and foreclosure sales for occupied properties at December 31, 2017 was $801 million of real estate that was acquired upon foreclosure of certain delinquent government-guaranteed loans (principally FHA-insured loans). We exclude these amounts from our nonperforming loans and foreclosed properties activity as we expect we will be reimbursed once the property is conveyed to the guarantor for principal and, up to certain limits, costs incurred during the foreclosure process and interest accrued during the holding period.2020.
We classify junior-lien home equity loans as nonperforming when the first-lien loan becomes 90 days past due even if the junior-lien loan is performing. At December 31, 2017 and 2016, $330 million and $428 million of such junior-lien home equity loans were included in nonperforming loans and leases.
Nonperforming loans also include certain loans that have been modified in TDRs where economic concessions have been granted to borrowers experiencing financial difficulties. Nonperforming TDRs excluding those modified loans in the PCI loan portfolio, are included in Table 31.28. 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 25 and Note 1 – Summary of Significant Accounting Principles to the Consolidated Financial Statements.
     
Table 31
Nonperforming Consumer Loans, Leases and Foreclosed Properties Activity (1)
   
     
(Dollars in millions)2017 2016
Nonperforming loans and leases, January 1$6,004
 $8,165
Additions3,254
 3,492
Reductions:   
Paydowns and payoffs(1,052) (1,044)
Sales(511) (1,604)
Returns to performing status (2)
(1,438) (1,628)
Charge-offs(676) (1,028)
Transfers to foreclosed properties(217) (294)
Transfers to loans held-for-sale(198) (55)
Total net reductions to nonperforming loans and leases(838) (2,161)
Total nonperforming loans and leases, December 31 (3)
5,166
 6,004
Total foreclosed properties, December 31 (4)
236
 363
Nonperforming consumer loans, leases and foreclosed properties, December 31$5,402
 $6,367
Nonperforming consumer loans and leases as a percentage of outstanding consumer loans and leases (5)
1.14% 1.32%
Nonperforming consumer loans, leases and foreclosed properties as a percentage of outstanding consumer loans, leases and foreclosed properties (5)
1.19
 1.39
(1)
Balances do not include nonperforming LHFS of $2 million and $69 million and nonaccruing TDRs removed from the PCI loan portfolio prior to January 1, 2010 of $26 million and $27 million at December 31, 2017 and 2016 as well as loans accruing past due 90 days or more as presented in Table 21 and Note 4 – Outstanding Loans and Leases to the Consolidated Financial Statements.
(2)
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.
(3)
At December 31, 2017, 31 percent of nonperforming loans were 180 days or more past due.
(4)
Foreclosed property balances do not include properties insured by certain government-guaranteed loans, principally FHA-insured, of $801 million and $1.2 billion at December 31, 2017 and 2016.
(5)
Outstanding consumer loans and leases exclude loans accounted for under the fair value option.

67Bank of America 201762



Table 28Nonperforming Consumer Loans, Leases and Foreclosed Properties Activity
(Dollars in millions)20202019
Nonperforming loans and leases, January 1$2,053 $3,842 
Additions2,278 1,407 
Reductions:
Paydowns and payoffs(440)(701)
Sales(38)(1,523)
Returns to performing status (1)
(1,014)(766)
Charge-offs(78)(111)
Transfers to foreclosed properties(36)(95)
Total net additions/(reductions) to nonperforming loans and leases672 (1,789)
Total nonperforming loans and leases, December 312,725 2,053 
Foreclosed properties, December 31 (2)
123 229 
Nonperforming consumer loans, leases and foreclosed properties, December 31$2,848 $2,282 
Nonperforming consumer loans and leases as a percentage of outstanding consumer loans and leases (3)
0.64 %0.44 %
Nonperforming consumer loans, leases and foreclosed properties as a percentage of outstanding consumer loans, leases and foreclosed properties (3)
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 3229 presents TDRs for the consumer real estate portfolio. Performing TDR balances are excluded from nonperforming loans and leases in Table 31.28. 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 25 and Note 1 – Summary of Significant Accounting Principles to the Consolidated Financial Statements.
Table 29Consumer Real Estate Troubled Debt Restructurings
December 31, 2020December 31, 2019
(Dollars in millions)NonperformingPerformingTotalNonperformingPerformingTotal
Residential mortgage (1, 2)
$1,195 $2,899 $4,094 $921 $3,832 $4,753 
Home equity (3)
248 836 1,084 252 977 1,229 
Total consumer real estate troubled debt restructurings$1,443 $3,735 $5,178 $1,173 $4,809 $5,982 
             
Table 32Consumer Real Estate Troubled Debt Restructurings
             
  December 31, 2017 December 31, 2016
(Dollars in millions)Nonperforming Performing Total Nonperforming Performing Total
Residential mortgage (1, 2)
$1,535
 $8,163
 $9,698
 $1,992
 $10,639
 $12,631
Home equity (3)
1,457
 1,399
 2,856
 1,566
 1,211
 2,777
Total consumer real estate troubled debt restructurings$2,992
 $9,562
 $12,554
 $3,558
 $11,850
 $15,408
(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.
(1)
(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.
At December 31, 2017 and 2016, residential mortgage TDRs deemed collateral dependent totaled $2.8 billion and $3.5 billion, and included $1.2 billion and $1.6 billion of loans classified as nonperforming and $1.6 billion and $1.9 billion of loans classified as performing.
(2)
Residential mortgage performing TDRs included $3.7 billion and $5.3 billion of loans that were fully-insured at December 31, 2017 and 2016.
(3)
Home equity TDRs deemed collateral dependent totaled $1.6 billion for both periods and included $1.2 billion and $1.3 billion of loans classified as nonperforming, and $388 million and $301 million of loans classified as performing at December 31, 2017 and 2016.
In addition to modifying consumer real estate loans, we work with customers who are experiencing financial difficulty by modifying credit card and other consumer loans. Credit card and other consumer loan modifications generally involve a reduction in the customer’s interest rate on the account and placing the customer on a fixed payment plan not exceeding 60 months, all of which are considered TDRs (the renegotiated TDR portfolio).months.
Modifications of credit card and other consumer loans are made through renegotiation programs utilizing direct customer contact, but may also utilize external renegotiation programs. The renegotiated TDR portfolio is excluded in large part from Table 31 as substantially all of the loans remain on accrual status until either charged off or paid in full. At December 31, 20172020 and 2016,2019, our renegotiatedcredit card and other consumer TDR portfolio was $490$701 million and $610$679 million, of which $426$614 million and $493$570 million were current or less than 30 days past due under the modified terms. The decline in the renegotiated TDR portfolio was primarily driven by paydowns and charge-offs as well as lower program enrollments. For more information on the renegotiated TDR portfolio, see Note 4 – Outstanding Loans and Leases to the Consolidated Financial Statements.
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 do not result in undesirable levels of risk.continue to be aligned with our risk appetite. We review, measure and manage concentrations of credit exposure by industry, product, geography, customer relationship and loan size. We also review, measure and manage commercial real estate loans by geographic location and property type. In addition, within our
Bank of America 68


non-U.S. portfolio, we evaluate exposures by region and by country. Tables 34, 37 40, 45 and 4640 summarize our concentrations. We also utilize syndications of exposure to third parties, loan sales, hedging and other risk mitigation techniques to manage the size and risk profile of the commercial credit portfolio. For more information on our industry concentrations, including our utilized exposure to the energy sector which was three percent of total commercial utilized exposure at both December 31, 2017 and 2016, see Commercial Portfolio Credit Risk Management – Industry Concentrations on page 6772 and Table 40.37.
We account for certain large corporate loans and loan commitments, including issued but unfunded letters of credit which are considered utilized for credit risk management purposes, that exceed our single-name credit risk concentration guidelines under the fair value option. Lending commitments, both funded and unfunded, are actively managed and monitored, and as appropriate, credit risk for these lending relationships may be mitigated through the use of credit derivatives, with our credit view and market perspectives determining the size and timing of the hedging activity. In addition, we purchase credit protection to cover the funded portion as well as the unfunded portion of certain other credit exposures. To lessen the cost of obtaining our desired credit protection levels, credit exposure may be added within an industry, borrower or counterparty group by selling protection. These credit derivatives do not meet the requirements for treatment as accounting hedges. They are carried at fair value with changes in fair value recorded in other income.
In addition, we are a member of various securities and derivative exchanges and clearinghouses, both in the U.S. and other countries. As a member, we may be required to pay a pro-rata share of the losses incurred by some of these organizations as a result of another member default and under other loss scenarios. For more information, see Note 12 – Commitments and Contingencies to the Consolidated Financial Statements.

63Bank of America 2017



Commercial Credit Portfolio
During 2017, credit2020, commercial asset quality amongweakened as a result of the economic impact from COVID-19. However, there were also positive signs during this period. The draws by large corporate borrowers was strong, other than
and commercial clients contributing to the $67.2 billion loan growth in the higher risk energy sub-sectors, wherefirst 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 saw improvementhad $22.7 billion of PPP loans outstanding with our small business clients at December 31, 2020, which are included in 2017. 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 continuedhas begun to stabilize in many sectors as certain economies have reopened. Certain sectors, including hospitality and retail, continue to be strong with conservative LTV ratios, stable market rentsnegatively impacted as a result of COVID-19. Moreover, many real estate markets, while improving, are still experiencing some disruptions in most sectorsdemand, supply chain challenges and vacancy rates remaining low.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 76.
Total commercial utilized credit exposure increased $25.9decreased $15.0 billion during 20172020 to $600.8$620.3 billion at December 31, 2017 primarily driven by increases inlower loans and leases. The utilization rate for loans and leases, SBLCs and financial guarantees, and
commercial letters of credit, in the aggregate, was 5957 percent at December 31, 2020 and 58 percent at December 31, 2017 and 2016.2019.
Table 3330 presents commercial credit exposure by type for utilized, unfunded and total binding committed credit exposure. Commercial utilized credit exposure includes SBLCs and financial guarantees and commercial letters of credit that have been issued and for which we are legally bound to advance funds under prescribed conditions during a specified time period, and excludes exposure related to trading account assets. Although funds have not yet been advanced, these exposure types are considered utilized for credit risk management purposes.
Table 30Commercial Credit Exposure by Type
 
Commercial Utilized (1)
Commercial Unfunded (2, 3, 4)
Total Commercial Committed
December 31
(Dollars in millions)202020192020201920202019
Loans and leases$499,065 $517,657 $404,740 $405,834 $903,805 $923,491 
Derivative assets (5)
47,179 40,485  — 47,179 40,485 
Standby letters of credit and financial guarantees34,616 36,062 538 468 35,154 36,530 
Debt securities and other investments22,618 25,546 4,827 5,101 27,445 30,647 
Loans held-for-sale8,378 7,047 9,556 15,135 17,934 22,182 
Operating leases6,424 6,660  — 6,424 6,660 
Commercial letters of credit855 1,049 280 451 1,135 1,500 
Other1,168 800  — 1,168 800 
Total$620,303 $635,306 $419,941 $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.

             
Table 33Commercial Credit Exposure by Type
             
  
Commercial Utilized (1)
 
Commercial Unfunded (2, 3, 4)
 Total Commercial Committed
  December 31
(Dollars in millions)2017 2016 2017 2016 2017 2016
Loans and leases (5)
$487,748
 $464,260
 $364,743
 $356,911
 $852,491
 $821,171
Derivative assets (6)
37,762
 42,512
 
 
 37,762
 42,512
Standby letters of credit and financial guarantees34,517
 33,135
 863
 660
 35,380
 33,795
Debt securities and other investments28,161
 26,244
 4,864
 5,474
 33,025
 31,718
Loans held-for-sale10,257
 6,510
 9,742
 13,019
 19,999
 19,529
Commercial letters of credit1,467
 1,464
 155
 112
 1,622
 1,576
Other888
 767
 
 13
 888
 780
Total $600,800
 $574,892
 $380,367
 $376,189
 $981,167
 $951,081
(1)69 Bank of America
Commercial utilized exposure includes loans of $4.8 billion and $6.0 billion and issued letters of credit with a notional amount of $232 million and $284 million accounted for under the fair value option at December 31, 2017 and 2016.
(2)


Commercial unfunded exposure includes commitments accounted for under the fair value option with a notional amount of $4.6 billion and $6.7 billion at December 31, 2017 and 2016.
(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 (e.g., syndicated or participated) to other financial institutions. The distributed amounts were $11.0 billion and $12.1 billion at December 31, 2017 and 2016.
(5)
Includes credit risk exposure associated with assets under operating lease arrangements of $6.3 billion and $5.7 billion at December 31, 2017 and 2016.
(6)
Derivative assets are carried at fair value, reflect the effects of legally enforceable master netting agreements and have been reduced by cash collateral of $34.6 billion and $43.3 billion at December 31, 2017 and 2016. Not reflected in utilized and committed exposure is additional non-cash derivative collateral held of $26.2 billion and $25.3 billion at December 31, 2017 and 2016, which consists primarily of other marketable securities.
Outstanding commercial loans and leases increased $22.9decreased $18.6 billion during 20172020 primarily driven by repayments due in part to $481.5reduced working capital needs and a favorable capital markets environment, partially offset by $22.7 billion of PPP loans outstanding at December 31, 2017 primarily due to growth in commercial and industrial loans. During 2017, nonperforming2020. Nonperforming commercial loans increased $728 million across industries, and leases decreased $440 million to $1.3 billion and commercial
reservable criticized balances decreased $2.8utilized exposure increased $27.2 billion to $13.6 billion both driven by
improvements in the energy sector. The allowance for loanspread across several industries, including travel and lease losses for the commercial portfolio decreased $248 million during 2017 to $5.0 billion at Decemberentertainment, as a result of weaker economic conditions arising from COVID-19. Table 31 2017. For more information, see Allowance for Credit Losses on page 72. Table 34 presents our commercial loans and leases portfolio and related credit quality information at December 31, 20172020 and 2016.2019.
Table 31Commercial Credit Quality
OutstandingsNonperforming
Accruing Past Due
90 Days or More (3)
December 31
(Dollars in millions)202020192020201920202019
Commercial and industrial:
U.S. commercial$288,728 $307,048 $1,243 $1,094 $228 $106 
Non-U.S. commercial90,460 104,966 418 43 10 
Total commercial and industrial379,188 412,014 1,661 1,137 238 114 
Commercial real estate60,364 62,689 404 280 6 19 
Commercial lease financing17,098 19,880 87 32 25 20 
456,650 494,583 2,152 1,449 269 153 
U.S. small business commercial (1)
36,469 15,333 75 50 115 97 
Commercial loans excluding loans accounted for under the fair value option493,119 509,916 2,227 1,499 384 250 
Loans accounted for under the fair value option (2)
5,946 7,741 
Total commercial loans and leases$499,065 $517,657 
             
Table 34Commercial Credit Quality
   
  Outstandings Nonperforming 
Accruing Past Due
90 Days or More
  December 31
(Dollars in millions)2017 2016 2017 2016 2017 2016
Commercial and industrial:           
U.S. commercial$284,836
 $270,372
 $814
 $1,256
 $144
 $106
Non-U.S. commercial97,792
 89,397
 299
 279
 3
 5
Total commercial and industrial382,628
 359,769
 1,113
 1,535
 147
 111
Commercial real estate (1)
58,298
 57,355
 112
 72
 4
 7
Commercial lease financing22,116
 22,375
 24
 36
 19
 19
 463,042
 439,499
 1,249
 1,643
 170
 137
U.S. small business commercial (2)
13,649
 12,993
 55
 60
 75
 71
Commercial loans excluding loans accounted for under the fair value option476,691
 452,492
 1,304
 1,703
 245
 208
Loans accounted for under the fair value option (3)
4,782
 6,034
 43
 84
 
 
Total commercial loans and leases$481,473
 $458,526
 $1,347
 $1,787
 $245
 $208
(1)
Includes U.S. commercial real estate of $54.8 billion and $54.3 billion and non-U.S. commercial real estate of $3.5 billion and $3.1 billion at December 31, 2017 and 2016.
(2)
Includes card-related products.
(3)
Commercial loans accounted for under the fair value option include U.S. commercial of $2.6 billion and $2.9 billion and non-U.S. commercial of $2.2 billion and $3.1 billion at December 31, 2017 and 2016. For more information on the fair value option, see Note 21 – Fair Value Option to the Consolidated Financial Statements.

(1)Includes card-related products.
(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.
Bank of America 201764


(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 3532 presents net charge-offs and related ratios for our commercial loans and leases for 20172020 and 2016. The increase in2019.
Table 32Commercial Net Charge-offs and Related Ratios
Net Charge-offs
Net Charge-off Ratios (1)
(Dollars in millions)2020201920202019
Commercial and industrial:
U.S. commercial$718 $256 0.23 %0.08 %
Non-U.S. commercial155 84 0.15 0.08 
Total commercial and industrial873 340 0.21 0.08 
Commercial real estate270 29 0.43 0.05 
Commercial lease financing59 21 0.32 0.10 
1,202 390 0.24 0.08 
U.S. small business commercial267 272 0.86 1.83 
Total commercial$1,469 $662 0.28 0.13 
(1)Net charge-off ratios are calculated as net charge-offs of $399 milliondivided by average outstanding loans and leases excluding loans accounted for 2017 was primarily driven by a single-name non-U.S. commercial charge-off of $292 million inunder the fourth quarter of 2017.fair value option.
         
Table 35Commercial Net Charge-offs and Related Ratios
       
  Net Charge-offs 
Net Charge-off Ratios (1)
(Dollars in millions)2017 2016 2017 2016
Commercial and industrial:       
U.S. commercial$232
 $184
 0.08% 0.07 %
Non-U.S. commercial440
 120
 0.48
 0.13
Total commercial and industrial672
 304
 0.18
 0.09
Commercial real estate9
 (31) 0.02
 (0.05)
Commercial lease financing5
 21
 0.02
 0.10
  686
 294
 0.15
 0.07
U.S. small business commercial215
 208
 1.60
 1.60
Total commercial$901
 $502
 0.20
 0.11
(1)
Net charge-off ratios are calculated as net charge-offs divided by average outstanding loans and leases excluding loans accounted for under the fair value option.
Table 3633 presents commercial utilized 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 utilized reservable criticized utilized exposure decreased $2.8increased $27.2 billion or 17 percent, during 2017 primarily driven by paydowns2020, which was spread across several industries, including travel and upgrades in the energy portfolio. Approximately 84entertainment, as a result of weaker economic conditions arising from COVID-19. At December 31, 2020 and 2019, 79 percent and 7690 percent of commercial utilized reservable criticized utilized exposure was securedsecured.
Table 33
Commercial Reservable Criticized Utilized Exposure (1, 2)
December 31
(Dollars in millions)20202019
Commercial and industrial:
U.S. commercial$21,388 6.83 %$8,272 2.46 %
Non-U.S. commercial5,051 5.03 989 0.89 
Total commercial and industrial26,439 6.40 9,261 2.07 
Commercial real estate10,213 16.42 1,129 1.75 
Commercial lease financing714 4.18 329 1.66 
37,366 7.59 10,719 2.01 
U.S. small business commercial1,300 3.56 733 4.78 
Total commercial reservable criticized utilized exposure (1)
$38,666 7.31 $11,452 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, 20172020 and 2016.2019.
(2)Percentages are calculated as commercial reservable criticized utilized exposure divided by total commercial reservable utilized exposure for each exposure category.
         
Table 36Commercial Utilized Reservable Criticized Exposure
         
  
Amount (1)
 
Percent (2)
 
Amount (1)
 
Percent (2)
  December 31
(Dollars in millions)2017 2016
Commercial and industrial:
U.S. commercial$9,891
 3.15% $10,311
 3.46%
Non-U.S. commercial1,766
 1.70
 3,974
 4.17
Total commercial and industrial11,657
 2.79
 14,285
 3.63
Commercial real estate566
 0.95
 399
 0.68
Commercial lease financing581
 2.63
 810
 3.62
  12,804
 2.57
 15,494
 3.27
U.S. small business commercial759
 5.56
 826
 6.36
Total commercial utilized reservable criticized exposure$13,563
 2.65
 $16,320
 3.35
(1)
Total commercial utilized reservable criticized exposure includes loans and leasesBank of $12.5 billion and $14.9 billion and commercial letters of credit of $1.1 billion and $1.4 billion at December 31, 2017 and 2016.America 70
(2)


Percentages are calculated as commercial utilized reservable criticized exposure divided by total commercial utilized reservable exposure for each exposure category.
Commercial and Industrial
Commercial and industrial loans include U.S. commercial and non-U.S. commercial portfolios.
U.S. Commercial
At December 31, 2017, 702020, 65 percent of the U.S. commercial loan portfolio, excluding small business, was managed in Global Banking,17 18 percent in Global Markets, 1115 percent in GWIM (generally business-purpose loans for high net worth clients) and the remainder primarily in Consumer Banking. U.S. commercial loans excluding loans accounted for under the fair value option, increased $14.5decreased $18.3 billion or five percent, during 2017 to $284.8 billion at December 31, 2017 due to growth across most of the commercial businesses.2020 driven by Global Banking. Reservable criticized balances decreased $420 million, or four percent,utilized exposure increased $13.1 billion, which was spread across several industries, including travel and nonperforming loans
and leases decreased $442 million, or 35 percent, in 2017 driven by improvements in the energy sector. Net charge-offs increased $48 million for 2017 compared to 2016.entertainment, as a result of weaker economic conditions arising from COVID-19.
Non-U.S. Commercial
At December 31, 2017,2020, 79 percent of the non-U.S. commercial loan portfolio was managed in Global Banking and 21 percent in Global Markets. OutstandingNon-U.S. commercial loans excluding loans accounted for under the fair value option, increased $8.4decreased $14.5 billion during 2020, primarily in 2017. Reservable criticized balances decreased $2.2 billion, or 56 percent, due primarily to paydowns and upgrades in the energy portfolio. Net charge-offs increased $320 million in 2017 to $440 million due to a single-name non-U.S. commercial charge-off of $292 million in the fourth quarter of 2017.Global Banking. For more information on the non-U.S. commercial portfolio, see Non-U.S. Portfolio on page 70.74.

65Bank of America 2017



Commercial Real Estate
Commercial real estate primarily includes commercial loans and leases 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 loans and leases portfolio at both December 31, 20172020 and 2016.2019. 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. Outstanding loans increased $943 million, or two percent, during 2017 to $58.3 billion at December 31, 2017 due to new originations outpacing paydowns.
During 2017,2020, we continued to see low default rates and solid credit qualityvarying degrees of improvement in both the residential and non-residential portfolios.
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.
Nonperforming commercial real estate loans and foreclosed properties increased $78 million, or 91 percent, during 2017 to $164 million at December 31, 2017 and reservable criticized balances increased $167 million, or 42 percent, to $566 million primarily due to loan downgrades. Net charge-offs were $9 million for 2017 compared to net recoveries of $31 million in 2016.
Table 3734 presents outstanding commercial real estate loans by geographic region, based on the geographic location of the collateral, and by property type.
Table 34Outstanding Commercial Real Estate Loans
December 31
(Dollars in millions)20202019
By Geographic Region   
California$14,028 $14,910 
Northeast11,628 12,408 
Southwest8,551 8,408 
Southeast6,588 5,937 
Florida4,294 3,984 
Midwest3,483 3,203 
Illinois2,594 3,349 
Midsouth2,370 2,468 
Northwest1,634 1,638 
Non-U.S. 3,187 3,724 
Other (1)
2,007 2,660 
Total outstanding commercial real estate loans$60,364 $62,689 
By Property Type  
Non-residential
Office$17,667 $17,902 
Industrial / Warehouse8,330 8,677 
Shopping centers / Retail7,931 8,183 
Hotels / Motels7,226 6,982 
Multi-family rental7,051 7,250 
Unsecured2,336 3,438 
Multi-use1,460 1,788 
Other7,146 6,958 
Total non-residential59,147 61,178 
Residential1,217 1,511 
Total outstanding commercial real estate loans$60,364 $62,689 
     
Table 37Outstanding Commercial Real Estate Loans
     
  December 31
(Dollars in millions)2017 2016
By Geographic Region  
  
California$13,607
 $13,450
Northeast10,072
 10,329
Southwest6,970
 7,567
Southeast5,487
 5,630
Midwest3,769
 4,380
Illinois3,263
 2,408
Florida3,170
 3,213
Midsouth2,962
 2,346
Northwest2,657
 2,430
Non-U.S. 3,538
 3,103
Other (1)
2,803
 2,499
Total outstanding commercial real estate loans$58,298
 $57,355
By Property Type 
  
Non-residential   
Office$16,718
 $16,643
Shopping centers / Retail8,825
 8,794
Multi-family rental8,280
 8,817
Hotels / Motels6,344
 5,550
Industrial / Warehouse6,070
 5,357
Multi-use2,771
 2,822
Unsecured2,187
 1,730
Land and land development160
 357
Other5,485
 5,595
Total non-residential56,840
 55,665
Residential1,458
 1,690
Total outstanding commercial real estate loans$58,298
 $57,355
(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.
(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,. Credit and includes $22.7 billion of PPP loans outstanding at December 31, 2020. Excluding PPP, credit card-related products were 50 percent and 4852 percent of the U.S. small business commercial portfolio at December 31, 2017
2020 and 2016. Net charge-offs of $215 million during 2017 were relatively flat compared to $208 million during 2016.2019. Of the U.S. small business commercial net charge-offs, 9091 percent and 8694 percent were credit card-related products in 20172020 and 2016.2019.

Bank of America 201766


Nonperforming Commercial Loans, Leases and Foreclosed Properties Activity
Table 3835 presents the nonperforming commercial loans, leases and foreclosed properties activity during 20172020 and 2016. 2019.
71 Bank of America


Nonperforming loans do not include loans accounted for under the fair value option. During 2017,2020, nonperforming commercial loans and leases decreased $399increased $728 million to $1.3 billion. Approximately
77$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 approximately 5966 percent were
contractually current. Commercial nonperforming loans were carried at approximately 8781 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 propertycollateral value less costs to sell.
Table 35
Nonperforming Commercial Loans, Leases and Foreclosed Properties Activity (1, 2)
(Dollars in millions)20202019
Nonperforming loans and leases, January 1$1,499 $1,102 
Additions3,518 2,048 
Reductions: 
Paydowns(1,002)(648)
Sales(350)(215)
Returns to performing status (3)
(172)(120)
Charge-offs(1,208)(478)
Transfers to foreclosed properties(2)(9)
Transfers to loans held-for-sale(56)(181)
Total net additions to nonperforming loans and leases728 397 
Total nonperforming loans and leases, December 312,227 1,499 
Foreclosed properties, December 3141 56 
Nonperforming commercial loans, leases and foreclosed properties, December 312,268 1,555 
Nonperforming commercial loans and leases as a percentage of outstanding commercial loans and leases (4)
0.45 %0.29 %
Nonperforming commercial loans, leases and foreclosed properties as a percentage of outstanding commercial loans, leases and foreclosed properties (4)
0.46 0.30 
     
Table 38
Nonperforming Commercial Loans, Leases and Foreclosed Properties Activity (1, 2)
   
(Dollars in millions)2017 2016
Nonperforming loans and leases, January 1$1,703
 $1,212
Additions1,616
 2,347
Reductions:   
Paydowns(930) (824)
Sales(136) (318)
Returns to performing status (3)
(280) (267)
Charge-offs(455) (434)
Transfers to foreclosed properties(40) (4)
Transfers to loans held-for-sale(174) (9)
Total net additions/(reductions) to nonperforming loans and leases(399) 491
Total nonperforming loans and leases, December 311,304
 1,703
Total foreclosed properties, December 3152
 14
Nonperforming commercial loans, leases and foreclosed properties, December 31$1,356
 $1,717
Nonperforming commercial loans and leases as a percentage of outstanding commercial loans and leases (4)
0.27% 0.38%
Nonperforming commercial loans, leases and foreclosed properties as a percentage of outstanding commercial loans, leases and foreclosed properties (4)
0.28
 0.38
(1)Balances do not include nonperforming loans held-for-sale of $359 million and $239 million at December 31, 2020 and 2019.
(1)
Balances do not include nonperforming LHFS of $339 million and $195 million at December 31, 2017 and 2016.
(2)
Includes U.S. small business commercial activity. Small business card loans are excluded as they are not classified as nonperforming.
(3)
Commercial loans and leases may be returned to performing status when all principal and interest is current and full repayment of the remaining contractual principal and interest is expected, or when the loan otherwise becomes well-secured and is in the process of collection. TDRs are generally classified as performing after a sustained period of demonstrated payment performance.
(4)
Outstanding commercial loans exclude loans accounted for under the fair value option.
(2)Includes U.S. small business commercial activity. Small business card loans are excluded as they are not classified as nonperforming.
(3)Commercial loans and leases may be returned to performing status when all principal and interest is current and full repayment of the remaining contractual principal and interest is expected, or when the loan otherwise becomes well-secured and is in the process of collection. TDRs are generally classified as performing after a sustained period of demonstrated payment performance.
(4)Outstanding commercial loans exclude loans accounted for under the fair value option.
Table 3936 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 45
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 25 and Note 1 – Summary of Significant Accounting Principles to the Consolidated Financial Statements.
            
Table 39Commercial Troubled Debt Restructurings
Table 36Table 36Commercial Troubled Debt Restructurings
  
 December 31, 2017 December 31, 2016December 31, 2020December 31, 2019
(Dollars in millions)(Dollars in millions)Nonperforming Performing Total Nonperforming Performing Total(Dollars in millions)NonperformingPerformingTotalNonperformingPerformingTotal
Commercial and industrial:Commercial and industrial:Commercial and industrial:
U.S. commercialU.S. commercial$370
 $866
 $1,236
 $720
 $1,140
 $1,860
U.S. commercial$509 $850 $1,359 $617 $999 $1,616 
Non-U.S. commercialNon-U.S. commercial11
 219
 230
 25
 283
 308
Non-U.S. commercial49 119 168 41 193 234 
Total commercial and industrialTotal commercial and industrial381
 1,085
 1,466
 745
 1,423
 2,168
Total commercial and industrial558 969 1,527 658 1,192 1,850 
Commercial real estateCommercial real estate38
 9
 47
 45
 95
 140
Commercial real estate137  137 212 14 226 
Commercial lease financingCommercial lease financing5
 13
 18
 2
 2
 4
Commercial lease financing42 2 44 18 31 49 
424
 1,107
 1,531
 792
 1,520
 2,312
737 971 1,708 888 1,237 2,125 
U.S. small business commercialU.S. small business commercial4
 15
 19
 2
 13
 15
U.S. small business commercial 29 29 — 27 27 
Total commercial troubled debt restructuringsTotal commercial troubled debt restructurings$428
 $1,122
 $1,550
 $794
 $1,533
 $2,327
Total commercial troubled debt restructurings$737 $1,000 $1,737 $888 $1,264 $2,152 
Industry Concentrations
Table 4037 presents commercial committed and utilized credit exposure by industry and the total net credit default protection purchased to cover the funded and unfunded portions of certain credit exposures. Our commercial credit exposure is diversified across a broad range of industries. Total commercial committed exposure increased $30.1decreased $22.1 billion, or threetwo percent, in 2017during 2020 to $981.2 billion at December 31, 2017.$1.0 trillion. The increasedecrease in commercial committed exposure was concentrated in the Media, Food & Staples Retailing, Capital Goods, Food, BeverageGlobal commercial banks, Asset managers and Tobaccofunds, Utilities, and the Asset Managers and FundsReal estate industry sectors. IncreasesDecreases were partially offset by reducedincreased exposure to the Healthcare EquipmentFinance companies and
Services, Telecommunications Services Automobiles and the Technology Hardware and Equipmentcomponents industry sectors.
Industry limits are used internally to manage industry concentrations and are based on committed exposure that is allocated
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 Managersmanagers and Funds,funds, our largest industry concentration with committed exposure of $91.1$101.5 billion, increased $5.5decreased $8.5 billion, or sixeight percent, in 2017. The increase primarily reflected an increase in exposure to several counterparties.during 2020.


67Bank of America 2017



Real estate, our second largest industry concentration with committed exposure of $83.8$92.4 billion, increased $115 million,decreased $4.0 billion, or less than onefour percent, in 2017.during 2020. For more information on the commercial real estate and related portfolios, see Commercial Portfolio Credit Risk Management – Commercial Real Estate on page 66.71.
Capital Goods,goods, our third largest industry concentration with committed exposure of $70.4$81.0 billion, increased $6.2 billion,remained flat during 2020.
Bank of America 72


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 nearly 10 percent, in 2017.could experience a more significant impact to their financial condition. The increase in committed exposureimpact of the pandemic has also placed significant stress on global demand for oil. Our energy-
occurred primarily as a result of increases in large conglomerates and machinery manufacturers.
Our energy-relatedrelated committed exposure decreased $2.5$3.3 billion, or sixnine percent, during 2020 to $33.0 billion, driven by declines in 2017exploration 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 25.
Table 37
Commercial Credit Exposure by Industry (1)
Commercial
Utilized
Total Commercial
Committed (2)
December 31
(Dollars in millions)2020201920202019
Asset managers and funds$68,093 $71,386 $101,540 $110,069 
Real estate (3)
69,267 70,361 92,414 96,370 
Capital goods39,911 41,082 80,959 80,892 
Finance companies46,948 40,173 70,004 63,942 
Healthcare equipment and services33,759 34,353 57,880 55,918 
Government and public education41,669 41,889 56,212 53,566 
Materials24,548 26,663 50,792 52,129 
Retailing24,749 25,868 49,710 48,317 
Consumer services32,000 28,434 48,026 49,071 
Food, beverage and tobacco22,871 24,163 44,628 45,956 
Commercial services and supplies21,154 23,103 38,149 38,944 
Transportation23,426 23,449 33,444 33,028 
Energy13,936 16,406 32,983 36,326 
Utilities12,387 12,383 29,234 36,060 
Individuals and trusts18,784 18,927 25,881 27,817 
Technology hardware and equipment10,515 10,646 24,796 24,072 
Media13,144 12,445 24,677 23,645 
Software and services11,709 10,432 23,647 20,556 
Global commercial banks20,751 30,171 22,922 32,345 
Automobiles and components10,956 7,345 20,765 14,910 
Consumer durables and apparel9,232 10,193 20,223 21,245 
Vehicle dealers15,028 18,013 18,696 21,435 
Pharmaceuticals and biotechnology5,217 5,964 16,349 20,206 
Telecommunication services9,411 9,154 15,605 16,113 
Insurance5,921 6,673 13,491 15,218 
Food and staples retailing5,209 6,290 11,810 10,392 
Financial markets infrastructure (clearinghouses)4,939 5,496 8,648 7,997 
Religious and social organizations4,769 3,844 6,759 5,756 
Total commercial credit exposure by industry$620,303 $635,306 $1,040,244 $1,062,295 
Net credit default protection purchased on total commitments (4)
  $(4,170)$(3,349)
(1)Includes U.S. small business commercial exposure.
(2)Includes the notional amount of unfunded legally binding lending commitments net of amounts distributed (i.e., syndicated or participated) to $36.8other financial institutions. The distributed amounts were $10.5 billion and $10.6 billion at December 31, 2017. Energy sector2020 and 2019.
(3)Industries are viewed from a variety of perspectives to best isolate the perceived risks. For purposes of this table, the real estate industry is defined based on the primary business activity of the borrowers or counterparties using operating cash flows and primary source of repayment as key factors.
(4)Represents net charge-offs were $156 million in 2017 comparednotional credit protection purchased to $241 million in 2016. Energy sector reservable criticized exposure decreased $3.9 billion in 2017 to $1.6 billion at December 31, 2017, due to paydownshedge funded and upgrades inunfunded exposures for which we elected the energy portfolio. The energy allowance forfair value option, as well as certain other credit losses decreased $365 million to $560 million at December 31, 2017.exposures. For more information, see Commercial Portfolio Credit Risk Management – Risk Mitigation.
         
Table 40
Commercial Credit Exposure by Industry (1)
         
  
Commercial
Utilized
 
Total Commercial
Committed (2)
  December 31
(Dollars in millions)2017 2016 2017 2016
Asset managers and funds$59,190
 $57,659
 $91,092
 $85,561
Real estate (3)
61,940
 61,203
 83,773
 83,658
Capital goods36,705
 34,278
 70,417
 64,202
Government and public education48,684
 45,694
 58,067
 54,626
Healthcare equipment and services37,780
 37,656
 57,256
 64,663
Finance companies34,050
 35,452
 53,107
 52,953
Retailing26,117
 25,577
 48,796
 49,082
Materials24,001
 22,578
 47,386
 44,357
Consumer services27,191
 27,413
 43,605
 42,523
Food, beverage and tobacco23,252
 19,669
 42,815
 37,145
Energy16,345
 19,686
 36,765
 39,231
Commercial services and supplies22,100
 21,241
 35,496
 35,360
Media19,155
 13,419
 33,955
 27,116
Global commercial banks29,491
 27,267
 31,764
 30,712
Transportation21,704
 19,805
 29,946
 27,483
Utilities11,342
 11,349
 27,935
 27,140
Individuals and trusts18,549
 16,364
 25,097
 21,764
Technology hardware and equipment10,728
 9,625
 22,071
 25,318
Vehicle dealers16,896
 16,053
 20,361
 19,425
Pharmaceuticals and biotechnology5,653
 5,539
 18,623
 18,910
Software and services8,562
 7,991
 18,202
 19,790
Consumer durables and apparel8,859
 8,112
 17,296
 15,794
Food and staples retailing4,955
 4,795
 15,589
 8,869
Automobiles and components5,988
 5,459
 13,318
 12,969
Telecommunication services6,389
 6,317
 13,108
 16,925
Insurance6,411
 7,406
 12,990
 13,936
Religious and social organizations4,454
 4,423
 6,318
 6,252
Financial markets infrastructure (clearinghouses)688
 656
 2,403
 3,107
Other3,621
 2,206
 3,616
 2,210
Total commercial credit exposure by industry$600,800
 $574,892
 $981,167
 $951,081
Net credit default protection purchased on total commitments (4)
 
  
 $(2,129) $(3,477)
(1)
Includes U.S. small business commercial exposure.
(2)
Includes the notional amount of unfunded legally binding lending commitments net of amounts distributed (e.g., syndicated or participated) to other financial institutions. The distributed amounts were $11.0 billion and $12.1 billion at December 31, 2017 and 2016.
(3)
Industries are viewed from a variety of perspectives to best isolate the perceived risks. For purposes of this table, the real estate industry is defined based on the borrowers’ or counterparties’ primary business activity using operating cash flows and primary source of repayment as key factors.
(4)
Represents net notional credit protection purchased. 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, 20172020 and 2016,2019, 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 $2.1$4.2 billion and $3.5$3.3 billion. We recorded net losses of $66$240 million in 20172020 compared to net losses of $438$145 million in 2016 on2019 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 49.44. For more information, see Trading Risk Management on page 77.79.



73Bank of America 201768



Tables 4138 and 4239 present the maturity profiles and the credit exposure debt ratings of the net credit default protection portfolio at December 31, 20172020 and 2016.2019.
Table 38Net Credit Default Protection by Maturity
December 31
20202019
Less than or equal to one year65 %54 %
Greater than one year and less than or equal to five years34 45 
Greater than five years1 
Total net credit default protection100 %100 %
     
Table 41Net Credit Default Protection by Maturity
     
  December 31
  2017 2016
Less than or equal to one year42% 56%
Greater than one year and less than or equal to five years58
 41
Greater than five years
 3
Total net credit default protection100% 100%
Table 39Net Credit Default Protection by Credit Exposure Debt Rating
Net
Notional
(1)
Percent of
Total
Net
Notional
(1)
Percent of
Total
 December 31
(Dollars in millions)20202019
Ratings (2, 3)
    
A$(250)6.0 %$(697)20.8 %
BBB(1,856)44.5 (1,089)32.5 
BB(1,363)32.7 (766)22.9 
B(465)11.2 (373)11.1 
CCC and below(182)4.4 (119)3.6 
NR (4)
(54)1.2 (305)9.1 
Total net credit
default protection
$(4,170)100.0 %$(3,349)100.0 %
(1)Represents net credit default protection purchased.
         
Table 42Net Credit Default Protection by Credit Exposure Debt Rating
         
  
Net
Notional
(1)
 Percent of
Total
 
Net
Notional
(1)
 Percent of
Total
  December 31
(Dollars in millions)2017 2016
Ratings (2, 3)
 
  
  
  
A$(280) 13.2% $(135) 3.9%
BBB(459) 21.6
 (1,884) 54.2
BB(893) 41.9
 (871) 25.1
B(403) 18.9
 (477) 13.7
CCC and below(84) 3.9
 (81) 2.3
NR (4)
(10) 0.5
 (29) 0.8
Total net credit default protection$(2,129) 100.0% $(3,477) 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.
(2)Ratings are refreshed on a quarterly basis.
(3)Ratings of BBB- or higher are considered to meet the definition of investment grade.
(4)NR is comprised of index positions held and any names that have not been rated.
In addition to our net notional credit default protection purchased to cover the funded and unfunded portion of certain credit exposures, credit derivatives are used for market-making activities for clients and establishing positions intended to profit from directional or relative value changes. We execute the majority of our credit derivative trades in the OTC market with large, multinational financial institutions, including broker-dealers and, to a lesser degree, with a variety of other investors. Because these transactions are executed in the OTC market, we are subject to settlement risk. We are also subject to credit risk in the event that these counterparties fail to perform under the terms of these contracts. In order to properly reflect counterparty credit risk, we record counterparty credit risk valuation adjustments on certain derivative assets, including our
purchased credit default protection. In most cases, credit derivative transactions are executed on a daily margin basis. Therefore, events such as a credit downgrade, depending on the ultimate rating level, or a breach of credit covenants would typically require an increase in the amount of collateral required by the counterparty, where applicable, and/or allow us to take additional protective measures such as early termination of all trades.
Table 43 presents the total contract/notional amount of credit derivatives outstanding and includes both purchased and written credit derivatives. The credit risk amounts are measured as net asset exposure by counterparty, taking into consideration all contracts with the counterparty. For more information on our written credit derivatives see Note 2 – Derivatives to the Consolidated Financial Statements.
The credit risk amounts discussed above and presented in Table 43 take into consideration the effects of legally enforceable master netting agreements while amounts disclosed in Note 2 – Derivatives to the Consolidated Financial Statements are shown on a gross basis. Credit risk reflects the potential benefit from offsetting exposure to non-credit derivative products with the same counterparties that may be netted upon the occurrence of certain events, thereby reducing our overall exposure.
         
Table 43Credit Derivatives
         
  Contract/
Notional
 Credit Risk Contract/
Notional
 Credit Risk
  December 31
(Dollars in millions)2017 2016
Purchased credit derivatives: 
  
  
  
Credit default swaps$470,907
 $2,434
 $603,979
 $2,732
Total return swaps/options54,135
 277
 21,165
 433
Total purchased credit derivatives$525,042
 $2,711
 $625,144
 $3,165
Written credit derivatives: 
  
  
  
Credit default swaps$448,201
 n/a
 $614,355
 n/a
Total return swaps/options55,223
 n/a
 25,354
 n/a
Total written credit derivatives$503,424
 n/a
 $639,709
 n/a
n/a = not applicable

69Bank of America 2017



Counterparty Credit Risk Valuation Adjustments
We record counterparty credit risk valuation adjustments, on certain derivative assets, including our credit default protection purchased, in order to properly reflect the credit risk of the counterparty, as presented in Table 44. We calculate CVA based on a modeled expected exposure that incorporates current market risk factors including changes in market spreads and non-credit related market factors that affect the value of a derivative. The exposure also takes into consideration credit mitigants such as legally enforceable master netting agreements and collateral. For more information, see Note 23 – Derivatives to the Consolidated Financial Statements.
We enter into risk management activities to offset market driven exposures. We often hedge the counterparty spread risk in CVA with credit default swaps (CDS). We hedge other market risks in CVA primarily with currency and interest rate swaps. In certain instances, the net-of-hedge amounts in the following table move in the same direction as the gross amount or may move in the opposite direction. This movement is a consequence of the complex interaction of the risks being hedged, resulting in limitations in the ability to perfectly hedge all of the market exposures at all times.
         
Table 44Credit Valuation Gains and Losses
     
(Dollars in millions)2017 2016
Gains (Losses)GrossHedgeNet GrossHedgeNet
Credit valuation$330
$(232)$98
 $374
$(160)$214
Non-U.S. Portfolio
Our non-U.S. credit and trading portfolios are subject to country risk. We define country risk as the risk of loss from unfavorable economic and political conditions, currency fluctuations, social instability and changes in government policies. A risk management framework is in place to measure, monitor and manage non-U.S. risk and exposures. In addition to the direct risk of doing business in a country, we also are exposed to indirect country risks (e.g.,
related to the collateral received on secured financing transactions or related to client clearing activities). These indirect exposures are managed in the normal course of business through credit, market and operational risk governance, rather than through country risk governance.
Table 4540 presents our 20 largest non-U.S. country exposures as ofat December 31, 2017.2020. These exposures accounted for 8690 percent and 88 percent of our total non-U.S. exposure at December 31, 20172020 and 2016.2019. Net country exposure for these 20 countries decreased $6.3increased $21.2 billion in 2017primarily driven by reductions in the U.K., Japan, Switzerland and Brazil, partially offset by increases in China and Belgium. On a product basis, funded commitments decreased in the U.K., Japan and Brazil, partially offset by increases in China, Belgium and France.2020. The decrease in the U.K. reflects the salemajority of the non-U.S. consumer credit card businessincrease was due to higher deposits with central banks in 2017. Unfunded commitments increased in the U.K., Germany and Belgium, which was partly offset by a decrease in Switzerland. Securities held decreased, driven by reduced holdings in France, the U.K. and Germany, while counterparty exposure decreased in Japan, Germany and the U.K.Japan.
Non-U.S. exposure is presented on an internal 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.
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 CDS,credit default swaps (CDS), and secured financing transactions. Securities and other investments are carried at fair value and long securities exposures are netted against short exposures with the same underlying issuer to, but not below, zero. Net country exposure represents country exposure less hedges and credit default protection purchased, net of credit default protection sold.

Bank of America 20177074



                
Table 45Top 20 Non-U.S. Countries Exposure
Table 40Table 40Top 20 Non-U.S. Countries Exposure
                
(Dollars in millions)(Dollars in millions)Funded Loans and Loan Equivalents Unfunded Loan Commitments Net Counterparty Exposure 
Securities/
Other
Investments
 Country Exposure at December 31
2017
 Hedges and Credit Default Protection Net Country Exposure at December 31
2017
 Increase (Decrease) from December 31
2016
(Dollars in millions)Funded Loans and Loan EquivalentsUnfunded Loan CommitmentsNet Counterparty ExposureSecurities/
Other
Investments
Country Exposure at December 31
2020
Hedges and Credit Default ProtectionNet Country Exposure at December 31
2020
Increase (Decrease) from December 31
2019
United KingdomUnited Kingdom$20,089
 $14,906
 $5,278
 $1,962
 $42,235
 $(4,640) $37,595
 $(10,138)United Kingdom$31,817 $18,201 $6,601 $4,086 $60,705 $(1,233)$59,472 $3,628 
GermanyGermany12,572
 9,856
 1,061
 1,102
 24,591
 (3,088) 21,503
 (875)Germany29,169 10,772 2,155 4,492 46,588 (1,685)44,903 14,075 
CanadaCanada7,037
 7,645
 2,016
 2,579
 19,277
 (554) 18,723
 (51)Canada8,657 8,681 1,624 2,628 21,590 (456)21,134 1,012 
FranceFrance8,219 8,353 988 4,329 21,889 (1,098)20,791 4,536 
JapanJapan12,679 1,086 1,115 3,325 18,205 (709)17,496 6,964 
ChinaChina13,634
 728
 746
 1,058
 16,166
 (241) 15,925
 5,040
China10,098 67 1,529 1,952 13,646 (226)13,420 (2,167)
AustraliaAustralia6,559 4,242 372 2,235 13,408 (321)13,087 1,985 
BrazilBrazil7,688
 501
 342
 2,726
 11,257
 (541) 10,716
 (2,950)Brazil5,854 696 708 3,288 10,546 (253)10,293 (1,479)
Australia5,596
 2,840
 575
 2,022
 11,033
 (444) 10,589
 1,666
France4,976
 5,591
 2,191
 2,811
 15,569
 (5,026) 10,543
 (151)
NetherlandsNetherlands4,654 4,109 486 997 10,246 (562)9,684 (643)
SingaporeSingapore4,115 278 359 4,603 9,355 (73)9,282 1,456 
South KoreaSouth Korea5,161 856 488 2,214 8,719 (168)8,551 (154)
IndiaIndia7,229
 316
 375
 3,328
 11,248
 (751) 10,497
 1,269
India5,428 221 353 1,989 7,991 (180)7,811 (4,206)
Japan7,399
 631
 923
 1,669
 10,622
 (1,532) 9,090
 (5,921)
SwitzerlandSwitzerland3,811 2,817 412 130 7,170 (275)6,895 (490)
Hong KongHong Kong6,925
 187
 585
 1,056
 8,753
 (75) 8,678
 1,199
Hong Kong4,434 452 584 1,128 6,598 (61)6,537 (519)
Netherlands5,357
 3,212
 650
 930
 10,149
 (1,682) 8,467
 1,069
South Korea4,934
 544
 635
 2,208
 8,321
 (420) 7,901
 1,795
Singapore3,571
 312
 504
 1,953
 6,340
 (77) 6,263
 845
Switzerland3,792
 2,810
 274
 184
 7,060
 (1,263) 5,797
 (3,849)
MexicoMexico2,883
 2,446
 226
 385
 5,940
 (453) 5,487
 1,003
Mexico3,712 1,379 205 1,112 6,408 (121)6,287 (1,524)
ItalyItaly2,791
 1,490
 512
 600
 5,393
 (1,147) 4,246
 159
Italy2,456 1,784 553 1,568 6,361 (669)5,692 315 
BelgiumBelgium2,440
 1,184
 82
 511
 4,217
 (252) 3,965
 2,039
Belgium2,471 1,334 505 797 5,107 (140)4,967 (1,540)
SpainSpain2,835 1,156 262 914 5,167 (351)4,816 94 
IrelandIreland2,785 1,050 100 253 4,188 (23)4,165 798 
United Arab EmiratesUnited Arab Emirates2,843
 351
 247
 43
 3,484
 (97) 3,387
 644
United Arab Emirates2,218 136 266 77 2,697 (10)2,687 (900)
Spain2,041
 820
 260
 1,232
 4,353
 (1,245) 3,108
 562
Turkey2,761
 83
 66
 82
 2,992
 (3) 2,989
 299
Total top 20 non-U.S. countries exposureTotal top 20 non-U.S. countries exposure$126,558
 $56,453
 $17,548
 $28,441
 $229,000
 $(23,531) $205,469
 $(6,346)Total top 20 non-U.S. countries exposure$157,132 $67,670 $19,665 $42,117 $286,584 $(8,614)$277,970 $21,241 
A number of economic conditions and geopolitical events have given rise to risk aversion in certain emerging markets. Our two largest emerging market country exposures at December 31, 2017 were China and Brazil. At December 31, 2017, net exposure to China was $15.9 billion, concentrated in large state-owned companies, subsidiaries of multinational corporations and commercial banks. At December 31, 2017, net exposure to Brazil was $10.7 billion, concentrated in sovereign securities, oil and gas companies and commercial banks.
The outlook for policy direction and therefore economic performance in the EU remains uncertain as a consequence of reduced political cohesion among EU countries. Additionally, we believe that the uncertainty in the U.K.’s ability to negotiate a favorable exit from the EU will further weigh on economic performance. Our largest EUnon-U.S. country exposure at December 31, 20172020 was the U.K. with net exposure of $37.6$59.5 billion, concentratedwhich 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.
in multinational corporations and sovereign clients.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 – 2017 Economic and Business EnvironmentRecent Developments – COVID-19 Pandemic on page 19.25 and Part I. Item 1A. Risk Factors on page 7.
Table 4641 presents countries wherethat had total cross-border exposure, exceededincluding the notional amount of cash loaned under secured financing agreements, exceeding one percent of our total assets.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, 2017,2020, the U.K. and France were the only countries where their respective total cross-border exposureexposures exceeded one percent of our total assets. At December 31, 2017, Germany had total cross-border exposure of $21.6 billion representing 0.95 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, 2017.
Cross-border exposure includes the components of Country Risk Exposure as detailed in Table 45 as well as the notional amount of cash loaned under secured financing agreements. Local exposure, defined as exposure booked in local offices of a respective country with clients in the same country, is excluded.2020.
          
Table 46Total Cross-border Exposure Exceeding One Percent of Total Assets
Table 41Table 41Total Cross-border Exposure Exceeding One Percent of Total Assets
          
(Dollars in millions)(Dollars in millions)December 31 Public Sector Banks Private Sector Cross-border
Exposure
 Exposure as a
Percent of
Total Assets
(Dollars in millions)December 31Public SectorBanksPrivate SectorCross-border
Exposure
Exposure as a
Percent of
Total Assets
United KingdomUnited Kingdom2017 $923
 $2,984
 $47,205
 $51,112
 2.24%United Kingdom2020$4,733 $2,269 $95,180 $102,182 3.62 %
2016 2,975
 4,557
 42,105
 49,637
 2.27
20191,859 3,580 93,232 98,671 4.05 
2015 3,264
 5,104
 38,576
 46,944
 2.19
20181,505 3,458 46,191 51,154 2.17 
FranceFrance2017 2,964
 1,521
 27,903
 32,388
 1.42
France20203,073 1,726 26,399 31,198 1.11 
2016 4,956
 1,205
 23,193
 29,354
 1.34
2019736 2,473 23,172 26,381 1.08 
 2015 3,343
 1,766
 17,099
 22,208
 1.04
2018633 2,385 29,847 32,865 1.40 


7175Bank of America 2017




Provision for Credit Losses
The provision for credit losses decreased $201 million to $3.4 billion in 2017 compared to 2016. The provision for credit losses was $583 million lower than net charge-offs for 2017, resulting in a reduction in the allowance for credit losses. This compared to a reduction of $224 million in the allowance in 2016.
The provision for credit losses for the consumer portfolio increased $159 million to $2.7 billion in 2017 compared to 2016. The increase was primarily driven by a provision increase of $672 million in the U.S. credit card portfolio due to portfolio seasoning and loan growth, largely offset by the consumer real estate portfolio due to continued portfolio improvement and increased home prices. Included in the provision is an expense of $76 million related to the PCI loan portfolio for 2017 compared to a benefit of $45 million in 2016.
The provision for credit losses for the commercial portfolio, including unfunded lending commitments, decreased $360 million to $669 million in 2017 compared to 2016 driven by reductions in energy exposures, partially offset by a single-name non-U.S. commercial charge-off.
Allowance for Credit Losses
Allowance for Loan and Lease Losses
TheOn January 1, 2020, the Corporation adopted the new accounting standard that requires the measurement of the allowance for loan and leasecredit losses isto 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 two components. The first component covers nonperforming commercial loans and TDRs. The second component covers loans and leases on which there are incurred losses that are not yet individually identifiable, as well as incurred losses that may not be representeda net increase of $2.9 billion in the loss forecast models. We evaluate the adequacy of the allowance for loan and lease losses based onand an increase of $310 million in the total of these two components, each of which is described in more detail below. 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 loancredit 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 lease losses excludes LHFS and loans accounted for undera $2.2 billion reserve increase related to the fair value option asconsumer portfolio. The increases were driven by deterioration in the fair value reflects a credit risk component.economic outlook resulting from the impact of COVID-19.
The first componentfollowing table presents an allocation of the allowance for loan and leasecredit losses covers both nonperforming commercial loans and all TDRs within the consumer and commercial portfolios. These loans are subject to impairment measurement based on the present value of projected future cash flows discounted at the loan’s original effective interest rate, or in certain circumstances, impairment may also be based upon the collateral value or the loan’s observable market price if available. Impairment measurement for the renegotiated consumer credit card, small business credit card and unsecured consumer TDR portfolios is based on the present value of projected cash flows discounted using the average portfolio contractual interest rate, excluding promotionally priced loans, in effect prior to restructuring. For purposes of computing this specific loss component of the allowance, larger impaired loans are evaluated individually and smaller impaired loans are evaluated as a pool using historical experience for the respective product types and risk ratings of the loans.
The second component of the allowance for loan and lease losses covers the remaining consumer and commercial loans and leases that have incurred losses that are not yet individually identifiable. The allowance for consumer and certain homogeneous commercial loan and lease products is based on aggregated portfolio evaluations, generally by product type. Loss forecast models are utilized that consider a variety of factors
including, but not limited to, historical loss experience, estimated defaults or foreclosures based on portfolio trends, delinquencies, economic trends and credit scores. Our consumer real estate loss forecast model estimates the portion of loans that will default based on individual loan attributes, the most significant of which are refreshed LTV or CLTV, and borrower credit score as well as vintage and geography, all of which are further broken down into current delinquency status. Additionally, we incorporate the delinquency status of underlying first-lien loans on our junior-lien home equity portfolio in our allowance process. Incorporating refreshed LTV and CLTV into our probability of default allows us to factor the impact of changes in home prices into our allowance for loan and lease losses. These loss forecast models are updated on a quarterly basis to incorporate information reflecting the current economic environment. As of December 31, 2017, the loss forecast process resulted in reductions in the allowance related to the residential mortgage and home equity portfolios compared to December 31, 2016.
The allowance for commercial loan and lease losses is established by product type after analyzing historical loss experience, internal risk rating, current economic conditions, industry performance trends, geographic for December 31, 2020, January 1, 2020and obligor concentrations within each portfolio and any other pertinent information. The statistical models for commercial loans are generally updated annually and utilize our historical database of actual defaults and other data, including external default data. The loan risk ratings and compositionDecember 31, 2019 (prior to the adoption of the commercial portfolios used to calculate the allowance are updated quarterly to incorporate the most recent data reflecting the current economic environment. For risk-rated commercial loans, we estimate the probability of default and the loss given default (LGD) based on our historical experience of defaults and credit losses. Factors considered when assessing the internal risk rating include the value of the underlying collateral, if applicable, the industry in which the obligor operates, the obligor’s liquidity and other financial indicators, and other quantitative and qualitative factors relevant to the obligor’s credit risk. As of December 31, 2017, the allowance decreased for the U.S. commercial and non-U.S. commercial portfolios compared to December 31, 2016.
Also included within the second component of the allowance for loan and lease losses are reserves to cover losses that are incurred but, in our assessment, may not be adequately represented in the historical loss data used in the loss forecast models. For example, factors that we consider include, among others, changes in lending policies and procedures, changes in economic and business conditions, changes in the nature and size of the portfolio, changes in portfolio concentrations, changes in the volume and severity of past due loans and nonaccrual loans, the effect of external factors such as competition, and legal and regulatory requirements. We also consider factors that are applicable to unique portfolio segments. For example, we consider the risk of uncertainty in our loss forecasting models related to junior-lien home equity loans that are current, but have first-lien loans that we do not service that are 30 days or more past due. In addition, we consider the increased risk of default associated with our interest-only loans that have yet to enter the amortization period. Further, we consider the inherent uncertainty in mathematical models that are built upon historical data.CECL accounting standard).

Table 42Allocation of the Allowance for Credit Losses by Product Type
AmountPercent of
Total
Percent of
Loans and
Leases
Outstanding (1)
AmountPercent of
Total
Percent of
Loans and
Leases
Outstanding
(1)
AmountPercent of
Total
Percent of
Loans and
Leases
Outstanding (1)
(Dollars in millions)December 31, 2020January 1, 2020December 31, 2019
Allowance for loan and lease losses      
Residential mortgage$459 2.44 %0.21 %$212 1.72 %0.09 %$325 3.45 %0.14 %
Home equity399 2.12 1.16 228 1.84 0.57 221 2.35 0.55 
Credit card8,420 44.79 10.70 6,809 55.10 6.98 3,710 39.39 3.80 
Direct/Indirect consumer752 4.00 0.82 566 4.58 0.62 234 2.49 0.26 
Other consumer41 0.22 n/m55 0.45 n/m52 0.55 n/m
Total consumer10,071 53.57 2.35 7,870 63.69 1.69 4,542 48.23 0.98 
U.S. commercial (2)
5,043 26.82 1.55 2,723 22.03 0.84 3,015 32.02 0.94 
Non-U.S. commercial1,241 6.60 1.37 668 5.41 0.64 658 6.99 0.63 
Commercial real estate2,285 12.15 3.79 1,036 8.38 1.65 1,042 11.07 1.66 
Commercial lease financing162 0.86 0.95 61 0.49 0.31 159 1.69 0.80 
Total commercial8,731 46.43 1.77 4,488 36.31 0.88 4,874 51.77 0.96 
Allowance for loan and lease losses18,802 100.00 %2.04 12,358 100.00 %1.27 9,416 100.00 %0.97 
Reserve for unfunded lending commitments1,878 1,123 813  
Allowance for credit losses$20,680 $13,481 $10,229 

Bank of America 201772


During 2017, the factors that impacted the allowance for loan and lease losses included improvements in the credit quality of the consumer real estate portfolios driven by continuing improvements in the U.S. economy and labor markets, proactive credit risk management initiatives and the impact of high credit quality originations. Evidencing the improvements in the U.S. economy and labor markets(1)Ratios are downward unemployment trends and increases in home prices. In addition to these improvements, in the consumer portfolio, nonperforming consumer loans decreased $838 million in 2017calculated as returns to performing status, charge-offs, paydowns and loan sales continued to outpace new nonaccrual loans. During 2017, the allowance for loan and lease losses in the commercial portfolio reflected decreased energy reserves primarily driven by reductions in energy exposures including utilized reservable criticized exposures.
We monitor differences between estimated and actual incurred loan and lease losses. This monitoring process includes periodic assessments by senior management of loan and lease portfolios and the models used to estimate incurred losses in those portfolios.
The allowance for loan and lease losses for the consumer portfolio, as presented in Table 48, was $5.4 billion at December 31, 2017, a decrease of $839 million from December 31, 2016. The decrease was primarily in the consumer real estate portfolio and the non-U.S. card portfolio which was sold in 2017, partially offset by an increase in the U.S. credit card portfolio. The reduction in the consumer real estate portfolio was due to improved home prices, lower nonperforming loans and a decrease in loan balances in our non-core portfolio. The increase in the U.S. credit card portfolio was driven by portfolio seasoning and loan growth.
The allowance for loan and lease losses for the commercial portfolio, as presented in Table 48, was $5.0 billion at December 31, 2017, a decrease of $248 million from December 31, 2016 driven by decreased energy reserves due to reductions in the higher risk energy sub-sectors. Commercial utilized reservable criticized exposure decreased to $13.6 billion at December 31, 2017 from $16.3 billion (to 2.65 percent from 3.35 percent of total commercial utilized reservable exposure) at December 31, 2016, largely due to paydowns and net upgrades in the energy portfolio. Nonperforming commercial loans decreased to $1.3
billion at December 31, 2017 from $1.7 billion (to 0.27 percentfrom0.38 percent of outstanding commercial loans excluding loans accounted for under the fair value option) at December 31, 2016 with the decrease primarily in the energy and metal and mining sectors. See Tables 34, 35 and 36 for more details on key commercial credit statistics.
The allowance for loan and lease losses as a percentage of total loans and leases outstanding was 1.12 percent at December 31, 2017 compared to 1.26 percent at December 31, 2016. The decrease in the ratio was primarily due to improved credit quality in the consumer real estate portfolio driven by improved economic conditions. The December 31, 2017 and 2016 ratios above include the PCI loan portfolio. Excluding the PCI loan portfolio, the allowance for loan and lease losses as a percentage of totalexcluding loans and leases outstanding was 1.10 percent and 1.24 percent at December 31, 2017 and 2016.
Reserve for Unfunded Lending Commitments
In addition to the allowance for loan and lease losses, we also estimate probable losses 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. Unfunded lending commitments are subject toConsumer loans accounted for under the same assessment as fundedfair value option include residential mortgage loans including estimates of probability of default and LGD. Due to the nature of unfunded commitments, the estimate of probable losses must also consider utilization. To estimate the portion of these undrawn commitments that is likely to be drawn by a borrower at the time of estimated default, analyses of our historical experience are applied to the unfunded commitments to estimate the funded exposure at default (EAD). The expected loss for unfunded lending commitments is the product of the probability of default, the LGD and the EAD, adjusted for any qualitative factors including economic uncertainty and inherent imprecision in models.
The reserve for unfunded lending commitments was $777$298 million at December 31, 2017 compared to $7622020 and $257 million at January 1, 2020 and December 31, 2019 and home equity loans of $437 million at December 31, 2016.
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.

(2)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
73Bank of America 2017
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



Table 47
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, which includesincluding certain loan and allowance ratios for 2020, noting that measurement of the allowance for loancredit losses for 2019 was based on management’s estimate of probable incurred losses. For more information on the Corporation’s credit loss accounting policies and leaseactivity 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 reserve for unfunded lending commitments, for 2017 and 2016.
Consolidated Financial Statements.
     
Table 47Allowance for Credit Losses   
     
(Dollars in millions)2017 2016
Allowance for loan and lease losses, January 1$11,237
 $12,234
Loans and leases charged off   
Residential mortgage(188) (403)
Home equity(582) (752)
U.S. credit card(2,968) (2,691)
Non-U.S. credit card (1)
(103) (238)
Direct/Indirect consumer(487) (392)
Other consumer(216) (232)
Total consumer charge-offs(4,544) (4,708)
U.S. commercial (2)
(589) (567)
Non-U.S. commercial(446) (133)
Commercial real estate(24) (10)
Commercial lease financing(16) (30)
Total commercial charge-offs(1,075) (740)
Total loans and leases charged off(5,619) (5,448)
Recoveries of loans and leases previously charged off   
Residential mortgage288
 272
Home equity369
 347
U.S. credit card455
 422
Non-U.S. credit card (1)
28
 63
Direct/Indirect consumer276
 258
Other consumer50
 27
Total consumer recoveries1,466
 1,389
U.S. commercial (3)
142
 175
Non-U.S. commercial6
 13
Commercial real estate15
 41
Commercial lease financing11
 9
Total commercial recoveries174
 238
Total recoveries of loans and leases previously charged off1,640
 1,627
Net charge-offs(3,979) (3,821)
Write-offs of PCI loans(207) (340)
Provision for loan and lease losses3,381
 3,581
Other (4)
(39) (174)
Total allowance for loan and lease losses, December 3110,393
 11,480
Less: Allowance included in assets of business held for sale (5)

 (243)
Allowance for loan and lease losses, December 3110,393
 11,237
Reserve for unfunded lending commitments, January 1762
 646
Provision for unfunded lending commitments15
 16
Other (4)

 100
Reserve for unfunded lending commitments, December 31777
 762
Allowance for credit losses, December 31$11,170
 $11,999
(1)
Represents net charge-offs related to the non-U.S. credit card loan portfolio, which was included in assets of business held for sale on the Consolidated Balance Sheet at December 31, 2016. In 2017, the Corporation sold its non-U.S. consumer credit card business.
(2)
Includes U.S. small business commercial charge-offs of $258 million and $253 million in 2017 and 2016.
(3)
Includes U.S. small business commercial recoveries of $43 million and $45 million in 2017 and 2016.
(4)
Primarily represents the net impact of portfolio sales, consolidations and deconsolidations, foreign currency translation adjustments, transfers to held-for-sale and certain other reclassifications.
(5)
Represents allowance related to the non-U.S. credit card loan portfolio, which was sold in 2017.

Bank of America 20177476



Table 43Allowance for Credit Losses
(Dollars in millions)20202019
Allowance for loan and lease losses, January 1$12,358 $9,601 
Loans and leases charged off
Residential mortgage(40)(93)
Home equity(58)(429)
Credit card(2,967)(3,535)
Direct/Indirect consumer(372)(518)
Other consumer(307)(249)
Total consumer charge-offs(3,744)(4,824)
U.S. commercial (1)
(1,163)(650)
Non-U.S. commercial(168)(115)
Commercial real estate(275)(31)
Commercial lease financing(69)(26)
Total commercial charge-offs(1,675)(822)
Total loans and leases charged off(5,419)(5,646)
Recoveries of loans and leases previously charged off
Residential mortgage70 140 
Home equity131 787 
Credit card618 587 
Direct/Indirect consumer250 309 
Other consumer23 15 
Total consumer recoveries1,092 1,838 
U.S. commercial (2)
178 122 
Non-U.S. commercial13 31 
Commercial real estate5 
Commercial lease financing10 
Total commercial recoveries206 160 
Total recoveries of loans and leases previously charged off1,298 1,998 
Net charge-offs(4,121)(3,648)
Provision for loan and lease losses10,565 3,574 
Other (111)
Allowance for loan and lease losses, December 3118,802 9,416 
Reserve for unfunded lending commitments, January 11,123 797 
Provision for unfunded lending commitments755 16 
Reserve for unfunded lending commitments, December 311,878 813 
Allowance for credit losses, December 31$20,680 $10,229 
Loan and allowance ratios:
Loans and leases outstanding at December 31 (3)
$921,180 $975,091 
Allowance for loan and lease losses as a percentage of total loans and leases outstanding at December 31 (3)
2.04 %0.97 %
Consumer allowance for loan and lease losses as a percentage of total consumer loans and leases outstanding at December 31 (4)
2.35 0.98 
Commercial allowance for loan and lease losses as a percentage of total commercial loans and leases outstanding at December 31 (5)
1.77 0.96 
Average loans and leases outstanding (3)
$974,281 $951,583 
Annualized net charge-offs as a percentage of average loans and leases outstanding (3)
0.42 %0.38 %
Allowance for loan and lease losses as a percentage of total nonperforming loans and leases at December 31380 265 
Ratio of the allowance for loan and lease losses at December 31 to net charge-offs4.56 2.58 
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)
$9,854 $4,151 
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)
181 %148 %
(1)Includes U.S. small business commercial charge-offs of $321 million in 2020 compared to $320 million in 2019.
(2)Includes U.S. small business commercial recoveries of $54 million in 2020 compared to $48 million in 2019.
(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.
     
Table 47Allowance for Credit Losses (continued)   
     
(Dollars in millions)2017 2016
Loan and allowance ratios (6):
   
Loans and leases outstanding at December 31 (7)
$931,039
 $908,812
Allowance for loan and lease losses as a percentage of total loans and leases outstanding at December 31 (7)
1.12% 1.26%
Consumer allowance for loan and lease losses as a percentage of total consumer loans and leases outstanding at December 31 (8)
1.18
 1.36
Commercial allowance for loan and lease losses as a percentage of total commercial loans and leases outstanding at December 31 (9)
1.05
 1.16
Average loans and leases outstanding (7)
$911,988
 $892,255
Net charge-offs as a percentage of average loans and leases outstanding (7, 10)
0.44% 0.43%
Net charge-offs and PCI write-offs as a percentage of average loans and leases outstanding (7)
0.46
 0.47
Allowance for loan and lease losses as a percentage of total nonperforming loans and leases at December 31 (7, 11)
161
 149
Ratio of the allowance for loan and lease losses at December 31 to net charge-offs (10)
2.61
 3.00
Ratio of the allowance for loan and lease losses at December 31 to net charge-offs and PCI write-offs2.48
 2.76
Amounts included in allowance for loan and lease losses for loans and leases that are excluded from nonperforming loans and leases at December 31 (12)
$3,971
 $3,951
Allowance for loan and lease losses as a percentage of total nonperforming loans and leases, excluding the allowance for loan and lease losses for loans and leases that are excluded from nonperforming loans and leases at December 31 (7, 12)
99% 98%
Loan and allowance ratios excluding PCI loans and the related valuation allowance (6, 13):
   
Allowance for loan and lease losses as a percentage of total loans and leases outstanding at December 31 (7)
1.10% 1.24%
Consumer allowance for loan and lease losses as a percentage of total consumer loans and leases outstanding at December 31 (8)
1.15
 1.31
Net charge-offs as a percentage of average loans and leases outstanding (7)
0.44
 0.44
Allowance for loan and lease losses as a percentage of total nonperforming loans and leases at December 31 (7, 11)
156
 144
Ratio of the allowance for loan and lease losses at December 31 to net charge-offs2.54
 2.89
(6)
Loan and allowance ratios for 2016 include $243 million of non-U.S. credit card allowance for loan and lease losses and $9.2 billion of ending non-U.S. credit card loans, which were included in assets of business held for sale on the Consolidated Balance Sheet at December 31, 2016. See footnote 1 for more information.
(7)
Outstanding loan and lease balances and ratios do not include loans accounted for under the fair value option of $5.7 billion and $7.1 billion at December 31, 2017 and 2016. Average loans accounted for under the fair value option were $6.7 billion and $8.2 billion in 2017 and 2016.
(8)
Excludes consumer loans accounted for under the fair value option of $928 million and $1.1 billion at December 31, 2017 and 2016.
(9)
Excludes commercial loans accounted for under the fair value option of $4.8 billion and $6.0 billion at December 31, 2017 and 2016.
(10)
Net charge-offs exclude $207 million and $340 million of write-offs in the PCI loan portfolio in 2017 and 2016. For more information on PCI write-offs, see Consumer Portfolio Credit Risk Management – Purchased Credit-impaired Loan Portfolio on page 60.
(11)
For more information on our definition of nonperforming loans, see page 62 and page 67.
(12)
Primarily includes amounts allocated to U.S. credit card and unsecured consumer lending portfolios in Consumer Banking, PCI loans and the non-U.S. credit portfolio in All Other.
(13)
For more information on the PCI loan portfolio and the valuation allowance for PCI loans, see Note 4 – Outstanding Loans and Leases and Note 5 – Allowance for Credit Lossesto the Consolidated Financial Statements.


7577Bank of America 2017



For reporting purposes, we allocate the allowance for credit losses across products as presented in Table 48.
             
Table 48Allocation of the Allowance for Credit Losses by Product Type    
         
 Amount 
Percent of
Total
 
Percent of
Loans and
Leases
Outstanding (1)
 Amount 
Percent of
Total
 
Percent of
Loans and
Leases
Outstanding (1)
(Dollars in millions)December 31, 2017 December 31, 2016
Allowance for loan and lease losses 
  
  
  
  
  
Residential mortgage$701
 6.74% 0.34% $1,012
 8.82% 0.53%
Home equity1,019
 9.80
 1.76
 1,738
 15.14
 2.62
U.S. credit card3,368
 32.41
 3.50
 2,934
 25.56
 3.18
Non-U.S. credit card
 
 
 243
 2.12
 2.64
Direct/Indirect consumer262
 2.52
 0.28
 244
 2.13
 0.26
Other consumer33
 0.32
 1.22
 51
 0.44
 2.01
Total consumer5,383
 51.79
 1.18
 6,222
 54.21
 1.36
U.S. commercial (2)
3,113
 29.95
 1.04
 3,326
 28.97
 1.17
Non-U.S. commercial803
 7.73
 0.82
 874
 7.61
 0.98
Commercial real estate935
 9.00
 1.60
 920
 8.01
 1.60
Commercial lease financing159
 1.53
 0.72
 138
 1.20
 0.62
Total commercial5,010
 48.21
 1.05
 5,258
 45.79
 1.16
Total allowance for loan and lease losses (3)
10,393
 100.00% 1.12
 11,480
 100.00% 1.26
Less: Allowance included in assets of business held for sale (4)

     (243)    
Allowance for loan and lease losses10,393
     11,237
    
Reserve for unfunded lending commitments777
     762
    
Allowance for credit losses$11,170
     $11,999
    
(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 included residential mortgage loans of $567 million and $710 million and home equity loans of $361 million and $341 million at December 31, 2017 and 2016. Commercial loans accounted for under the fair value option included U.S. commercial loans of $2.6 billion and $2.9 billion and non-U.S. commercial loans of $2.2 billion and $3.1 billion at December 31, 2017 and 2016.
(2)
Includes allowance for loan and lease losses for U.S. small business commercial loans of $439 million and $416 million at December 31, 2017 and 2016.
(3)
Includes $289 million and $419 million of valuation allowance presented with the allowance for loan and lease losses related to PCI loans at December 31, 2017 and 2016.
(4)
Represents allowance for loan and lease losses related to the non-U.S. credit card loan portfolio, which was included in assets of business held for sale on the Consolidated Balance Sheet at December 31, 2016. In 2017, the Corporation sold its non-U.S. consumer credit card business.


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 81.82.
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 25.
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.
QuantitativeModel risk is the potential for adverse consequences from decisions based on incorrect or misused model outputs and reports. Given that models such as VaR, are an essential component in evaluatingused across the Corporation, model risk impacts all risk types including credit, market risks within a portfolio.and operational risks. The Enterprise Model Risk Committee (EMRC), a subcommittee of the MRC, is responsible for providing management oversight and approval of model risk management and governance. The EMRCPolicy defines model risk standards, consistent with our risk framework and risk appetite, prevailing regulatory guidance and industry best practice. ModelsAll models, including risk management, valuation and regulatory capital models, must meet certain validation criteria, including effective challenge of the conceptual soundness of the model, development processindependent model testing and ongoing monitoring through outcomes analysis and benchmarking. The Enterprise Model Risk Committee (EMRC), a sufficient demonstrationsubcommittee of developmental evidence incorporating a comparison of alternative theories and approaches. The EMRCthe MRC, oversees that model standards are consistent with model risk requirements and monitors the effective challenge in the model validation process across the Corporation. In addition, the relevant stakeholders must agree on any required actions or restrictions to the models and maintain a stringent monitoring process for continued compliance.
Interest Rate Risk
Interest rate risk represents exposures to instruments whose values vary with the level or volatility of interest rates. These instruments include, but are not limited to, loans, debt securities, certain trading-related assets and liabilities, deposits, borrowings and derivatives. Hedging instruments used to mitigate these risks include derivatives such as options, futures, forwards and swaps.

Bank of America 201776


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. First,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. Second,In addition, we originate a variety of MBS, which involves the accumulation of mortgage-related loans in anticipation of eventual securitization. Third,securitization, and we may hold positions in mortgage securities and residential mortgage loans as part of the ALM portfolio. Fourth, we createWe also record MSRs as part of our mortgage origination activities. For more information on MSRs, see Note 1 – Summary of Significant Accounting Principles and Note 20 – Fair Value Measurements to the Consolidated Financial Statements. 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 83.84.
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
Bank of America 78


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 further exacerbated if expected hedging or pricing correlations are compromised by disproportionate demand or lack of demand for certain instruments. We utilize various risk mitigating techniques as discussed in more detail in Trading Risk Management.
Trading Risk Management
To evaluate riskrisks in our trading activities, we focus on the actual and potential volatility of revenues generated by individual positions as well as portfolios of positions. Various techniques and procedures are utilized to enable the most complete understanding of these risks. Quantitative measures of market risk are evaluated on a daily basis from a single position to the portfolio of the Corporation. These measures include sensitivities of positions to various market risk factors, such as the potential impact on revenue from a one basis point change in interest rates, and statistical measures utilizing both actual and hypothetical market moves, such as VaR and stress testing. Periods of extreme market stress influence the reliability of these techniques to varying degrees. Qualitative evaluations of market risk utilize the suite of quantitative risk measures while understanding each of their respective limitations. Additionally, risk managers independently evaluate the risk of the portfolios under the current market environment and potential future environments.
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. Thislevel, which means that for a VaR with a one-day holding period, there should not be losses in excess of VaR, on average, 99 out of 100 trading days.
Within any VaR model, there are significant and numerous assumptions that will differ from company to company. The accuracy of a VaR model depends on the availability and quality of historical data for each of the risk factors in the portfolio. A VaR model may require additional modeling assumptions for new products that do not have the necessary historical market data or for less liquid positions for which accurate daily prices
are not consistently available. For positions with insufficient historical data for the VaR calculation, the process for establishing an appropriate proxy is based on fundamental and statistical analysis of the new product or less liquid position. This analysis identifies reasonable alternatives that replicate both the expected volatility and correlation to other market risk factors that the missing data would be expected to experience.


77Bank of America 2017



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.ICAAP. For more information regarding ICAAP,, see Capital Management on page 45.50.
Global Risk Management continually reviews, evaluates and enhances our VaR model so that it reflects the material risks in our trading portfolio. Changes to the VaR model are reviewed and approved prior to implementation and any material changes are reported to management through the appropriate management committees.
Trading limits on quantitative risk measures, including VaR, are independently set by Global Markets Risk Management and reviewed on a regular basis so that trading limits remain relevant and within our overall risk appetite for market risks. Trading limits are reviewed in the context of market liquidity, volatility and strategic business priorities. Trading limits are set at both a granular level to allow for extensive coverage of risks as well as at aggregated portfolios to account for correlations among risk factors. All trading limits are approved at least annually. Approved trading limits are stored and tracked in a centralized limits management system. Trading limit excesses are communicated to management for review. Certain quantitative market risk measures and corresponding limits have been identified as critical in the Corporation’s Risk Appetite Statement. These risk appetite limits are reported on a daily basis and are approved at least annually by the ERC and the Board.
In periods of market stress, Global Markets senior leadership communicates daily to discuss losses, key risk positions and any limit excesses. As a result of this process, the businesses may selectively reduce risk.
Table 4944 presents the total market-based trading portfolio VaR which is the combination of the total covered positions (and less liquid trading positions) portfolio and the impact from less liquid trading exposures.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 4944 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. The fair value option portfolio combined with the total market-based trading portfolio VaR represents our total market-based portfolio VaR. Additionally, market risk VaR for
79 Bank of America


trading activities as presented in Table 4944 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 4944 include market risk to which we are exposed from all business segments, excluding CVAcredit valuation adjustment (CVA), DVA and DVA.
related hedges. The majority of this portfolio is within the Global Markets segment.
Table 4944 presents year-end, average, high and low daily trading VaR for 20172020 and 20162019 using a 99 percent confidence
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.
Table 44Market Risk VaR for Trading Activities
20202019
(Dollars in millions)Year
End
Average
High (1)
Low (1)
Year
End
Average
High (1)
Low (1)
Foreign exchange$8 $7 $25 $2 $$$13 $
Interest rate30 19 39 7 25 24 49 14 
Credit79 58 91 25 26 23 32 16 
Equity20 24 162 12 29 22 33 14 
Commodities4 6 12 3 31 
Portfolio diversification(72)(61)  (47)(49)— — 
Total covered positions portfolio69 53 171 27 41 32 47 24 
Impact from less liquid exposures52 27   — — — 
Total covered positions and less liquid trading positions portfolio121 80 169 30 41 35 53 27 
Fair value option loans52 52 84 7 10 13 
Fair value option hedges11 13 17 9 10 10 17 
Fair value option portfolio diversification(17)(24)  (9)(10)— — 
Total fair value option portfolio46 41 86 9 10 16 
Portfolio diversification(4)(15)  (5)(7)— — 
Total market-based portfolio$163 $106 171 32 $45 $38 56 28 
                 
Table 49Market Risk VaR for Trading Activities       
                 
 2017 2016
(Dollars in millions)Year End Average 
High (1)
 
Low (1)
 Year End Average 
High (1)
 
Low (1)
Foreign exchange$7
 $11
 $25
 $3
 $8
 $9
 $16
 $5
Interest rate22
 21
 41
 11
 11
 19
 30
 10
Credit29
 26
 33
 21
 25
 30
 37
 25
Equity19
 18
 33
 12
 19
 18
 30
 11
Commodity5
 5
 9
 3
 4
 6
 12
 3
Portfolio diversification(49) (47) 
 
 (39) (46) 
 
Total covered positions trading portfolio33
 34
 53
 23
 28
 36
 50
 24
Impact from less liquid exposures5
 6
 
 
 6
 5
 
 
Total market-based trading portfolio38
 40
 63
 26
 34
 41
 58
 28
Fair value option loans9
 10
 14
 7
 14
 23
 40
 12
Fair value option hedges7
 7
 11
 4
 6
 11
 22
 5
Fair value option portfolio diversification(7) (8) 
 
 (10) (21) 
 
Total fair value option portfolio9
 9
 11
 6
 10
 13
 20
 8
Portfolio diversification(4) (4) 
 
 (4) (6) 
 
Total market-based portfolio$43
 $45
 69
 29
 $40
 $48
 70
 32
(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.

Bank of America 201778


(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 total market-basedcovered positions and less liquid trading positions portfolio VaR for 2017,2020, corresponding to the data in Table 49.44. Peak VaR in mid-March 2020 was driven by increased market realized volatility and higher implied volatilities.
bac-20201231_g3.jpg
Additional VaR statistics produced within our single VaR model are provided in Table 5045 at the same level of detail as in Table 49.44. 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 50 45
presents average trading VaR statistics at 99 percent and 95 percent confidence levels for 20172020 and 2016.2019. 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.
          
Table 50Average Market Risk VaR for Trading Activities – 99 percent and 95 percent VaR Statistics
          
   2017 2016
(Dollars in millions) 99 percent 95 percent 99 percent 95 percent
Foreign exchange $11
 $6
 $9
 $5
Interest rate 21
 14
 19
 12
Credit 26
 15
 30
 18
Equity 18
 10
 18
 11
Commodity 5
 3
 6
 3
Portfolio diversification (47) (30) (46) (30)
Total covered positions trading portfolio 34
 18
 36
 19
Impact from less liquid exposures 6
 2
 5
 3
Total market-based trading portfolio 40
 20
 41
 22
Fair value option loans 10
 6
 23
 13
Fair value option hedges 7
 5
 11
 8
Fair value option portfolio diversification (8) (6) (21) (13)
Total fair value option portfolio 9
 5
 13
 8
Portfolio diversification (4) (3) (6) (4)
Total market-based portfolio $45
 $22
 $48
 $26
Bank of America 80


Table 45Average Market Risk VaR for Trading Activities – 99 percent and 95 percent VaR Statistics
20202019
(Dollars in millions)99 percent95 percent99 percent95 percent
Foreign exchange$7 $4 $$
Interest rate19 9 24 15 
Credit58 18 23 15 
Equity24 13 22 11 
Commodities6 3 
Portfolio diversification(61)(26)(49)(29)
Total covered positions portfolio53 21 32 18 
Impact from less liquid exposures27 2 
Total covered positions and less liquid trading positions portfolio80 23 35 20 
Fair value option loans52 13 10 
Fair value option hedges13 7 10 
Fair value option portfolio diversification(24)(8)(10)(5)
Total fair value option portfolio41 12 10 
Portfolio diversification(15)(6)(7)(5)
Total market-based portfolio$106 $29 $38 $21 
Backtesting
The accuracy of the VaR methodology is evaluated by backtesting, which compares the daily VaR results, utilizing a one-day holding period, against a comparable subset of trading revenue. A backtesting excess occurs when a trading loss exceeds the VaR for the corresponding day. These excesses are evaluated to understand the positions and market moves that produced the trading loss andwith a goal to assess whetherensure 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 intradayintra-day trading revenues.
We conduct daily backtesting on our portfolios, ranging from the total market-based portfolio to individual trading areas. Additionally, we conduct daily backtesting on the VaR results used for regulatory capital calculations as well as the VaR results for key legal entities, regions and risk factors. These results are reported to senior market risk management. Senior management regularly reviews and evaluates the results of these tests.
During 2017,2020, there were noseven days in which there was a backtesting excess forwhere this subset of trading revenue had losses that exceeded our total market-basedcovered portfolio VaR, utilizing a one-day holding period.


79Bank of America 2017



Total Trading-related Revenue
Total trading-related revenue, excluding brokerage fees, and CVA, DVA and funding valuation adjustment gains (losses), represents the total amount earned from trading positions, including market-based net interest income, which are taken in a diverse range of financial instruments and markets. Trading account assets and liabilities are reported at fair value. For more information on fair value, see Note 20 – Fair Value Measurements to the Consolidated Financial Statements.
Trading-related revenue can be volatile and is largely driven by general market conditions and customer demand. Also, trading-related revenue is dependent on the volume and type of transactions, the level of risk assumed, and the volatility of price and rate movements at any given time within the
ever-changing market environment. Significant daily revenue by business is monitored and the primary drivers of these are reviewed.
The following histogram is a graphic depiction of trading volatility and illustrates the daily level of trading-related revenue for 20172020 and 2016.2019. During 2017,2020, positive trading-related revenue was recorded for 10098 percent of the trading days, of which 77 percent were daily trading gains of over $25 million. This compares to 2016 where positive trading-related revenue was recorded for 99 percent of the trading days, of which 8487 percent were daily trading gains of over $25 million, and the largest loss was $24$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.
bac-20201231_g4.jpg
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
81 Bank of America


severe point during a crisis is selected for each historical scenario. Hypothetical scenarios provide estimated portfolio impacts from potential
future market stress events. Scenarios are reviewed and updated in response to changing positions and new economic or political information. In addition, new or ad hoc scenarios are developed to address specific potential market events or particular vulnerabilities in the portfolio. The stress tests are reviewed on a regular basis and the results are presented to senior management.
Stress testing for the trading portfolio is integrated with enterprise-wide stress testing and incorporated into the limits framework. The macroeconomic scenarios used for enterprise-wide stress testing purposes differ from the typical trading portfolio scenarios in that they have a longer time horizon and the results are forecasted over multiple periods for use in consolidated capital and liquidity planning. For more information, see Managing Risk on page 41.
47.


Bank of America 201780


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-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 5146 presents the spot and 12-month forward rates used in our baseline forecasts at December 31, 20172020 and 2016.2019.
      
Table 51Forward Rates
Table 46Table 46Forward Rates
      
 December 31, 2017December 31, 2020
 
Federal
Funds
 
Three-month
LIBOR
 
10-Year
Swap
 Federal
Funds
Three-month
LIBOR
10-Year
Swap
Spot ratesSpot rates1.50% 1.69% 2.40%Spot rates0.25 %0.24 %0.93 %
12-month forward rates12-month forward rates2.00
 2.14
 2.48
12-month forward rates0.25 0.19 1.06 
      
 December 31, 2016December 31, 2019
Spot ratesSpot rates0.75% 1.00% 2.34%Spot rates1.75 %1.91 %1.90 %
12-month forward rates12-month forward rates1.25
 1.51
 2.49
12-month forward rates1.50 1.62 1.92 
Table 5247 shows the pre-tax dollarpretax impact to forecasted net interest income over the next 12 months from December 31, 20172020 and 2016,2019 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 2017,2020, the asset sensitivity of our balance sheet increased in both up-rate and down-rate scenarios primarily due to rising rates was largely unchanged.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 benefitimpact coming from the short end of the yield curve. Additionally, higher interest rates impact the fair value of debt securities and, accordingly, for debt securities classified as available for sale (AFS),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 45.
51.
Table 47Table 47Estimated Banking Book Net Interest Income Sensitivity to Curve Changes
Short
Rate (bps)
Long
Rate (bps)
        December 31
Table 52Estimated Banking Book Net Interest Income Sensitivity
(Dollars in millions)(Dollars in millions)Short
Rate (bps)
Long
Rate (bps)
20202019
        
(Dollars in millions)
Short
Rate (bps)
 
Long
Rate (bps)
 December 31
Curve Change  2017 2016
Parallel ShiftsParallel Shifts       Parallel Shifts
+100 bps
instantaneous shift
+100 bps
instantaneous shift
+100 +100 $3,317
 $3,370
+100 bps
instantaneous shift
+100+100$10,468 $4,190 
-50 bps
instantaneous shift
-50
 -50
 (2,273) (2,900)
-25 bps
instantaneous shift
-25 bps
instantaneous shift
-25 -25 (2,766)(1,500)
FlattenersFlatteners 
  
    
Flatteners  
Short-end
instantaneous change
Short-end
instantaneous change
+100 
 2,182
 2,473
Short-end
instantaneous change
+100— 6,321 2,641 
Long-end
instantaneous change
Long-end
instantaneous change

 -50
 (1,246) (961)
Long-end
instantaneous change
— -25 (1,686)(653)
SteepenersSteepeners 
  
    Steepeners  
Short-end
instantaneous change
Short-end
instantaneous change
-50
 
 (1,021) (1,918)
Short-end
instantaneous change
-25 — (1,084)(844)
Long-end
instantaneous change
Long-end
instantaneous change

 +100 1,135
 928
Long-end
instantaneous change
— +1004,333 1,561 
The sensitivity analysis in Table 5247 assumes that we take no action in response to these rate shocks and does not assume any change in other macroeconomic variables normally correlated with changes in interest rates. As part of our ALM activities, we use securities, certain residential mortgages, and interest rate and foreign exchange derivatives in managing interest rate sensitivity.
The behavior of our depositdeposits 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 5247 assumes no change in deposit portfolio size or mix from the baseline forecast in alternate rate environments. In higher rate scenarios, any customer activity resulting in the replacement of low-cost or noninterest-bearingnon-interest-bearing deposits with higher-yieldinghigher 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
Bank of America 82


activities, see Note 23 – Derivativesto the Consolidated Financial Statements.Statements.
Our interest rate contracts are generally non-leveraged generic interest rate and foreign exchange basis swaps, options, futures and forwards. In addition, we use foreign exchange contracts, including cross-currency interest rate swaps, foreign currency futures contracts, foreign currency forward contracts and options to mitigate the foreign exchange risk associated with foreign currency-denominated assets and liabilities.
Changes to the composition of our derivatives portfolio during 20172020 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.


81Bank of America 2017



Table 53 presents derivatives utilized in our ALM activities including those designated as accounting and economic hedging instruments 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, 2017 and 2016. These amounts do not include derivative hedges on our MSRs.
                   
Table 53Asset and Liability Management Interest Rate and Foreign Exchange Contracts
       
    December 31, 2017  
    Expected Maturity  
(Dollars in millions, average estimated duration in years)
Fair
Value
 Total 2018 2019 2020 2021 2022 Thereafter 
Average
Estimated
Duration
Receive-fixed interest rate swaps (1)
$2,330
  
  
  
  
  
  
  
 5.38
Notional amount 
 $176,390
 $21,850
 $27,176
 $16,347
 $6,498
 $19,120
 $85,399
  
Weighted-average fixed-rate 
 2.42% 3.20% 1.87% 1.88% 2.99% 2.10% 2.52%  
Pay-fixed interest rate swaps (1)
(37)  
  
  
  
  
  
  
 5.63
Notional amount 
 $45,873
 $11,555
 $1,210
 $4,344
 $1,616
 $
 $27,148
  
Weighted-average fixed-rate 
 2.15% 1.73% 2.07% 2.16% 2.22% % 2.32%  
Same-currency basis swaps (2)
(17)  
  
  
  
  
  
  
  
Notional amount 
 $38,622
 $11,028
 $6,789
 $1,180
 $2,807
 $955
 $15,863
  
Foreign exchange basis swaps (1, 3, 4)
(1,616)  
  
  
  
  
  
  
  
Notional amount 
 107,263
 24,886
 11,922
 13,367
 9,301
 6,860
 40,927
  
Option products (5)
13
  
  
  
  
  
  
  
  
Notional amount (6)
 
 1,218
 1,201
 
 
 
 
 17
  
Foreign exchange contracts (1, 4, 7)
1,424
  
  
  
  
  
  
  
  
Notional amount (6)
  (11,783) (28,689) 2,231
 (24) 2,471
 2,919
 9,309
  
Net ALM contracts$2,097
  
  
  
  
  
  
  
  
       
    December 31, 2016  
    Expected Maturity  
(Dollars in millions, average estimated duration in years)
Fair
Value
 Total 2017 2018 2019 2020 2021 Thereafter 
Average
Estimated
Duration
Receive-fixed interest rate swaps (1)
$4,055
  
  
  
  
  
  
  
 4.81
Notional amount 
 $118,603
 $21,453
 $25,788
 $10,283
 $7,515
 $5,307
 $48,257
  
Weighted-average fixed-rate 
 2.83% 3.64% 2.81% 2.31% 2.07% 3.18% 2.67%  
Pay-fixed interest rate swaps (1)
159
  
  
  
  
  
  
  
 2.77
Notional amount 
 $22,400
 $1,527
 $9,168
 $2,072
 $7,975
 $213
 $1,445
  
Weighted-average fixed-rate 
 1.37% 1.84% 1.47% 0.97% 1.08% 1.00% 2.45%  
Same-currency basis swaps (2)
(26)  
  
  
  
  
  
  
  
Notional amount 
 $59,274
 $20,775
 $11,027
 $6,784
 $1,180
 $2,799
 $16,709
  
Foreign exchange basis swaps (1, 3, 4)
(4,233)  
  
  
  
  
  
  
  
Notional amount 
 125,522
 26,509
 22,724
 12,178
 12,150
 8,365
 43,596
  
Option products (5)
5
  
  
  
  
  
  
  
  
Notional amount (6)
 
 1,687
 1,673
 
 
 
 
 14
  
Foreign exchange contracts (1, 4, 7)
3,180
  
  
  
  
  
  
  
  
Notional amount (6)
 
 (20,285) (30,199) 197
 1,961
 (8) 881
 6,883
  
Futures and forward rate contracts19
  
  
  
  
  
  
  
  
Notional amount (6)
 
 37,896
 37,896
 
 
 
 
 
  
Net ALM contracts$3,159
  
  
  
  
  
  
  
  
(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, 2017 and 2016, the notional amount of same-currency basis swaps included $38.6 billion and $59.3 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 option products of $1.2 billion and $1.7 billion at December 31, 2017 and 2016 was substantially all in foreign exchange options.
(6)
Reflects the net of long and short positions. Amounts shown as negative reflect a net short position.
(7)
The notional amount of foreign exchange contracts of $(11.8) billion at December 31, 2017 was comprised of $29.1 billion in foreign currency-denominated and cross-currency receive-fixed swaps, $(35.6) billion in net foreign currency forward rate contracts, $(6.2) billion in foreign currency-denominated pay-fixed swaps and $940 million in net foreign currency futures contracts. Foreign exchange contracts of $(20.3) billion at December 31, 2016 were comprised of $21.5 billion in foreign currency-denominated and cross-currency receive-fixed swaps, $(38.5) billion in net foreign currency forward rate contracts, $(4.6) billion in foreign currency-denominated pay-fixed swaps and $1.3 billion in foreign currency futures contracts.

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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 lossesresults on both open and terminated cash flow hedge derivative instruments recorded in accumulated OCI were $1.3 billiona gain of $580 million and $1.4 billion,a loss of $496 million, on a pre-taxpretax basis, at December 31, 20172020 and 2016.2019. These netgains 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, 2017,2020, the pre-taxafter-tax net lossesgains are expected to be reclassified into earnings as follows: $208a gain of $187 million or 16 percent, within the next year, 56 percenta gain of $358 million in years two through five, and 18 percenta loss of $59 million in years six through 10,ten, with the remaining 10 percentloss of $50 million thereafter. For more information on derivatives designated as cash flow hedges, see Note 23 – Derivativesto the Consolidated Financial Statements.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, 2017.2020.
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 48Asset and Liability Management Interest Rate and Foreign Exchange Contracts
December 31, 2020
Expected Maturity
(Dollars in millions, average estimated duration in years)Fair
Value
Total20212022202320242025ThereafterAverage
Estimated
Duration
Receive-fixed interest rate swaps (1)
$14,885        8.08 
Notional amount��$269,015 $11,050 $20,908 $30,654 $31,317 $32,898 $142,188 
Weighted-average fixed-rate1.54 %3.25 %0.91 %1.48 %1.17 %1.07 %1.69 %
Pay-fixed interest rate swaps (1)
(5,502)       6.52 
Notional amount $252,698 $7,562 $21,667 $24,671 $24,406 $32,052 $142,340  
Weighted-average fixed-rate0.89 %0.57 %0.10 %1.28 %0.86 %0.68 %1.00 %
Same-currency basis swaps (2)
(235)        
Notional amount $223,659 $18,769 $12,245 $9,747 $22,737 $28,222 $131,939  
Foreign exchange basis swaps (1, 3, 4)
(1,014)  
Notional amount 112,465 27,424 16,038 8,066 3,819 4,446 52,672  
Foreign exchange contracts (1, 4, 5)
349  
Notional amount (6)
(42,490)(69,299)2,841 2,505 4,735 4,369 12,359 
Futures and forward rate contracts47 
Notional amount14,255 14,255      
Option products   
Notional amount 17   17     
Net ALM contracts$8,530         
83 Bank of America


Table 48Asset and Liability Management Interest Rate and Foreign Exchange Contracts (continued)
  December 31, 2019
  Expected Maturity
(Dollars in millions, average estimated duration in years)Fair
Value
Total20202021202220232024ThereafterAverage
Estimated
Duration
Receive-fixed interest rate swaps (1)
$12,370        6.47 
Notional amount $215,123 $16,347 $14,642 $21,616 $36,356 $21,257 $104,905 
Weighted-average fixed-rate2.68 %2.68 %3.17 %2.48 %2.36 %2.55 %2.79 %
Pay-fixed interest rate swaps (1)
(2,669)       6.99 
Notional amount $69,586 $4,344 $2,117 $— $13,993 $8,194 $40,938  
Weighted-average fixed-rate2.36 %2.16 %2.15 %— %2.52 %2.26 %2.35 %
Same-currency basis swaps (2)
(290)        
Notional amount $152,160 $18,857 $18,590 $4,306 $2,017 $14,567 $93,823  
Foreign exchange basis swaps (1, 3, 4)
(1,258)  
Notional amount 113,529 23,639 24,215 14,611 7,111 3,521 40,432  
Foreign exchange contracts (1, 4, 5)
414  
Notional amount (6)
(53,106)(79,315)4,539 2,674 2,340 4,432 12,224 
Option products—   
Notional amount 15 — — — 15 — —  
Net ALM contracts$8,567         
(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 ManagementAllowance for Credit Losses
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 atOn January 1, 2020, the time of commitment and manage credit and liquidity risks by selling or securitizing a portionCorporation adopted the new accounting standard that requires the measurement of the loans we originate.
Interest rate risk and market risk canallowance for credit losses to be substantialbased on management’s best estimate of lifetime ECL inherent 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 IRLCs and the related residential first mortgage LHFS between the dateCorporation’s relevant financial assets. Upon adoption of the IRLC andnew accounting standard, the date the loans are sold to the secondary market. AnCorporation recorded a net increase in mortgage interest rates typically leads to a decreaseof $3.3 billion in the valueallowance for credit losses which was comprised of these instruments. Conversely,a net increase of $2.9 billion in the valueallowance for loan and lease losses and an increase of $310 million in the MSRs willreserve for unfunded lending commitments. The net increase was primarily driven by lower prepayment expectations when there is ana $3.1 billion increase in interest rates. Because the interest rate risks of these two hedged items offset, we combine them into one overall hedged item with one combined economic hedge portfolio consisting of derivative contracts and securities.
During 2017 and 2016, we recorded gains in mortgage banking income of $118 million and $366 million related to the changecredit 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, 2020and December 31, 2019 (prior to the adoption of the CECL accounting standard).
Table 42Allocation of the Allowance for Credit Losses by Product Type
AmountPercent of
Total
Percent of
Loans and
Leases
Outstanding (1)
AmountPercent of
Total
Percent of
Loans and
Leases
Outstanding
(1)
AmountPercent of
Total
Percent of
Loans and
Leases
Outstanding (1)
(Dollars in millions)December 31, 2020January 1, 2020December 31, 2019
Allowance for loan and lease losses      
Residential mortgage$459 2.44 %0.21 %$212 1.72 %0.09 %$325 3.45 %0.14 %
Home equity399 2.12 1.16 228 1.84 0.57 221 2.35 0.55 
Credit card8,420 44.79 10.70 6,809 55.10 6.98 3,710 39.39 3.80 
Direct/Indirect consumer752 4.00 0.82 566 4.58 0.62 234 2.49 0.26 
Other consumer41 0.22 n/m55 0.45 n/m52 0.55 n/m
Total consumer10,071 53.57 2.35 7,870 63.69 1.69 4,542 48.23 0.98 
U.S. commercial (2)
5,043 26.82 1.55 2,723 22.03 0.84 3,015 32.02 0.94 
Non-U.S. commercial1,241 6.60 1.37 668 5.41 0.64 658 6.99 0.63 
Commercial real estate2,285 12.15 3.79 1,036 8.38 1.65 1,042 11.07 1.66 
Commercial lease financing162 0.86 0.95 61 0.49 0.31 159 1.69 0.80 
Total commercial8,731 46.43 1.77 4,488 36.31 0.88 4,874 51.77 0.96 
Allowance for loan and lease losses18,802 100.00 %2.04 12,358 100.00 %1.27 9,416 100.00 %0.97 
Reserve for unfunded lending commitments1,878 1,123 813  
Allowance for credit losses$20,680 $13,481 $10,229 
(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.
(2)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
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 MSRs, IRLCsnew accounting standard, primarily due to the deterioration in the economic outlook resulting from the impact of COVID-19 on both the consumer and LHFS, netcommercial 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 gainsthe 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 the hedge portfolio.management’s estimate of probable incurred losses. For more information on MSRs, see Note 20 – Fair Value Measurementsto the Consolidated Financial Statements and for more information on mortgage banking income, see Consumer Banking on page 31.
Compliance 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 related self-regulatory organizations’ standards and codes of conduct (collectively, applicable laws, rules and regulations). Global Compliance independently assesses compliance risk, and evaluates FLUs and control functions for adherence to applicable
laws, rules and regulations, including identifying compliance issues and risks, performing monitoring and developing tests to be conducted by the Enterprise Independent Testing unit, and reporting on the state of compliance activities across the Corporation. Enterprise Independent Testing, an independent testing function within IRM, works with Global Compliance, 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. Additionally, Global Compliance works with FLUs and control functions so that day-to-day activities operate in a compliant manner. 
The Corporation’s approach to the management of compliance risk is described in the Global Compliance - Enterprise Policy, which outlines the requirements of the Corporation’s global compliance program, and defines roles and responsibilities of FLUs, IRM and Corporate Audit, the three lines of defense in managing compliance risk. The requirements work together to drive a comprehensive risk-based approach for the proactive identification, management and escalation of compliance risks throughout the Corporation. For more information on FLUs and control functions, see Managing Risk on page 41.
The Global Compliance - Enterprise Policy also sets the requirements for reporting compliance risk information to executive management as well as the Board or appropriate Board-level committees in support of Global Compliance’s responsibility for conducting independent oversight of the Corporation’s compliance risk management activities. The Board provides oversight of compliance risk through its Audit Committee and the ERC.
Operational Risk Management
Operational risk is the risk ofcredit loss resulting from inadequate or failed internal processes, people and systems or from external events. Operational risk may occur anywhere in the Corporation, including third-party business processes, and is not limited to operations functions. Effects may extend beyond financial losses and may result in reputational risk impacts. Operational risk includes legal risk. Additionally, operational risk is a component in the calculation of total risk-weighted assets used in the Basel 3 capital calculation. For more information on Basel 3 calculations, see Capital Management on page 45.
The Corporation’s approach to Operational Risk Management is outlined in the Operational Risk - Enterprise Policy, and supporting standards which establish the requirements and accountabilities for managing operational risk through a comprehensive set of integrated practices implemented by the Corporation so that our business processes are designed and executed effectively. The Operational Risk - Enterprise Policy is the basis for the operational risk management program.
The operational risk management program describes the processes for identifying, measuring, monitoring, controlling and reporting operational risk information to executive management, as well as the Board or Appropriate Board-Level committees. Under the operational risk management program, FLUs and control functions are responsible for identifying, escalating and debating risk associated with their business activities. The operational risk management teams independently monitor and assess processes and controls, and develop tests to be conducted by the Enterprise Independent Testing unit to validate that processes are operating as intended. The requirements work together to drive a comprehensive risk-based approach for the proactive identification, management and escalation of operational risks throughout the Corporation.


83Bank of America 2017



The MRC oversees the Corporation’saccounting policies and processes for operational risk management and serves as an escalation point for critical operational risk matters with the Corporation. The MRC reports operational risk activities to the ERC of the Board.
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 thoseactivity related to the management of our strategic, operational, compliance andallowance for credit risks.
The Corporation manages reputational risk 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. The Corporation has processes and procedures in place to respond to events that give rise to reputational risk, including educating individuals and organizations that influence public opinion, implementing external communication strategies to mitigate the risk, and informing key stakeholders of potential reputational risks.
The Corporation’s organization and governance structure provides oversight of reputational risks, and reputational risk reporting is provided regularly and directly to management and the ERC, which provides primary oversight of reputational risk. In addition, each FLU has a committee, which includes representatives from Compliance, Legal and Risk, that is responsible for the oversight of reputational risk. Such committees’ oversight includes providing approval for business activities that present elevated levels of reputational risks.
Complex Accounting Estimates
Our significant accounting principles, as described in losses, see Note 1 – Summary of Significant Accounting Principlesand Note 5 – Outstanding Loans and Leases and Allowance for Credit Losses to the Consolidated Financial Statements,Statements.
Bank of America 76


Table 43Allowance for Credit Losses
(Dollars in millions)20202019
Allowance for loan and lease losses, January 1$12,358 $9,601 
Loans and leases charged off
Residential mortgage(40)(93)
Home equity(58)(429)
Credit card(2,967)(3,535)
Direct/Indirect consumer(372)(518)
Other consumer(307)(249)
Total consumer charge-offs(3,744)(4,824)
U.S. commercial (1)
(1,163)(650)
Non-U.S. commercial(168)(115)
Commercial real estate(275)(31)
Commercial lease financing(69)(26)
Total commercial charge-offs(1,675)(822)
Total loans and leases charged off(5,419)(5,646)
Recoveries of loans and leases previously charged off
Residential mortgage70 140 
Home equity131 787 
Credit card618 587 
Direct/Indirect consumer250 309 
Other consumer23 15 
Total consumer recoveries1,092 1,838 
U.S. commercial (2)
178 122 
Non-U.S. commercial13 31 
Commercial real estate5 
Commercial lease financing10 
Total commercial recoveries206 160 
Total recoveries of loans and leases previously charged off1,298 1,998 
Net charge-offs(4,121)(3,648)
Provision for loan and lease losses10,565 3,574 
Other (111)
Allowance for loan and lease losses, December 3118,802 9,416 
Reserve for unfunded lending commitments, January 11,123 797 
Provision for unfunded lending commitments755 16 
Reserve for unfunded lending commitments, December 311,878 813 
Allowance for credit losses, December 31$20,680 $10,229 
Loan and allowance ratios:
Loans and leases outstanding at December 31 (3)
$921,180 $975,091 
Allowance for loan and lease losses as a percentage of total loans and leases outstanding at December 31 (3)
2.04 %0.97 %
Consumer allowance for loan and lease losses as a percentage of total consumer loans and leases outstanding at December 31 (4)
2.35 0.98 
Commercial allowance for loan and lease losses as a percentage of total commercial loans and leases outstanding at December 31 (5)
1.77 0.96 
Average loans and leases outstanding (3)
$974,281 $951,583 
Annualized net charge-offs as a percentage of average loans and leases outstanding (3)
0.42 %0.38 %
Allowance for loan and lease losses as a percentage of total nonperforming loans and leases at December 31380 265 
Ratio of the allowance for loan and lease losses at December 31 to net charge-offs4.56 2.58 
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)
$9,854 $4,151 
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)
181 %148 %
(1)Includes U.S. small business commercial charge-offs of $321 million in 2020 compared to $320 million in 2019.
(2)Includes U.S. small business commercial recoveries of $54 million in 2020 compared to $48 million in 2019.
(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.
77 Bank of America


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 essentialalso exposed to these risks in understandingother areas of the MD&A. ManyCorporation (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 82.
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 25.
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 significant accounting principles require complex judgmentsnon-trading positions arising from changes in interest rates is managed through our ALM activities. We have elected to estimateaccount 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.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 requirements and monitors the effective challenge in the model validation process across the Corporation.
Interest Rate Risk
Interest rate risk represents exposures to instruments whose values vary with the level or volatility of interest rates. These instruments include, but are not limited to, loans, debt securities, certain trading-related assets and liabilities, deposits, borrowings and derivatives. Hedging instruments used to mitigate these risks include derivatives such as options, futures, forwards and swaps.
Foreign Exchange Risk
Foreign exchange risk represents exposures to changes in the values of current holdings and future cash flows denominated in currencies other than the U.S. dollar. The types of instruments exposed to this risk include investments in non-U.S. subsidiaries, foreign currency-denominated loans and securities, future cash flows in foreign currencies arising from foreign exchange transactions, foreign currency-denominated debt and various foreign exchange derivatives whose values fluctuate with changes in the level or volatility of currency exchange rates or non-U.S. interest rates. Hedging instruments used to mitigate this risk include foreign exchange options, currency swaps, futures, forwards, and foreign currency-denominated debt and deposits.
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 84.
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
Bank of America 78


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 further exacerbated if expected hedging or pricing correlations are compromised by disproportionate demand or lack of demand for certain instruments. We utilize various risk mitigating techniques as discussed in more detail in Trading Risk Management.
Trading Risk Management
To evaluate risks in our trading activities, we focus on the actual and potential volatility of revenues generated by individual positions as well as portfolios of positions. Various techniques and procedures are utilized to enable the most complete understanding of these risks. Quantitative measures of market risk are evaluated on a daily basis from a single position to the portfolio of the Corporation. These measures include sensitivities of positions to various market risk factors, such as the potential impact on revenue from a one basis point change in interest rates, and statistical measures utilizing both actual and hypothetical market moves, such as VaR and stress testing. Periods of extreme market stress influence the reliability of these techniques to varying degrees. Qualitative evaluations of market risk utilize the suite of quantitative risk measures while understanding each of their respective limitations. Additionally, risk managers independently evaluate the risk of the portfolios under the current market environment and potential future environments.
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 proceduresthe necessary historical market data or for less liquid positions for which accurate daily prices
are not consistently available. For positions with insufficient historical data for the VaR calculation, the process for establishing an appropriate proxy is based on fundamental and processesstatistical 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 placemarket 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 facilitate making these judgments.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 50.
Global Risk Management continually reviews, evaluates and enhances our VaR model so that it reflects the material risks in our trading portfolio. Changes to the VaR model are reviewed and approved prior to implementation and any material changes are reported to management through the appropriate management committees.
Trading limits on quantitative risk measures, including VaR, are independently set by Global Markets Risk Management and reviewed on a regular basis so that trading limits remain relevant and within our overall risk appetite for market risks. Trading limits are reviewed in the context of market liquidity, volatility and strategic business priorities. Trading limits are set at both a granular level to allow for extensive coverage of risks as well as at aggregated portfolios to account for correlations among risk factors. All trading limits are approved at least annually. Approved trading limits are stored and tracked in a centralized limits management system. Trading limit excesses are communicated to management for review. Certain quantitative market risk measures and corresponding limits have been identified as critical in the Corporation’s Risk Appetite Statement. These risk appetite limits are reported on a daily basis and are approved at least annually by the ERC and the Board.
In periods of market stress, Global Markets senior leadership communicates daily to discuss losses, key risk positions and any limit excesses. As a result of this process, the businesses may selectively reduce risk.
Table 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
79 Bank of America


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 more judgmental estimatestotal market-based portfolio VaR results in Table 44 include market risk to which we are summarizedexposed 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
level. The amounts disclosed in Table 44 and Table 45 align to the following discussion. We have identified and described the developmentview 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 becovered positions used in the processBasel 3 capital calculations. Foreign exchange and commodity positions are always considered covered positions, regardless of determiningtrading or banking treatment for the inputstrade, 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 models. Where alternatives exist,impact of market volatility related to the pandemic in the VaR look back period.
Table 44Market Risk VaR for Trading Activities
20202019
(Dollars in millions)Year
End
Average
High (1)
Low (1)
Year
End
Average
High (1)
Low (1)
Foreign exchange$8 $7 $25 $2 $$$13 $
Interest rate30 19 39 7 25 24 49 14 
Credit79 58 91 25 26 23 32 16 
Equity20 24 162 12 29 22 33 14 
Commodities4 6 12 3 31 
Portfolio diversification(72)(61)  (47)(49)— — 
Total covered positions portfolio69 53 171 27 41 32 47 24 
Impact from less liquid exposures52 27   — — — 
Total covered positions and less liquid trading positions portfolio121 80 169 30 41 35 53 27 
Fair value option loans52 52 84 7 10 13 
Fair value option hedges11 13 17 9 10 10 17 
Fair value option portfolio diversification(17)(24)  (9)(10)— — 
Total fair value option portfolio46 41 86 9 10 16 
Portfolio diversification(4)(15)  (5)(7)— — 
Total market-based portfolio$163 $106 171 32 $45 $38 56 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.
bac-20201231_g3.jpg
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 45Average Market Risk VaR for Trading Activities – 99 percent and 95 percent VaR Statistics
20202019
(Dollars in millions)99 percent95 percent99 percent95 percent
Foreign exchange$7 $4 $$
Interest rate19 9 24 15 
Credit58 18 23 15 
Equity24 13 22 11 
Commodities6 3 
Portfolio diversification(61)(26)(49)(29)
Total covered positions portfolio53 21 32 18 
Impact from less liquid exposures27 2 
Total covered positions and less liquid trading positions portfolio80 23 35 20 
Fair value option loans52 13 10 
Fair value option hedges13 7 10 
Fair value option portfolio diversification(24)(8)(10)(5)
Total fair value option portfolio41 12 10 
Portfolio diversification(15)(6)(7)(5)
Total market-based portfolio$106 $29 $38 $21 
Backtesting
The accuracy of the VaR methodology is evaluated by backtesting, which compares the daily VaR results, utilizing a one-day holding period, against a comparable subset of trading revenue. A backtesting excess occurs when a trading loss exceeds the VaR for the corresponding day. These excesses are evaluated to understand the positions and market moves that produced the trading loss with a goal to ensure that the VaR methodology accurately represents those losses. We expect the frequency of trading losses in excess of VaR to be in line with the confidence level of the VaR statistic being tested. For example, with a 99 percent confidence level, we haveexpect 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 factors that we believe representVaR calculation.
The trading revenue used for backtesting is defined by regulatory agencies in order to most closely align with the most reasonable value in developingVaR component of the inputs. Actual performance thatregulatory capital calculation. This revenue differs from total trading-related revenue in that it excludes revenue from trading activities that either do not generate market risk or the market risk cannot be included in VaR. Some examples of the types of revenue excluded for backtesting are fees, commissions, reserves, net interest income and intra-day trading revenues.
We conduct daily backtesting on the VaR results used for regulatory capital calculations as well as the VaR results for key legal entities, regions and risk factors. These results are reported to senior market risk management. Senior management regularly reviews and evaluates the results of these tests.
During 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.
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.
bac-20201231_g4.jpg
Trading Portfolio Stress Testing
Because the very nature of a VaR model suggests results can exceed our estimates ofand it is dependent on a limited historical window, we also stress test our portfolio using scenario analysis. This analysis estimates the key variables could impact our results of operations. Separate from the possible future impact to our results of operations from input and model variables,change in the value of our lendingtrading 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 market-sensitiveindividual 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
81 Bank of America


severe point during a crisis is selected for each historical scenario. Hypothetical scenarios provide estimated portfolio impacts from potential future market stress events. Scenarios are reviewed and updated in response to changing positions and new economic or political information. In addition, new or ad hoc scenarios are developed to address specific potential market events or particular vulnerabilities in the portfolio. The stress tests are reviewed on a regular basis and the results are presented to senior management.
Stress testing for the trading portfolio is integrated with enterprise-wide stress testing and incorporated into the limits framework. The macroeconomic scenarios used for enterprise-wide stress testing purposes differ from the typical trading portfolio scenarios in that they have a longer time horizon and the results are forecasted over multiple periods for use in consolidated capital and liquidity planning. For more information, see Managing Risk on page 47.
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 46Forward Rates
December 31, 2020
 Federal
Funds
Three-month
LIBOR
10-Year
Swap
Spot rates0.25 %0.24 %0.93 %
12-month forward rates0.25 0.19 1.06 
December 31, 2019
Spot rates1.75 %1.91 %1.90 %
12-month forward rates1.50 1.62 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 51.
Table 47Estimated Banking Book Net Interest Income Sensitivity to Curve Changes
Short
Rate (bps)
Long
Rate (bps)
December 31
(Dollars in millions)20202019
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— 6,321 2,641 
Long-end
instantaneous change
— -25 (1,686)(653)
Steepeners  
Short-end
instantaneous change
-25 — (1,084)(844)
Long-end
instantaneous change
— +1004,333 1,561 
The sensitivity analysis in Table 47 assumes that we take no action in response to these rate shocks and does not assume any change in other macroeconomic variables normally correlated with changes in interest rates. As part of our ALM activities, we use securities, certain residential mortgages, and interest rate and foreign exchange derivatives in managing interest rate sensitivity.
The behavior of our deposits portfolio in the baseline forecast and in alternate interest rate scenarios is a key assumption in our projected estimates of net interest income. The sensitivity analysis in Table 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 exchange contracts, including cross-currency interest rate swaps, foreign currency futures contracts, foreign currency forward contracts and options to mitigate the foreign exchange risk associated with foreign currency-denominated assets and liabilities.
Changes to the composition of our derivatives portfolio during 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 mayand 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 subsequentin 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 balance sheet date, often significantly, dueConsolidated Financial Statements.
We hedge our net investment in non-U.S. operations determined to have functional currencies other than the natureU.S. dollar using forward foreign exchange contracts that typically settle in less than 180 days, cross-currency basis swaps and magnitude of future credit and market conditions. Such credit and market conditions may change quickly andforeign exchange options. We recorded net after-tax losses on derivatives in unforeseen ways and the resulting volatility could have a significant, negative effectaccumulated OCI associated with net investment hedges which were offset by gains on future operating results.
our net investments in consolidated non-U.S. entities at December 31, 2020.
These fluctuations would not be indicative of deficienciesTable 48 presents derivatives utilized in our modelsALM 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 48Asset and Liability Management Interest Rate and Foreign Exchange Contracts
December 31, 2020
Expected Maturity
(Dollars in millions, average estimated duration in years)Fair
Value
Total20212022202320242025ThereafterAverage
Estimated
Duration
Receive-fixed interest rate swaps (1)
$14,885        8.08 
Notional amount��$269,015 $11,050 $20,908 $30,654 $31,317 $32,898 $142,188 
Weighted-average fixed-rate1.54 %3.25 %0.91 %1.48 %1.17 %1.07 %1.69 %
Pay-fixed interest rate swaps (1)
(5,502)       6.52 
Notional amount $252,698 $7,562 $21,667 $24,671 $24,406 $32,052 $142,340  
Weighted-average fixed-rate0.89 %0.57 %0.10 %1.28 %0.86 %0.68 %1.00 %
Same-currency basis swaps (2)
(235)        
Notional amount $223,659 $18,769 $12,245 $9,747 $22,737 $28,222 $131,939  
Foreign exchange basis swaps (1, 3, 4)
(1,014)  
Notional amount 112,465 27,424 16,038 8,066 3,819 4,446 52,672  
Foreign exchange contracts (1, 4, 5)
349  
Notional amount (6)
(42,490)(69,299)2,841 2,505 4,735 4,369 12,359 
Futures and forward rate contracts47 
Notional amount14,255 14,255      
Option products   
Notional amount 17   17     
Net ALM contracts$8,530         
83 Bank of America


Table 48Asset and Liability Management Interest Rate and Foreign Exchange Contracts (continued)
  December 31, 2019
  Expected Maturity
(Dollars in millions, average estimated duration in years)Fair
Value
Total20202021202220232024ThereafterAverage
Estimated
Duration
Receive-fixed interest rate swaps (1)
$12,370        6.47 
Notional amount $215,123 $16,347 $14,642 $21,616 $36,356 $21,257 $104,905 
Weighted-average fixed-rate2.68 %2.68 %3.17 %2.48 %2.36 %2.55 %2.79 %
Pay-fixed interest rate swaps (1)
(2,669)       6.99 
Notional amount $69,586 $4,344 $2,117 $— $13,993 $8,194 $40,938  
Weighted-average fixed-rate2.36 %2.16 %2.15 %— %2.52 %2.26 %2.35 %
Same-currency basis swaps (2)
(290)        
Notional amount $152,160 $18,857 $18,590 $4,306 $2,017 $14,567 $93,823  
Foreign exchange basis swaps (1, 3, 4)
(1,258)  
Notional amount 113,529 23,639 24,215 14,611 7,111 3,521 40,432  
Foreign exchange contracts (1, 4, 5)
414  
Notional amount (6)
(53,106)(79,315)4,539 2,674 2,340 4,432 12,224 
Option products—   
Notional amount 15 — — — 15 — —  
Net ALM contracts$8,567         
(1)Does not include basis adjustments on either fixed-rate debt issued by the Corporation or inputs.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.

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, 2020and December 31, 2019 (prior to the adoption of the CECL accounting standard).
Table 42Allocation of the Allowance for Credit Losses by Product Type
AmountPercent of
Total
Percent of
Loans and
Leases
Outstanding (1)
AmountPercent of
Total
Percent of
Loans and
Leases
Outstanding
(1)
AmountPercent of
Total
Percent of
Loans and
Leases
Outstanding (1)
(Dollars in millions)December 31, 2020January 1, 2020December 31, 2019
Allowance for loan and lease losses      
Residential mortgage$459 2.44 %0.21 %$212 1.72 %0.09 %$325 3.45 %0.14 %
Home equity399 2.12 1.16 228 1.84 0.57 221 2.35 0.55 
Credit card8,420 44.79 10.70 6,809 55.10 6.98 3,710 39.39 3.80 
Direct/Indirect consumer752 4.00 0.82 566 4.58 0.62 234 2.49 0.26 
Other consumer41 0.22 n/m55 0.45 n/m52 0.55 n/m
Total consumer10,071 53.57 2.35 7,870 63.69 1.69 4,542 48.23 0.98 
U.S. commercial (2)
5,043 26.82 1.55 2,723 22.03 0.84 3,015 32.02 0.94 
Non-U.S. commercial1,241 6.60 1.37 668 5.41 0.64 658 6.99 0.63 
Commercial real estate2,285 12.15 3.79 1,036 8.38 1.65 1,042 11.07 1.66 
Commercial lease financing162 0.86 0.95 61 0.49 0.31 159 1.69 0.80 
Total commercial8,731 46.43 1.77 4,488 36.31 0.88 4,874 51.77 0.96 
Allowance for loan and lease losses18,802 100.00 %2.04 12,358 100.00 %1.27 9,416 100.00 %0.97 
Reserve for unfunded lending commitments1,878 1,123 813  
Allowance for credit losses$20,680 $13,481 $10,229 
(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.
(2)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
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 incurred losses. For more information on 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.
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Table 43Allowance for Credit Losses
(Dollars in millions)20202019
Allowance for loan and lease losses, January 1$12,358 $9,601 
Loans and leases charged off
Residential mortgage(40)(93)
Home equity(58)(429)
Credit card(2,967)(3,535)
Direct/Indirect consumer(372)(518)
Other consumer(307)(249)
Total consumer charge-offs(3,744)(4,824)
U.S. commercial (1)
(1,163)(650)
Non-U.S. commercial(168)(115)
Commercial real estate(275)(31)
Commercial lease financing(69)(26)
Total commercial charge-offs(1,675)(822)
Total loans and leases charged off(5,419)(5,646)
Recoveries of loans and leases previously charged off
Residential mortgage70 140 
Home equity131 787 
Credit card618 587 
Direct/Indirect consumer250 309 
Other consumer23 15 
Total consumer recoveries1,092 1,838 
U.S. commercial (2)
178 122 
Non-U.S. commercial13 31 
Commercial real estate5 
Commercial lease financing10 
Total commercial recoveries206 160 
Total recoveries of loans and leases previously charged off1,298 1,998 
Net charge-offs(4,121)(3,648)
Provision for loan and lease losses10,565 3,574 
Other (111)
Allowance for loan and lease losses, December 3118,802 9,416 
Reserve for unfunded lending commitments, January 11,123 797 
Provision for unfunded lending commitments755 16 
Reserve for unfunded lending commitments, December 311,878 813 
Allowance for credit losses, December 31$20,680 $10,229 
Loan and allowance ratios:
Loans and leases outstanding at December 31 (3)
$921,180 $975,091 
Allowance for loan and lease losses as a percentage of total loans and leases outstanding at December 31 (3)
2.04 %0.97 %
Consumer allowance for loan and lease losses as a percentage of total consumer loans and leases outstanding at December 31 (4)
2.35 0.98 
Commercial allowance for loan and lease losses as a percentage of total commercial loans and leases outstanding at December 31 (5)
1.77 0.96 
Average loans and leases outstanding (3)
$974,281 $951,583 
Annualized net charge-offs as a percentage of average loans and leases outstanding (3)
0.42 %0.38 %
Allowance for loan and lease losses as a percentage of total nonperforming loans and leases at December 31380 265 
Ratio of the allowance for loan and lease losses at December 31 to net charge-offs4.56 2.58 
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)
$9,854 $4,151 
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)
181 %148 %
(1)Includes U.S. small business commercial charge-offs of $321 million in 2020 compared to $320 million in 2019.
(2)Includes U.S. small business commercial recoveries of $54 million in 2020 compared to $48 million in 2019.
(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.
77 Bank of America


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 82.
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 25.
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 requirements and monitors the effective challenge in the model validation process across the Corporation.
Interest Rate Risk
Interest rate risk represents exposures to instruments whose values vary with the level or volatility of interest rates. These instruments include, but are not limited to, loans, debt securities, certain trading-related assets and liabilities, deposits, borrowings and derivatives. Hedging instruments used to mitigate these risks include derivatives such as options, futures, forwards and swaps.
Foreign Exchange Risk
Foreign exchange risk represents exposures to changes in the values of current holdings and future cash flows denominated in currencies other than the U.S. dollar. The types of instruments exposed to this risk include investments in non-U.S. subsidiaries, foreign currency-denominated loans and securities, future cash flows in foreign currencies arising from foreign exchange transactions, foreign currency-denominated debt and various foreign exchange derivatives whose values fluctuate with changes in the level or volatility of currency exchange rates or non-U.S. interest rates. Hedging instruments used to mitigate this risk include foreign exchange options, currency swaps, futures, forwards, and foreign currency-denominated debt and deposits.
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 84.
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 further exacerbated if expected hedging or pricing correlations are compromised by disproportionate demand or lack of demand for certain instruments. We utilize various risk mitigating techniques as discussed in more detail in Trading Risk Management.
Trading Risk Management
To evaluate risks in our trading activities, we focus on the actual and potential volatility of revenues generated by individual positions as well as portfolios of positions. Various techniques and procedures are utilized to enable the most complete understanding of these risks. Quantitative measures of market risk are evaluated on a daily basis from a single position to the portfolio of the Corporation. These measures include sensitivities of positions to various market risk factors, such as the potential impact on revenue from a one basis point change in interest rates, and statistical measures utilizing both actual and hypothetical market moves, such as VaR and stress testing. Periods of extreme market stress influence the reliability of these techniques to varying degrees. Qualitative evaluations of market risk utilize the suite of quantitative risk measures while understanding each of their respective limitations. Additionally, risk managers independently evaluate the risk of the portfolios under the current market environment and potential future environments.
VaR is a common statistic used to measure market risk as it allows the aggregation of market risk factors, including the effects of portfolio diversification. A VaR model simulates the value of a portfolio under a range of scenarios in order to generate a distribution of potential gains and losses. VaR represents the loss a portfolio is not expected to exceed more than a certain number of times per period, based on a specified holding period, confidence level and window of historical data. We use one VaR model consistently across the trading portfolios and it uses a historical simulation approach based on a three-year window of historical data. Our primary VaR statistic is equivalent to a 99 percent confidence level, which means that for a VaR with a one-day holding period, there should not be losses in excess of VaR, on average, 99 out of 100 trading days.
Within any VaR model, there are significant and numerous assumptions that will differ from company to company. The accuracy of a VaR model depends on the availability and quality of historical data for each of the risk factors in the portfolio. A VaR model may require additional modeling assumptions for new products that do not have the necessary historical market data or for less liquid positions for which accurate daily prices
are not consistently available. For positions with insufficient historical data for the VaR calculation, the process for establishing an appropriate proxy is based on fundamental and statistical analysis of the new product or less liquid position. This analysis identifies reasonable alternatives that replicate both the expected volatility and correlation to other market risk factors that the missing data would be expected to experience.
VaR may not be indicative of realized revenue volatility as changes in market conditions or in the composition of the portfolio can have a material impact on the results. In particular, the historical data used for the VaR calculation might indicate higher or lower levels of portfolio diversification than will be experienced. In order for the VaR model to reflect current market conditions, we update the historical data underlying our VaR model on a weekly basis, or more frequently during periods of market stress, and regularly review the assumptions underlying the model. A minor portion of risks related to our trading positions is not included in VaR. These risks are reviewed as part of our ICAAP. For more information regarding ICAAP, see Capital Management on page 50.
Global Risk Management continually reviews, evaluates and enhances our VaR model so that it reflects the material risks in our trading portfolio. Changes to the VaR model are reviewed and approved prior to implementation and any material changes are reported to management through the appropriate management committees.
Trading limits on quantitative risk measures, including VaR, are independently set by Global Markets Risk Management and reviewed on a regular basis so that trading limits remain relevant and within our overall risk appetite for market risks. Trading limits are reviewed in the context of market liquidity, volatility and strategic business priorities. Trading limits are set at both a granular level to allow for extensive coverage of risks as well as at aggregated portfolios to account for correlations among risk factors. All trading limits are approved at least annually. Approved trading limits are stored and tracked in a centralized limits management system. Trading limit excesses are communicated to management for review. Certain quantitative market risk measures and corresponding limits have been identified as critical in the Corporation’s Risk Appetite Statement. These risk appetite limits are reported on a daily basis and are approved at least annually by the ERC and the Board.
In periods of market stress, Global Markets senior leadership communicates daily to discuss losses, key risk positions and any limit excesses. As a result of this process, the businesses may selectively reduce risk.
Table 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
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.
Table 44Market Risk VaR for Trading Activities
20202019
(Dollars in millions)Year
End
Average
High (1)
Low (1)
Year
End
Average
High (1)
Low (1)
Foreign exchange$8 $7 $25 $2 $$$13 $
Interest rate30 19 39 7 25 24 49 14 
Credit79 58 91 25 26 23 32 16 
Equity20 24 162 12 29 22 33 14 
Commodities4 6 12 3 31 
Portfolio diversification(72)(61)  (47)(49)— — 
Total covered positions portfolio69 53 171 27 41 32 47 24 
Impact from less liquid exposures52 27   — — — 
Total covered positions and less liquid trading positions portfolio121 80 169 30 41 35 53 27 
Fair value option loans52 52 84 7 10 13 
Fair value option hedges11 13 17 9 10 10 17 
Fair value option portfolio diversification(17)(24)  (9)(10)— — 
Total fair value option portfolio46 41 86 9 10 16 
Portfolio diversification(4)(15)  (5)(7)— — 
Total market-based portfolio$163 $106 171 32 $45 $38 56 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.
bac-20201231_g3.jpg
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 45Average Market Risk VaR for Trading Activities – 99 percent and 95 percent VaR Statistics
20202019
(Dollars in millions)99 percent95 percent99 percent95 percent
Foreign exchange$7 $4 $$
Interest rate19 9 24 15 
Credit58 18 23 15 
Equity24 13 22 11 
Commodities6 3 
Portfolio diversification(61)(26)(49)(29)
Total covered positions portfolio53 21 32 18 
Impact from less liquid exposures27 2 
Total covered positions and less liquid trading positions portfolio80 23 35 20 
Fair value option loans52 13 10 
Fair value option hedges13 7 10 
Fair value option portfolio diversification(24)(8)(10)(5)
Total fair value option portfolio41 12 10 
Portfolio diversification(15)(6)(7)(5)
Total market-based portfolio$106 $29 $38 $21 
Backtesting
The accuracy of the VaR methodology is evaluated by backtesting, which compares the daily VaR results, utilizing a one-day holding period, against a comparable subset of trading revenue. A backtesting excess occurs when a trading loss exceeds the VaR for the corresponding day. These excesses are evaluated to understand the positions and market moves that produced the trading loss with a goal to ensure that the VaR methodology accurately represents those losses. We expect the frequency of trading losses in excess of VaR to be in line with the confidence level of the VaR statistic being tested. For example, with a 99 percent confidence level, we expect one trading loss in excess of VaR every 100 days or between two to three trading losses in excess of VaR over the course of a year. The number of backtesting excesses observed can differ from the statistically expected number of excesses if the current level of market volatility is materially different than the level of market volatility that existed during the three years of historical data used in the VaR calculation.
The trading revenue used for backtesting is defined by regulatory agencies in order to most closely align with the VaR component of the regulatory capital calculation. This revenue differs from total trading-related revenue in that it excludes revenue from trading activities that either do not generate market risk or the market risk cannot be included in VaR. Some examples of the types of revenue excluded for backtesting are fees, commissions, reserves, net interest income and intra-day trading revenues.
We conduct daily backtesting on the VaR results used for regulatory capital calculations as well as the VaR results for key legal entities, regions and risk factors. These results are reported to senior market risk management. Senior management regularly reviews and evaluates the results of these tests.
During 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.
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.
bac-20201231_g4.jpg
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
81 Bank of America


severe point during a crisis is selected for each historical scenario. Hypothetical scenarios provide estimated portfolio impacts from potential future market stress events. Scenarios are reviewed and updated in response to changing positions and new economic or political information. In addition, new or ad hoc scenarios are developed to address specific potential market events or particular vulnerabilities in the portfolio. The stress tests are reviewed on a regular basis and the results are presented to senior management.
Stress testing for the trading portfolio is integrated with enterprise-wide stress testing and incorporated into the limits framework. The macroeconomic scenarios used for enterprise-wide stress testing purposes differ from the typical trading portfolio scenarios in that they have a longer time horizon and the results are forecasted over multiple periods for use in consolidated capital and liquidity planning. For more information, see Managing Risk on page 47.
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 46Forward Rates
December 31, 2020
 Federal
Funds
Three-month
LIBOR
10-Year
Swap
Spot rates0.25 %0.24 %0.93 %
12-month forward rates0.25 0.19 1.06 
December 31, 2019
Spot rates1.75 %1.91 %1.90 %
12-month forward rates1.50 1.62 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 51.
Table 47Estimated Banking Book Net Interest Income Sensitivity to Curve Changes
Short
Rate (bps)
Long
Rate (bps)
December 31
(Dollars in millions)20202019
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— 6,321 2,641 
Long-end
instantaneous change
— -25 (1,686)(653)
Steepeners  
Short-end
instantaneous change
-25 — (1,084)(844)
Long-end
instantaneous change
— +1004,333 1,561 
The sensitivity analysis in Table 47 assumes that we take no action in response to these rate shocks and does not assume any change in other macroeconomic variables normally correlated with changes in interest rates. As part of our ALM activities, we use securities, certain residential mortgages, and interest rate and foreign exchange derivatives in managing interest rate sensitivity.
The behavior of our deposits portfolio in the baseline forecast and in alternate interest rate scenarios is a key assumption in our projected estimates of net interest income. The sensitivity analysis in Table 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 exchange contracts, including cross-currency interest rate swaps, foreign currency futures contracts, foreign currency forward contracts and options to mitigate the foreign exchange risk associated with foreign currency-denominated assets and liabilities.
Changes to the composition of our derivatives portfolio during 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 48Asset and Liability Management Interest Rate and Foreign Exchange Contracts
December 31, 2020
Expected Maturity
(Dollars in millions, average estimated duration in years)Fair
Value
Total20212022202320242025ThereafterAverage
Estimated
Duration
Receive-fixed interest rate swaps (1)
$14,885        8.08 
Notional amount��$269,015 $11,050 $20,908 $30,654 $31,317 $32,898 $142,188 
Weighted-average fixed-rate1.54 %3.25 %0.91 %1.48 %1.17 %1.07 %1.69 %
Pay-fixed interest rate swaps (1)
(5,502)       6.52 
Notional amount $252,698 $7,562 $21,667 $24,671 $24,406 $32,052 $142,340  
Weighted-average fixed-rate0.89 %0.57 %0.10 %1.28 %0.86 %0.68 %1.00 %
Same-currency basis swaps (2)
(235)        
Notional amount $223,659 $18,769 $12,245 $9,747 $22,737 $28,222 $131,939  
Foreign exchange basis swaps (1, 3, 4)
(1,014)  
Notional amount 112,465 27,424 16,038 8,066 3,819 4,446 52,672  
Foreign exchange contracts (1, 4, 5)
349  
Notional amount (6)
(42,490)(69,299)2,841 2,505 4,735 4,369 12,359 
Futures and forward rate contracts47 
Notional amount14,255 14,255      
Option products   
Notional amount 17   17     
Net ALM contracts$8,530         
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Table 48Asset and Liability Management Interest Rate and Foreign Exchange Contracts (continued)
  December 31, 2019
  Expected Maturity
(Dollars in millions, average estimated duration in years)Fair
Value
Total20202021202220232024ThereafterAverage
Estimated
Duration
Receive-fixed interest rate swaps (1)
$12,370        6.47 
Notional amount $215,123 $16,347 $14,642 $21,616 $36,356 $21,257 $104,905 
Weighted-average fixed-rate2.68 %2.68 %3.17 %2.48 %2.36 %2.55 %2.79 %
Pay-fixed interest rate swaps (1)
(2,669)       6.99 
Notional amount $69,586 $4,344 $2,117 $— $13,993 $8,194 $40,938  
Weighted-average fixed-rate2.36 %2.16 %2.15 %— %2.52 %2.26 %2.35 %
Same-currency basis swaps (2)
(290)        
Notional amount $152,160 $18,857 $18,590 $4,306 $2,017 $14,567 $93,823  
Foreign exchange basis swaps (1, 3, 4)
(1,258)  
Notional amount 113,529 23,639 24,215 14,611 7,111 3,521 40,432  
Foreign exchange contracts (1, 4, 5)
414  
Notional amount (6)
(53,106)(79,315)4,539 2,674 2,340 4,432 12,224 
Option products—   
Notional amount 15 — — — 15 — —  
Net ALM contracts$8,567         
(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 50.
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 appropriate Board-level committees in support of Global Compliance and Operational Risk’s responsibilities for conducting independent oversight of our compliance and operational risk management activities. The Board provides oversight of compliance risk through its Audit Committee and the ERC, and operational risk through the ERC.
A key operational risk facing the Corporation is information security, which includes cybersecurity. Cybersecurity 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 integrity of our, 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 withinternal 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.
The Corporation manages reputational risk 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
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 risk is 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.
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, representsto be based on management’s best estimate of probable losseslifetime ECL inherent in the Corporation’sCorporation's relevant financial assets.
The Corporation's estimate of lifetime ECL includes the use of quantitative models that incorporate forward-looking macroeconomic scenarios that are applied over the contractual life of the loan portfolios, adjusted for expected prepayments and borrower-controlled extension options. 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 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 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.
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, factors the Corporation considers include changes in lending policies and procedures, business conditions, the nature and size of the portfolio, excluding thoseportfolio concentrations, the volume and severity of past due loans accountedand nonaccrual loans, the effect of external factors such as competition and legal and regulatory requirements, among others. Further, the Corporation considers the inherent uncertainty in quantitative models that are built on historical data.
The allowance for undercredit losses can also be impacted by unanticipated changes in asset quality of the fair value option.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. 
As described above, the process to determine the allowance for credit losses 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
and Leases and Allowance for Credit Lossesto the Consolidated Financial Statements.Statements.
Our estimate for the allowance for loan and lease losses is sensitive to the loss rates and expected cash flows from our Consumer Real Estate and Credit Card and Other Consumer portfolio segments, as well as our U.S. small business commercial card portfolio within the Commercial portfolio segment. For each one-percent increase in the loss rates on loans collectively evaluated for impairment in our Consumer Real Estate portfolio segment, excluding PCI loans, coupled with a one-percent decrease in the discounted cash flows on those loans individually evaluated for impairment within this portfolio segment, the allowance for loan and lease losses at December 31, 2017 would have increased $36 million. We subject our PCI portfolio to stress scenarios to evaluate the potential impact given certain events. A one-percent decrease in the expected cash flows could result in a $99 million impairment of the portfolio. Within our Credit Card and Other Consumer portfolio segment and U.S. small business commercial card portfolio, for each one-percent increase in the loss rates on loans collectively evaluated for impairment coupled with a one-percent decrease in the expected cash flows on those loans individually evaluated for impairment, the allowance for loan and lease losses at December 31, 2017 would have increased $41 million.
Our allowance for loan and lease losses is sensitive to the risk ratings assigned to loans and leases within the Commercial portfolio segment (excluding the U.S. small business commercial card portfolio). Assuming a downgrade of one level in the internal risk ratings for commercial loans and leases, except loans and leases already risk-rated Doubtful as defined by regulatory authorities, the allowance for loan and lease losses would have increased $2.6 billion at December 31, 2017.
The allowance for loan and lease losses as a percentage of total loans and leases at December 31, 2017 was 1.12 percent and these hypothetical increases in the allowance would raise the ratio to 1.41 percent.
These sensitivity analyses do not represent management’s expectations of the deterioration in risk ratings or the increases in loss rates but are provided as hypothetical scenarios to assess the sensitivity of the allowance for loan and lease losses to changes in key inputs. We believe the risk ratings and loss severities currently in use are appropriate and that the probability of the alternative scenarios outlined above occurring within a short period of time is remote.
The process of determining the level of the allowance for credit losses requires a high degree of judgment. It is possible that others, given the same information, may at any point in time reach different reasonable conclusions.


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Fair Value of Financial Instruments
We are, underUnder applicable accounting standards, we are required to maximize the use of observable inputs and minimize the use of unobservable inputs in measuring fair value. We classify fair value measurements of financial instruments and MSRs based on the three-level fair value hierarchy in the accounting standards.
The fair values of assets and liabilities may include adjustments, such as market liquidity and credit quality, where appropriate. Valuations of products using models or other techniques are sensitive to assumptions used for the significant inputs. Where market data is available, the inputs used for valuation reflect that information as of our valuation date. Inputs to valuation models are considered unobservable if they are supported by little or no market activity. In periods of extreme volatility, lessened liquidity or in illiquid markets, there may be more variability in market pricing or a lack of market data to use in the valuation process. In keeping with the prudent application of estimates and management judgment in determining the fair value of assets and liabilities, we have in place various processes and controls that include: a model validation policy that requires review and approval of quantitative models used for deal pricing, financial statement 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. Similarly,For example, broker quotes that are executable are given a higher level of reliance thanin less active markets may only be indicative broker quotes, which are not executable.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. Total recurring Level 3 assets were $12.9 billion, or 0.57 percent of total assets, and total recurring Level 3 liabilities were $7.7 billion, or 0.38 percent of total liabilities, at December 31, 2017 compared to $14.5 billion or 0.66 percent and $7.2 billion or 0.37 percent at December 31, 2016.
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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liabilities became unobservable or observable, respectively, in the current marketplace. These transfers are considered to be effective as of the beginning of the quarter in which they occur. For more information on the significant transfers into and out of Level 3 during 20172020, 2019 and 2016,2018, see Note 20 – Fair Value Measurements to the Consolidated Financial Statements.
Accrued Income Taxes and Deferred Tax Assets
Accrued income taxes, reported as a component of either other assets or accrued expenses and other liabilities on the Consolidated Balance Sheet, represent the net amount of current income taxes we expect to pay to or receive from various taxing jurisdictions attributable to our operations to date. We currently file income tax returns in more than 100 federal, state and non-U.S. 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-notmore likely than not to be realized.
Consistent with the applicable accounting standards,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.
On December 22, 2017, the President signed into law the Tax Act which made significant changes to federal income tax law including, among other things, reducing the statutory corporate income tax rate to 21 percent from 35 percent and changing the taxation of our non-U.S. business activities. On that same date, the SEC issued Staff Accounting Bulletin No. 118, which specifies, among other things, that reasonable estimates of the income tax effects of the Tax Act should be used, if determinable. We have accounted for the effects of the Tax Act using reasonable estimates based on currently available information and our interpretations thereof. This accounting may change due to, among other things, changes in interpretations we have made and the issuance of new tax or accounting guidance.
See Note 19 – Income Taxesto the Consolidated Financial Statements for a table of significant tax attributes and additional information. For more information, see page 16 under Part I. Item 1A. Risk Factors - Regulatory, Compliance and Legal.
Goodwill and Intangible Assets
The nature of and accounting for goodwill and intangible assets are discussed in Note 1 – Summary of Significant Accounting Principles, and Note 87 – Goodwill and Intangible Assets to the Consolidated Financial Statements. Goodwill is reviewed for potential impairment at the reporting unit level on an annual basis, which for the Corporation is as of June 30, and in interim periods if events or circumstances indicate a potential impairment. A reporting unit is an operating segment or one level below.


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We completed our annual goodwill impairment test as of June 30, 2017 for all of our reporting units that had goodwill.2020. In performing that test, we compared the fair value of each reporting unit to its estimated carrying value as measured by allocated equity, which includes goodwill. To determineequity. We estimated the fair value we utilized a combination of valuation techniques, consistent with the market approach andeach reporting unit based on the income approach (which utilizes the present value of cash flows to estimate fair value) and also utilized independent valuation specialists.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 including the application ofand then factored in a control premium of 30 percent, based upon observed comparable premiums paid for change-in-control transactions for financial institutions.
Under the income approach, we estimated the fair value of the individual reporting units based on the net present value of estimated future cash flows, utilizing internal forecasts, and an appropriate terminal value. Discount rates used ranged from 8.9 to 13.3 percent and were derived from a capital asset pricing model (i.e., cost of equity financing) that we believe adequately reflects the risk and uncertainty specifically in our internally-developed forecasts, the financial markets generally and industries similar to each of the reporting units. Cumulative average growth rates developed by management for revenues and expenses in each reporting unit ranged from zero to 5.1 percent.
A prolonged decrease in a particular assumption could eventually lead to the fair value of a reporting unit being less than its carrying value.
Based on the results of the test, we determined that theeach reporting unit’s estimated fair value exceeded theits respective carrying value for alland that the goodwill assigned to each reporting unit was not impaired. The fair values of the reporting units that had goodwill, indicating there was no impairment.
Representations and Warranties Liability
The methodology usedas a percentage of their carrying values ranged from 109 percent to 213 percent. It currently remains difficult to estimate the liability for obligations under representations and warrantiesfuture economic impacts related to transfers of residential mortgage loans considers, among other things, the repurchase experience implied in prior settlements,pandemic. If economic and adjusts the experience implied by those prior settlements based on the characteristics of those trusts where the Corporation has a continuing possibility of timely claims. The estimate of the liability for obligations under representations and warranties is based upon currently available information, significant judgment, and a number of factors, including those set forth above, that are subject to change. Changes to any one of these factors could significantly impact the estimate of our liability.
The estimate of the liability for representations and warranties is sensitive to future defaults, loss severity and the net repurchase rate. An assumed simultaneous increase or decrease of 10 percent in estimated future defaults, loss severity and the net repurchase rate would result in an increase of approximately $250 million or decrease of approximately $200 millionmarket conditions (both in the representationsU.S. and warranties liability as of December 31, 2017. These sensitivities are hypothetical and are intended to provide an indication of the impact of a significantinternationally) deteriorate, our reporting units could be negatively impacted, which could change in theseour key assumptions on the representations and warranties liability. In reality, changes in one assumptionrelated estimates and may result in changes in other assumptions, which may or may not counteract the sensitivity.a future impairment charge.
Certain Contingent Liabilities
For more information on representations and warranties exposure and the corresponding estimated range of possible loss,complex judgments associated with certain contingent liabilities, see Off-Balance Sheet Arrangements and Contractual Obligations – Representations and Warranties on page 40, as well as Note 7 – Representations and Warranties Obligations and Corporate Guarantees and Note 12 – Commitments and Contingenciesto the Consolidated Financial Statements.Statements.
2016 Compared to 2015
The following discussion and analysis provide a comparison of our results of operations for 2016 and 2015. This discussion should be read in conjunction with the Consolidated Financial Statements and related Notes.
Overview
Net Income
Net income was $17.8 billion, or $1.49 per diluted share in 2016 compared to $15.9 billion, or $1.31 per diluted share in 2015. The results for 2016 compared to 2015 were driven by higher net interest income and lower noninterest expense, partially offset by a decline in noninterest income and higher provision for credit losses.
Net Interest Income
Net interest income increased $2.1 billion to $41.1 billion in 2016 compared to 2015. The net interest yield increased seven bps to 2.21 percent for 2016. These increases were primarily driven by growth in commercial loans, the impact of higher short-end interest rates and increased debt securities balances, as well as a charge of $612 million in 2015 related to the redemption of certain trust preferred securities, partially offset by lower loan spreads and market-related hedge ineffectiveness.
Noninterest Income
Noninterest income decreased $1.4 billion to $42.6 billion in 2016 compared to 2015. The following highlights the significant changes.
Service charges increased $257 million primarily due to higher treasury-related revenue.
Investment and brokerage services income decreased $592 million driven by lower transactional revenue, and decreased asset management fees due to lower market valuations, partially offset by the impact of higher long-term AUM flows.
Investment banking income decreased $331 million driven by lower equity issuance fees and advisory fees due to a decline in market fee pools.
Trading account profits increased $429 million due to a stronger performance across credit products led by mortgages, and continued strength in rates products, partially offset by reduced client activity in equities.
Mortgage banking income decreased $511 million primarily driven by a decline in production income, higher representations and warranties provision and lower servicing income, partially offset by more favorable MSR results, net of the related hedge performance.
Gains on sales of debt securities decreased $648 million primarily driven by lower sales volume.
Other income increased $102 million primarily due to lower DVA losses on structured liabilities, improved results from loans and the related hedging activities in the fair value option portfolio and lower payment protection insurance expense, partially offset by lower gains on asset sales. DVA losses related to structured liabilities were $97 million in 2015 compared to $633 million in 2015.
Provision for Credit Losses
The provision for credit losses increased $436 million to $3.6 billion for 2016 compared to 2015. The provision for credit losses was $224 million lower than net charge-offs for 2016, resulting in a reduction in the allowance for credit losses. This compared to a reduction of $1.2 billion in the allowance for credit losses in 2015.

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The provision for credit losses for the consumer portfolio increased $360 million to $2.6 billion in 2016 compared to 2015 due to a slower pace of credit quality improvement. Included in the provision is a benefit of $45 million related to the PCI loan portfolio for 2016 compared to a benefit of $40 million in 2015. The provision for credit losses for the commercial portfolio, including unfunded lending commitments, increased $76 million to $1.0 billion in 2016 compared to 2015 driven by an increase in energy sector reserves in the first half of 2016 for the higher risk energy sub-sectors. While we experienced some deterioration in the energy sector in 2016, oil prices stabilized which contributed to a modest improvement in energy-related exposure by year end.
Noninterest Expense
Noninterest expense decreased $2.5 billion to $55.1 billion for 2016 compared to 2015. Personnel expense decreased $1.0 billion as we continued to manage headcount and achieve cost savings. Continued expense management, as well as the expiration of advisor retention awards, more than offset the increases in client-facing professionals. Professional fees decreased $293 million primarily due to lower legal fees. Other general operating expense decreased $655 million primarily driven by lower foreclosed properties expense and lower brokerage fees, partially offset by higher FDIC expense.
Income Tax Expense
The income tax expense was $7.2 billion on pretax income of $25.0 billion in 2016 compared to tax expense of $6.3 billion on pre-tax income of $22.2 billion in 2015. The effective tax rate for 2016 was 28.8 percent and was driven by our recurring tax preferences and net tax benefits related to various tax audit matters, partially offset by a $348 million charge for the impact of the U.K. tax law changes discussed below. The effective tax rate for 2015 was 28.3 percent and was driven by our recurring tax preferences and by tax benefits related to certain non-U.S. restructurings, partially offset by a charge for the impact of the U.K. tax law change enacted in 2015. The charge recorded in both years for the reduction in the U.K. corporate income tax rate was the result of remeasuring our U.K. net deferred tax assets using the lower tax rate.
Business Segment Operations
Consumer Banking
Net income for Consumer Banking increased $523 million to $7.2 billion in 2016 compared to 2015 primarily driven by lower noninterest expense and higher revenue, partially offset by higher provision for credit losses. Net interest income increased $862 million to $21.3 billion primarily due to the beneficial impact of an increase in investable assets as a result of higher deposits. Noninterest income decreased $650 million to $10.4 billion due to lower mortgage banking income and gains in 2015 on certain divestitures. The provision for credit losses increased $369 million to $2.7 billion in 2016 primarily driven by a slower pace of improvement in the credit card portfolio. Noninterest expense decreased $1.1 billion to $17.7 billion driven by improved operating efficiencies and lower fraud costs, partially offset by higher FDIC expense.
Global Wealth & Investment Management
Net income for GWIM increased $205 million to $2.8 billion in 2016 compared to 2015 driven by a decrease in noninterest expense, partially offset by a decrease in revenue. Net interest income increased $232 million to $5.8 billion driven by the impact
of growth in loan and deposit balances. Noninterest income, which primarily includes investment and brokerage services income, decreased $616 million to $11.9 billion. The decline in noninterest income was driven by lower transactional revenue and decreased asset management fees primarily due to lower market valuations in 2016, partially offset by the impact of long-term AUM flows. Noninterest expense decreased $763 million to $13.2 billion primarily due to the expiration of advisor retention awards, lower revenue-related incentives and lower operating and support costs, partially offset by higher FDIC expense.
Global Banking
Net income for Global Banking increased $390 million to $5.7 billion in 2016 compared to 2015 as higher revenue more than offset an increase in the provision for credit losses. Revenue increased $824 million to $18.4 billion in 2016 compared to 2015 driven by higher net interest income, which increased $227 million to $9.5 billion driven by the impact of growth in loans and leases and higher deposits. Noninterest income increased $597 million to $9.0 billion primarily due to the impact from loans and the related loan hedging activities in the fair value option portfolio and higher treasury-related revenues, partially offset by lower investment banking fees. The provision for credit losses increased $197 million to $883 million in 2016 driven by increases in energy-related reserves as well as loan growth. Noninterest expense of $8.5 billion remained relatively unchanged in 2016 as investments in client-facing professionals in Commercial and Business Banking, higher severance costs and an increase in FDIC expense were largely offset by lower operating and support costs.
Global Markets
Net income for Global Markets increased $1.4 billion to $3.8 billion in 2016 compared to 2015. Net DVA losses were $238 million compared to losses of $786 million in 2015. Excluding net DVA, net income increased $1.1 billion to $4.0 billion in 2016 compared to 2015 primarily driven by higher sales and trading revenue and lower noninterest expense, partially offset by lower investment banking fees and investment and brokerage services revenue. Sales and trading revenue, excluding net DVA, increased $638 million primarily due to a stronger performance globally across credit products led by mortgages and continued strength in rates products. The increase was partially offset by challenging credit market conditions in early 2016 as well as reduced client activity in equities, most notably in Asia, and a less favorable trading environment for equity derivatives. Noninterest expense decreased $1.2 billion to $10.2 billion primarily due to lower litigation expense and lower revenue-related expenses.
All Other
The net loss for All Other increased $601 million to $1.7 billion in 2016 primarily due to lower gains on the sale of debt securities, lower mortgage banking income, lower gains on sales of consumer real estate loans and an increase in noninterest expense, partially offset by an improvement in the provision for credit losses. Mortgage banking income decreased $133 million primarily due to higher representations and warranties provision, partially offset by more favorable net MSR results. Gains on the sales of loans were $232 million in 2016 compared to gains of $1.0 billion in 2015. The benefit in the provision for credit losses improved $79 million to a benefit of $100 million in 2016 primarily driven by lower loan and lease balances from continued run-off of non-core consumer real estate loans. Noninterest expense increased $486 million to $5.6 billion driven by litigation expense.



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Non-GAAP Reconciliations
Tables 5449 and 5550 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)20202019201820172016
Reconciliation of average shareholders’ equity to average tangible shareholders’ equity and average tangible common shareholders’ equity     
Shareholders’ equity$267,309 $267,889 $264,748 $271,289 $265,843 
Goodwill(68,951)(68,951)(68,951)(69,286)(69,750)
Intangible assets (excluding MSRs)(1,862)(1,721)(2,058)(2,652)(3,382)
Related deferred tax liabilities821 773 906 1,463 1,644 
Tangible shareholders’ equity$197,317 $197,990 $194,645 $200,814 $194,355 
Preferred stock(23,624)(23,036)(22,949)(24,188)(24,656)
Tangible common shareholders’ equity$173,693 $174,954 $171,696 $176,626 $169,699 
Reconciliation of year-end shareholders’ equity to year-end tangible shareholders’ equity and year-end tangible common shareholders’ equity     
Shareholders’ equity$272,924 $264,810 $265,325 $267,146 $266,195 
Goodwill(68,951)(68,951)(68,951)(68,951)(69,744)
Intangible assets (excluding MSRs)(2,151)(1,661)(1,774)(2,312)(2,989)
Related deferred tax liabilities920 713 858 943 1,545 
Tangible shareholders’ equity$202,742 $194,911 $195,458 $196,826 $195,007 
Preferred stock(24,510)(23,401)(22,326)(22,323)(25,220)
Tangible common shareholders’ equity$178,232 $171,510 $173,132 $174,503 $169,787 
Reconciliation of year-end assets to year-end tangible assets     
Assets$2,819,627 $2,434,079 $2,354,507 $2,281,234 $2,188,067 
Goodwill(68,951)(68,951)(68,951)(68,951)(69,744)
Intangible assets (excluding MSRs)(2,151)(1,661)(1,774)(2,312)(2,989)
Related deferred tax liabilities920 713 858 943 1,545 
Tangible assets$2,749,445 $2,364,180 $2,284,640 $2,210,914 $2,116,879 
(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 31.
Table 50
Quarterly Reconciliations to GAAP Financial Measures (1)
2020 Quarters2019 Quarters
(Dollars in millions)FourthThirdSecondFirstFourthThirdSecondFirst
Reconciliation of average shareholders’ equity to average tangible shareholders’ equity and average tangible common shareholders’ equity        
Shareholders’ equity$271,020 $267,323 $266,316 $264,534 $266,900 $270,430 $267,975 $266,217 
Goodwill(68,951)(68,951)(68,951)(68,951)(68,951)(68,951)(68,951)(68,951)
Intangible assets (excluding MSRs)(2,173)(1,976)(1,640)(1,655)(1,678)(1,707)(1,736)(1,763)
Related deferred tax liabilities910 855 790 728 730 752 770 841 
Tangible shareholders’ equity$200,806 $197,251 $196,515 $194,656 $197,001 $200,524 $198,058 $196,344 
Preferred stock(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$272,924 $268,850 $265,637 $264,918 $264,810 $268,387 $271,408 $267,010 
Goodwill(68,951)(68,951)(68,951)(68,951)(68,951)(68,951)(68,951)(68,951)
Intangible assets (excluding MSRs)(2,151)(2,185)(1,630)(1,646)(1,661)(1,690)(1,718)(1,747)
Related deferred tax liabilities920 910 789 790 713 734 756 773 
Tangible shareholders’ equity$202,742 $198,624 $195,845 $195,111 $194,911 $198,480 $201,495 $197,085 
Preferred stock(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$2,819,627 $2,738,452 $2,741,688 $2,619,954 $2,434,079 $2,426,330 $2,395,892 $2,377,164 
Goodwill(68,951)(68,951)(68,951)(68,951)(68,951)(68,951)(68,951)(68,951)
Intangible assets (excluding MSRs)(2,151)(2,185)(1,630)(1,646)(1,661)(1,690)(1,718)(1,747)
Related deferred tax liabilities920 910 789 790 713 734 756 773 
Tangible assets$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 31.

           
Table 54
Five-year Reconciliations to GAAP Financial Measures (1)
           
(Dollars in millions, shares in thousands)2017 2016 2015 2014 2013
Reconciliation of net interest income to net interest income on a fully taxable-equivalent basis 
  
  
  
  
Net interest income$44,667
 $41,096
 $38,958
 $40,779
 $40,719
Fully taxable-equivalent adjustment925
 900
 889
 851
 859
Net interest income on a fully taxable-equivalent basis$45,592
 $41,996
 $39,847
 $41,630
 $41,578
Reconciliation of total revenue, net of interest expense to total revenue, net of interest expense on a fully taxable-equivalent basis 
  
  
  
  
Total revenue, net of interest expense$87,352
 $83,701
 $82,965
 $85,894
 $87,502
Fully taxable-equivalent adjustment925
 900
 889
 851
 859
Total revenue, net of interest expense on a fully taxable-equivalent basis$88,277
 $84,601
 $83,854
 $86,745
 $88,361
Reconciliation of income tax expense to income tax expense on a fully taxable-equivalent basis 
  
  
  
  
Income tax expense$10,981
 $7,199
 $6,277
 $2,443
 $4,194
Fully taxable-equivalent adjustment925
 900
 889
 851
 859
Income tax expense on a fully taxable-equivalent basis$11,906
 $8,099
 $7,166
 $3,294
 $5,053
Reconciliation of average common shareholders’ equity to average tangible common shareholders’ equity 
  
  
  
  
Common shareholders’ equity$247,101
 $241,187
 $229,576
 $222,907
 $218,340
Goodwill(69,286) (69,750) (69,772) (69,809) (69,910)
Intangible assets (excluding MSRs)(2,652) (3,382) (4,201) (5,109) (6,132)
Related deferred tax liabilities1,463
 1,644
 1,852
 2,090
 2,328
Tangible common shareholders’ equity$176,626
 $169,699
 $157,455
 $150,079
 $144,626
Reconciliation of average shareholders’ equity to average tangible shareholders’ equity 
  
  
  
  
Shareholders’ equity$271,289
 $265,843
 $251,384
 $238,317
 $233,819
Goodwill(69,286) (69,750) (69,772) (69,809) (69,910)
Intangible assets (excluding MSRs)(2,652) (3,382) (4,201) (5,109) (6,132)
Related deferred tax liabilities1,463
 1,644
 1,852
 2,090
 2,328
Tangible shareholders’ equity$200,814
 $194,355
 $179,263
 $165,489
 $160,105
Reconciliation of year-end common shareholders’ equity to year-end tangible common shareholders’ equity 
  
  
  
  
Common shareholders’ equity$244,823
 $240,975
 $233,343
 $224,167
 $219,124
Goodwill(68,951) (69,744) (69,761) (69,777) (69,844)
Intangible assets (excluding MSRs)(2,312) (2,989) (3,768) (4,612) (5,574)
Related deferred tax liabilities943
 1,545
 1,716
 1,960
 2,166
Tangible common shareholders’ equity$174,503
 $169,787
 $161,530
 $151,738
 $145,872
Reconciliation of year-end shareholders’ equity to year-end tangible shareholders’ equity 
  
  
  
  
Shareholders’ equity$267,146
 $266,195
 $255,615
 $243,476
 $232,475
Goodwill(68,951) (69,744) (69,761) (69,777) (69,844)
Intangible assets (excluding MSRs)(2,312) (2,989) (3,768) (4,612) (5,574)
Related deferred tax liabilities943
 1,545
 1,716
 1,960
 2,166
Tangible shareholders’ equity$196,826
 $195,007
 $183,802
 $171,047
 $159,223
Reconciliation of year-end assets to year-end tangible assets 
  
  
  
  
Assets$2,281,234
 $2,188,067
 $2,144,606
 $2,104,539
 $2,102,064
Goodwill(68,951) (69,744) (69,761) (69,777) (69,844)
Intangible assets (excluding MSRs)(2,312) (2,989) (3,768) (4,612) (5,574)
Related deferred tax liabilities943
 1,545
 1,716
 1,960
 2,166
Tangible assets$2,210,914
 $2,116,879
 $2,072,793
 $2,032,110
 $2,028,812
(1)
Presents reconciliations of non-GAAP financial measures to GAAP financial measures. We believe the use of these non-GAAP financial measures provides additional clarity in assessing the results of the Corporation. Other companies may define or calculate these measures differently. 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 27.

Bank of America 88




Statistical Tables
Bank of America 201788


                 
Table 55
Quarterly Reconciliations to GAAP Financial Measures (1)
                 
  2017 Quarters 2016 Quarters
(Dollars in millions)Fourth Third Second First Fourth Third Second First
Reconciliation of net interest income to net interest income on a fully taxable-equivalent basis 
  
  
  
  
  
  
  
Net interest income$11,462
 $11,161
 $10,986
 $11,058
 $10,292
 $10,201
 $10,118
 $10,485
Fully taxable-equivalent adjustment251
 240
 237
 197
 234
 228
 223
 215
Net interest income on a fully taxable-equivalent basis$11,713
 $11,401
 $11,223
 $11,255
 $10,526
 $10,429
 $10,341
 $10,700
Reconciliation of total revenue, net of interest expense to total revenue, net of interest expense on a fully taxable-equivalent basis 
  
  
  
  
  
  
  
Total revenue, net of interest expense$20,436
 $21,839
 $22,829
 $22,248
 $19,990
 $21,635
 $21,286
 $20,790
Fully taxable-equivalent adjustment251
 240
 237
 197
 234
 228
 223
 215
Total revenue, net of interest expense on a fully taxable-equivalent basis$20,687
 $22,079
 $23,066
 $22,445
 $20,224
 $21,863
 $21,509
 $21,005
Reconciliation of income tax expense to income tax expense on a fully taxable-equivalent basis 
  
  
  
  
  
  
  
Income tax expense$3,796
 $2,187
 $3,015
 $1,983
 $1,268
 $2,257
 $1,943
 $1,731
Fully taxable-equivalent adjustment251
 240
 237
 197
 234
 228
 223
 215
Income tax expense on a fully taxable-equivalent basis$4,047
 $2,427
 $3,252
 $2,180
 $1,502
 $2,485
 $2,166
 $1,946
Reconciliation of average common shareholders’ equity to average tangible common shareholders’ equity 
  
  
  
  
  
  
  
Common shareholders’ equity$250,838
 $249,214
 $245,756
 $242,480
 $244,519
 $243,220
 $240,078
 $236,871
Goodwill(68,954) (68,969) (69,489) (69,744) (69,745) (69,744) (69,751) (69,761)
Intangible assets (excluding MSRs)(2,399) (2,549) (2,743) (2,923) (3,091) (3,276) (3,480) (3,687)
Related deferred tax liabilities1,344
 1,465
 1,506
 1,539
 1,580
 1,628
 1,662
 1,707
Tangible common shareholders’ equity$180,829
 $179,161
 $175,030
 $171,352
 $173,263
 $171,828
 $168,509
 $165,130
Reconciliation of average shareholders’ equity to average tangible shareholders’ equity 
  
  
  
  
  
  
  
Shareholders’ equity$273,162
 $273,238
 $270,977
 $267,700
 $269,739
 $268,440
 $265,056
 $260,065
Goodwill(68,954) (68,969) (69,489) (69,744) (69,745) (69,744) (69,751) (69,761)
Intangible assets (excluding MSRs)(2,399) (2,549) (2,743) (2,923) (3,091) (3,276) (3,480) (3,687)
Related deferred tax liabilities1,344
 1,465
 1,506
 1,539
 1,580
 1,628
 1,662
 1,707
Tangible shareholders’ equity$203,153
 $203,185
 $200,251
 $196,572
 $198,483
 $197,048
 $193,487
 $188,324
Reconciliation of period-end common shareholders’ equity to period-end tangible common shareholders’ equity 
  
  
  
  
  
  
  
Common shareholders’ equity$244,823
 $249,646
 $245,440
 $242,770
 $240,975
 $244,379
 $241,884
 $238,501
Goodwill(68,951) (68,968) (68,969) (69,744) (69,744) (69,744) (69,744) (69,761)
Intangible assets (excluding MSRs)(2,312) (2,459) (2,610) (2,827) (2,989) (3,168) (3,352) (3,578)
Related deferred tax liabilities943
 1,435
 1,471
 1,513
 1,545
 1,588
 1,637
 1,667
Tangible common shareholders’ equity$174,503
 $179,654
 $175,332
 $171,712
 $169,787
 $173,055
 $170,425
 $166,829
Reconciliation of period-end shareholders’ equity to period-end tangible shareholders’ equity 
  
  
  
  
  
  
  
Shareholders’ equity$267,146
 $271,969
 $270,660
 $267,990
 $266,195
 $269,600
 $267,104
 $262,843
Goodwill(68,951) (68,968) (68,969) (69,744) (69,744) (69,744) (69,744) (69,761)
Intangible assets (excluding MSRs)(2,312) (2,459) (2,610) (2,827) (2,989) (3,168) (3,352) (3,578)
Related deferred tax liabilities943
 1,435
 1,471
 1,513
 1,545
 1,588
 1,637
 1,667
Tangible shareholders’ equity$196,826
 $201,977
 $200,552
 $196,932
 $195,007
 $198,276
 $195,645
 $191,171
Reconciliation of period-end assets to period-end tangible assets 
  
  
  
  
  
  
  
Assets$2,281,234
 $2,284,174
 $2,254,714
 $2,247,794
 $2,188,067
 $2,195,588
 $2,187,149
 $2,185,818
Goodwill(68,951) (68,968) (68,969) (69,744) (69,744) (69,744) (69,744) (69,761)
Intangible assets (excluding MSRs)(2,312) (2,459) (2,610) (2,827) (2,989) (3,168) (3,352) (3,578)
Related deferred tax liabilities943
 1,435
 1,471
 1,513
 1,545
 1,588
 1,637
 1,667
Tangible assets$2,210,914
 $2,214,182
 $2,184,606
 $2,176,736
 $2,116,879
 $2,124,264
 $2,115,690
 $2,114,146
(1)
Table of Contents
Presents reconciliations of non-GAAP financial measures to GAAP financial measures. We believe the use of these non-GAAP financial measures provides additional clarity in assessing the results of the Corporation. Other companies may define or calculate these measures differently. 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 27.

Page
89Bank of America 2017



Statistical Tables

          
Table I  Outstanding Loans and Leases
          
 December 31
(Dollars in millions)2017 2016 2015 2014 2013
Consumer 
  
  
  
  
Residential mortgage (1)
$203,811
 $191,797
 $187,911
 $216,197
 $248,066
Home equity57,744
 66,443
 75,948
 85,725
 93,672
U.S. credit card96,285
 92,278
 89,602
 91,879
 92,338
Non-U.S. credit card
 9,214
 9,975
 10,465
 11,541
Direct/Indirect consumer (2)
93,830
 94,089
 88,795
 80,381
 82,192
Other consumer (3)
2,678
 2,499
 2,067
 1,846
 1,977
Total consumer loans excluding loans accounted for under the fair value option454,348
 456,320
 454,298
 486,493
 529,786
Consumer loans accounted for under the fair value option (4)
928
 1,051
 1,871
 2,077
 2,164
Total consumer455,276
 457,371
 456,169
 488,570
 531,950
Commercial         
U.S. commercial (5)
298,485
 283,365
 265,647
 233,586
 225,851
Non-U.S. commercial97,792
 89,397
 91,549
 80,083
 89,462
Commercial real estate (6)
58,298
 57,355
 57,199
 47,682
 47,893
Commercial lease financing22,116
 22,375
 21,352
 19,579
 25,199
Total commercial loans excluding loans accounted for under the fair value option476,691
 452,492
 435,747
 380,930
 388,405
Commercial loans accounted for under the fair value option (4)
4,782
 6,034
 5,067
 6,604
 7,878
Total commercial481,473
 458,526
 440,814
 387,534
 396,283
Less: Loans of business held for sale (7)

 (9,214) 
 
 
Total loans and leases$936,749
 $906,683
 $896,983
 $876,104
 $928,233
(1)
Includes pay option loans of $1.4 billion, $1.8 billion, $2.3 billion, $3.2 billion and $4.4 billion at December 31, 2017, 2016, 2015, 2014 and 2013, respectively. The Corporation no longer originates pay option loans.
(2)
Includes auto and specialty lending loans of $49.9 billion, $48.9 billion, $42.6 billion, $37.7 billion and $38.5 billion, unsecured consumer lending loans of $469 million, $585 million, $886 million, $1.5 billion and $2.7 billion, U.S. securities-based lending loans of $39.8 billion, $40.1 billion, $39.8 billion, $35.8 billion and $31.2 billion, non-U.S. consumer loans of $3.0 billion, $3.0 billion, $3.9 billion, $4.0 billion and $4.7 billion, student loans of $0, $497 million, $564 million, $632 million and $4.1 billion, and other consumer loans of $684 million, $1.1 billion, $1.0 billion, $761 million and $1.0 billion at December 31, 2017, 2016, 2015, 2014 and 2013, respectively.
(3)
Includes consumer finance loans of $0, $465 million, $564 million, $676 million and $1.2 billion, consumer leases of $2.5 billion, $1.9 billion, $1.4 billion, $1.0 billion and $606 million, and consumer overdrafts of $163 million, $157 million, $146 million, $162 million and $176 million at December 31, 2017, 2016, 2015, 2014 and 2013, respectively.
(4)
Consumer loans accounted for under the fair value option includes residential mortgage loans of $567 million, $710 million, $1.6 billion, $1.9 billion and $2.0 billion, and home equity loans of $361 million, $341 million, $250 million, $196 million and $147 million at December 31, 2017, 2016, 2015, 2014 and 2013, respectively. Commercial loans accounted for under the fair value option includes U.S. commercial loans of $2.6 billion, $2.9 billion, $2.3 billion, $1.9 billion and $1.5 billion, and non-U.S. commercial loans of $2.2 billion, $3.1 billion, $2.8 billion, $4.7 billion and $6.4 billion at December 31, 2017, 2016, 2015, 2014 and 2013, respectively.
(5)
Includes U.S. small business commercial loans, including card-related products, of $13.6 billion, $13.0 billion, $12.9 billion, $13.3 billion and $13.3 billion at December 31, 2017, 2016, 2015, 2014 and 2013, respectively.
(6)
Includes U.S. commercial real estate loans of $54.8 billion, $54.3 billion, $53.6 billion, $45.2 billion and $46.3 billion, and non-U.S. commercial real estate loans of $3.5 billion, $3.1 billion, $3.5 billion, $2.5 billion and $1.6 billion at December 31, 2017, 2016, 2015, 2014 and 2013, respectively.
(7)
Represents non-U.S. credit card loans, which were included in assets of business held for sale on the Consolidated Balance Sheet.


Bank of America 201790


          
Table II  Nonperforming Loans, Leases and Foreclosed Properties (1)
          
 December 31
(Dollars in millions)2017 2016 2015 2014 2013
Consumer 
  
  
  
  
Residential mortgage$2,476
 $3,056
 $4,803
 $6,889
 $11,712
Home equity2,644
 2,918
 3,337
 3,901
 4,075
Direct/Indirect consumer46
 28
 24
 28
 35
Other consumer
 2
 1
 1
 18
Total consumer (2)
5,166
 6,004
 8,165
 10,819
 15,840
Commercial 
  
  
  
  
U.S. commercial814
 1,256
 867
 701
 819
Non-U.S. commercial299
 279
 158
 1
 64
Commercial real estate112
 72
 93
 321
 322
Commercial lease financing24
 36
 12
 3
 16
 1,249
 1,643
 1,130
 1,026
 1,221
U.S. small business commercial55
 60
 82
 87
 88
Total commercial (3)
1,304
 1,703
 1,212
 1,113
 1,309
Total nonperforming loans and leases6,470
 7,707
 9,377
 11,932
 17,149
Foreclosed properties288
 377
 459
 697
 623
Total nonperforming loans, leases and foreclosed properties$6,758
 $8,084
 $9,836
 $12,629
 $17,772
(1)
Balances do not include PCI loans even though the customer may be contractually past due. PCI loans are recorded at fair value upon acquisition and accrete interest income over the remaining life of the loan. In addition, balances do not include foreclosed properties insured by certain government-guaranteed loans, principally FHA-insured loans, that entered foreclosure of $801 million, $1.2 billion, $1.4 billion, $1.1 billion and $1.4 billion at December 31, 2017, 2016, 2015, 2014 and 2013, respectively.
(2)
In 2017, $867 million in interest income was estimated to be contractually due on $5.2 billion of consumer loans and leases classified as nonperforming at December 31, 2017, as presented in the table above, plus $10.1 billion of TDRs classified as performing at December 31, 2017. Approximately $578 million of the estimated $867 million in contractual interest was received and included in interest income for 2017.
(3)
In 2017, $90 million in interest income was estimated to be contractually due on $1.3 billion of commercial loans and leases classified as nonperforming at December 31, 2017, as presented in the table above, plus $1.1 billion of TDRs classified as performing at December 31, 2017. Approximately $58 million of the estimated $90 million in contractual interest was received and included in interest income for 2017.
          
Table III  Accruing Loans and Leases Past Due 90 Days or More (1)
          
 December 31
(Dollars in millions)2017 2016 2015 2014 2013
Consumer 
  
  
  
  
Residential mortgage (2)
$3,230
 $4,793
 $7,150
 $11,407
 $16,961
U.S. credit card900
 782
 789
 866
 1,053
Non-U.S. credit card
 66
 76
 95
 131
Direct/Indirect consumer40
 34
 39
 64
 408
Other consumer
 4
 3
 1
 2
Total consumer4,170
 5,679
 8,057
 12,433
 18,555
Commercial 
  
  
  
  
U.S. commercial 144
 106
 113
 110
 47
Non-U.S. commercial3
 5
 1
 
 17
Commercial real estate4
 7
 3
 3
 21
Commercial lease financing19
 19
 15
 40
 41
 170
 137
 132
 153
 126
U.S. small business commercial75
 71
 61
 67
 78
Total commercial245
 208
 193
 220
 204
Total accruing loans and leases past due 90 days or more (3)
$4,415
 $5,887
 $8,250
 $12,653
 $18,759
(1)
Our policy is to classify consumer real estate-secured loans as nonperforming at 90 days past due, except the PCI loan portfolio, the fully-insured loan portfolio and loans accounted for under the fair value option as referenced in footnote 3.
(2)
Balances are fully-insured loans.
(3)
Balances exclude loans accounted for under the fair value option. At December 31, 2017, 2016, 2015, 2014 and 2013, $2 million, $1 million, $1 million, $5 million and $8 million of loans accounted for under the fair value option were past due 90 days or more and still accruing interest.

91Bank of America 2017



          
Table IV  Allowance for Credit Losses
          
(Dollars in millions)2017 2016 2015 2014 2013
Allowance for loan and lease losses, January 1$11,237
 $12,234
 $14,419
 $17,428
 $24,179
Loans and leases charged off     
  
  
Residential mortgage(188) (403) (866) (855) (1,508)
Home equity(582) (752) (975) (1,364) (2,258)
U.S. credit card(2,968) (2,691) (2,738) (3,068) (4,004)
Non-U.S. credit card (1)
(103) (238) (275) (357) (508)
Direct/Indirect consumer(487) (392) (383) (456) (710)
Other consumer(216) (232) (224) (268) (273)
Total consumer charge-offs(4,544) (4,708) (5,461) (6,368) (9,261)
U.S. commercial (2)
(589) (567) (536) (584) (774)
Non-U.S. commercial(446) (133) (59) (35) (79)
Commercial real estate(24) (10) (30) (29) (251)
Commercial lease financing(16) (30) (19) (10) (4)
Total commercial charge-offs(1,075) (740) (644) (658) (1,108)
Total loans and leases charged off(5,619) (5,448) (6,105) (7,026) (10,369)
Recoveries of loans and leases previously charged off     
  
  
Residential mortgage288
 272
 393
 969
 424
Home equity369
 347
 339
 457
 455
U.S. credit card455
 422
 424
 430
 628
Non-U.S. credit card28
 63
 87
 115
 109
Direct/Indirect consumer276
 258
 271
 287
 365
Other consumer50
 27
 31
 39
 39
Total consumer recoveries1,466
 1,389
 1,545
 2,297
 2,020
U.S. commercial (3)
142
 175
 172
 214
 287
Non-U.S. commercial6
 13
 5
 1
 34
Commercial real estate15
 41
 35
 112
 102
Commercial lease financing11
 9
 10
 19
 29
Total commercial recoveries174
 238
 222
 346
 452
Total recoveries of loans and leases previously charged off1,640
 1,627
 1,767
 2,643
 2,472
Net charge-offs(3,979) (3,821) (4,338) (4,383) (7,897)
Write-offs of PCI loans(207) (340) (808) (810) (2,336)
Provision for loan and lease losses3,381
 3,581
 3,043
 2,231
 3,574
Other (4)
(39) (174) (82) (47) (92)
Total allowance for loan and lease losses, December 3110,393
 11,480
 12,234
 14,419
 17,428
Less: Allowance included in assets of business held for sale (5)

 (243) 
 
 
Allowance for loan and lease losses, December 3110,393
 11,237
 12,234
 14,419
 17,428
Reserve for unfunded lending commitments, January 1762
 646
 528
 484
 513
Provision for unfunded lending commitments15
 16
 118
 44
 (18)
Other (4)

 100
 
 
 (11)
Reserve for unfunded lending commitments, December 31777
 762
 646
 528
 484
Allowance for credit losses, December 31$11,170
 $11,999
 $12,880
 $14,947
 $17,912
(1)
Represents net charge-offs related to the non-U.S. credit card loan portfolio, which was included in assets of business held for sale on the Consolidated Balance Sheet at December 31, 2016. In 2017, the Corporation sold its non-U.S. consumer credit card business.
(2)
Includes U.S. small business commercial charge-offs of $258 million, $253 million, $282 million, $345 million and $457 million in 2017, 2016, 2015, 2014 and 2013, respectively.
(3)
Includes U.S. small business commercial recoveries of $43 million, $45 million, $57 million, $63 million and $98 million in 2017, 2016, 2015, 2014 and 2013, respectively.
(4)
Primarily represents the net impact of portfolio sales, consolidations and deconsolidations, foreign currency translation adjustments, transfers to held-for-sale and certain other reclassifications.
(5)
Represents allowance related to the non-U.S. credit card loan portfolio, which was sold in 2017.

Bank of America 201792


          
Table IV  Allowance for Credit Losses (continued)
          
(Dollars in millions)2017 2016 2015 2014 2013
Loan and allowance ratios (6):
         
Loans and leases outstanding at December 31 (7)
$931,039
 $908,812
 $890,045
 $867,422
 $918,191
Allowance for loan and lease losses as a percentage of total loans and leases outstanding at December 31 (7)
1.12% 1.26% 1.37% 1.66% 1.90%
Consumer allowance for loan and lease losses as a percentage of total consumer loans and leases outstanding at December 31 (8)
1.18
 1.36
 1.63
 2.05
 2.53
Commercial allowance for loan and lease losses as a percentage of total commercial loans and leases outstanding at December 31 (9)
1.05
 1.16
 1.11
 1.16
 1.03
Average loans and leases outstanding (7)
$911,988
 $892,255
 $869,065
 $888,804
 $909,127
Net charge-offs as a percentage of average loans and leases outstanding (7, 10)
0.44% 0.43% 0.50% 0.49% 0.87%
Net charge-offs and PCI write-offs as a percentage of average loans and leases outstanding (7)
0.46
 0.47
 0.59
 0.58
 1.13
Allowance for loan and lease losses as a percentage of total nonperforming loans and leases at December 31 (7, 11)
161
 149
 130
 121
 102
Ratio of the allowance for loan and lease losses at December 31 to net charge-offs (10)
2.61
 3.00
 2.82
 3.29
 2.21
Ratio of the allowance for loan and lease losses at December 31 to net charge-offs and PCI write-offs2.48
 2.76
 2.38
 2.78
 1.70
Amounts included in allowance for loan and lease losses for loans and leases that are excluded from nonperforming loans and leases at December 31 (12)
$3,971
 $3,951
 $4,518
 $5,944
 $7,680
Allowance for loan and lease losses as a percentage of total nonperforming loans and leases, excluding the allowance for loan and lease losses for loans and leases that are excluded from nonperforming loans and leases at December 31 (7, 12)
99% 98% 82% 71% 57%
Loan and allowance ratios excluding PCI loans and the related valuation allowance (6, 13):
         
Allowance for loan and lease losses as a percentage of total loans and leases outstanding at December 31 (7)
1.10% 1.24% 1.31% 1.51% 1.67%
Consumer allowance for loan and lease losses as a percentage of total consumer loans and leases outstanding at December 31 (8)
1.15
 1.31
 1.50
 1.79
 2.17
Net charge-offs as a percentage of average loans and leases outstanding (7)
0.44
 0.44
 0.51
 0.50
 0.90
Allowance for loan and lease losses as a percentage of total nonperforming loans and leases at December 31 (7, 11)
156
 144
 122
 107
 87
Ratio of the allowance for loan and lease losses at December 31 to net charge-offs2.54
 2.89
 2.64
 2.91
 1.89
(6)
Loan and allowance ratios for 2016 include $243 million of non-U.S. credit card allowance for loan and lease losses and $9.2 billion of ending non-U.S. credit card loans, which were included in assets of business held for sale on the Consolidated Balance Sheet at December 31, 2016. See footnote 1 for more information.
(7)
Outstanding loan and lease balances and ratios do not include loans accounted for under the fair value option of $5.7 billion, $7.1 billion, $6.9 billion, $8.7 billion and $10.0 billion at December 31, 2017, 2016, 2015, 2014 and 2013, respectively. Average loans accounted for under the fair value option were $6.7 billion, $8.2 billion, $7.7 billion, $9.9 billion and $9.5 billion in 2017, 2016, 2015, 2014 and 2013, respectively.
(8)
Excludes consumer loans accounted for under the fair value option of $928 million, $1.1 billion, $1.9 billion, $2.1 billion and $2.2 billion at December 31, 2017, 2016, 2015, 2014 and 2013, respectively.
(9)
Excludes commercial loans accounted for under the fair value option of $4.8 billion, $6.0 billion, $5.1 billion, $6.6 billion and $7.9 billion at December 31, 2017, 2016, 2015, 2014 and 2013, respectively.
(10)
Net charge-offs exclude $207 million, $340 million, $808 million, $810 million and $2.3 billion of write-offs in the PCI loan portfolio in 2017, 2016, 2015, 2014 and 2013 respectively. For more information on PCI write-offs, see Consumer Portfolio Credit Risk Management – Purchased Credit-impaired Loan Portfolio on page 60.
(11)
For more information on our definition of nonperforming loans, see page 62 and page 67.
(12)
Primarily includes amounts allocated to U.S. credit card and unsecured consumer lending portfolios in Consumer Banking, PCI loans and the non-U.S. credit portfolio in All Other.
(13)
For more information on the PCI loan portfolio and the valuation allowance for PCI loans, see Note 4 – Outstanding Loans and Leases and Note 5 – Allowance for Credit Lossesto the Consolidated Financial Statements.

93Bank of America 2017


Table IOutstanding Loans and Leases
  December 31
(Dollars in millions)20202019201820172016
Consumer     
Residential mortgage$223,555 $236,169 $208,557 $203,811 $191,797 
Home equity34,311 40,208 48,286 57,744 66,443 
Credit card78,708 97,608 98,338 96,285 92,278 
Non-U.S. credit card — — — 9,214 
Direct/Indirect consumer (1)
91,363 90,998 91,166 96,342 95,962 
Other consumer (2)
124 192 202 166 626 
Total consumer loans excluding loans accounted for under the fair value option428,061 465,175 446,549 454,348 456,320 
Consumer loans accounted for under the fair value option (3)
735 594 682 928 1,051 
Total consumer428,796 465,769 447,231 455,276 457,371 
Commercial
U.S. commercial288,728 307,048 299,277 284,836 270,372 
Non-U.S. commercial90,460 104,966 98,776 97,792 89,397 
Commercial real estate (4)
60,364 62,689 60,845 58,298 57,355 
Commercial lease financing17,098 19,880 22,534 22,116 22,375 
456,650 494,583 481,432 463,042 439,499 
U.S. small business commercial (5)
36,469 15,333 14,565 13,649 12,993 
Total commercial loans excluding loans accounted for under the fair value option493,119 509,916 495,997 476,691 452,492 
Commercial loans accounted for under the fair value option (3)
5,946 7,741 3,667 4,782 6,034 
Total commercial499,065 517,657 499,664 481,473 458,526 
Less: Loans of business held for sale (6)
 — — — (9,214)
Total loans and leases$927,861 $983,426 $946,895 $936,749 $906,683 

(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.
                    
Table V  Allocation of the Allowance for Credit Losses by Product Type
                    
 December 31
 2017 2016 2015 2014 2013
(Dollars in millions)Amount Percent
of Total
 Amount Percent
of Total
 Amount Percent
of Total
 Amount Percent
of Total
 Amount Percent
of Total
Allowance for loan and lease losses 
  
  
  
  
  
  
  
  
  
Residential mortgage$701
 6.74% $1,012
 8.82% $1,500
 12.26% $2,900
 20.11% $4,084
 23.43%
Home equity1,019
 9.80
 1,738
 15.14
 2,414
 19.73
 3,035
 21.05
 4,434
 25.44
U.S. credit card3,368
 32.41
 2,934
 25.56
 2,927
 23.93
 3,320
 23.03
 3,930
 22.55
Non-U.S. credit card
 
 243
 2.12
 274
 2.24
 369
 2.56
 459
 2.63
Direct/Indirect consumer262
 2.52
 244
 2.13
 223
 1.82
 299
 2.07
 417
 2.39
Other consumer33
 0.32
 51
 0.44
 47
 0.38
 59
 0.41
 99
 0.58
Total consumer5,383
 51.79
 6,222
 54.21
 7,385
 60.36
 9,982
 69.23
 13,423
 77.02
U.S. commercial (1)
3,113
 29.95
 3,326
 28.97
 2,964
 24.23
 2,619
 18.16
 2,394
 13.74
Non-U.S. commercial803
 7.73
 874
 7.61
 754
 6.17
 649
 4.50
 576
 3.30
Commercial real estate935
 9.00
 920
 8.01
 967
 7.90
 1,016
 7.05
 917
 5.26
Commercial lease financing159
 1.53
 138
 1.20
 164
 1.34
 153
 1.06
 118
 0.68
Total commercial5,010
 48.21
 5,258
 45.79
 4,849
 39.64
 4,437
 30.77
 4,005
 22.98
Total allowance for loan and lease losses (2)
10,393
 100.00% 11,480
 100.00% 12,234
 100.00% 14,419
 100.00% 17,428
 100.00%
Less: Allowance included in assets of business held for sale (3)

   (243)   
   
   
  
Allowance for loan and lease losses10,393
   11,237
   12,234
   14,419
   17,428
  
Reserve for unfunded lending commitments777
   762
  
 646
   528
   484
  
Allowance for credit losses$11,170
   $11,999
  
 $12,880
   $14,947
   $17,912
  
(1)
Includes allowance for loan and lease losses for U.S. small business commercial loans of $439 million, $416 million, $507 million, $536 million and $462 million at December 31, 2017, 2016, 2015, 2014 and 2013, respectively.
(2)
Includes $289 million, $419 million, $804 million, $1.7 billion and $2.5 billion of valuation allowance presented with the allowance for loan and lease losses related to PCI loans at December 31, 2017, 2016, 2015, 2014 and 2013, respectively.
(3)
Represents allowance for loan and lease losses related to the non-U.S. credit card loan portfolio, which was included in assets of business held for sale on the Consolidated Balance Sheet at December 31, 2016. In 2017, the Corporation sold its non-U.S. consumer credit card business.
(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.
(4)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.
        
Table VI  Selected Loan Maturity Data (1, 2)
        
 December 31, 2017
(Dollars in millions)
Due in One
Year or Less
 Due After One Year Through Five Years 
Due After
Five Years
 Total
U.S. commercial$74,563
 $177,459
 $49,090
 $301,112
U.S. commercial real estate14,015
 35,741
 5,005
 54,761
Non-U.S. and other (3)
42,933
 53,094
 7,457
 103,484
Total selected loans$131,511
 $266,294
 $61,552
 $459,357
Percent of total29% 58% 13% 100%
Sensitivity of selected loans to changes in interest rates for loans due after one year: 
  
  
  
Fixed interest rates 
 $17,765
 $27,992
  
Floating or adjustable interest rates 
 248,529
 33,560
  
Total 
 $266,294
 $61,552
  
(5)Includes card-related products.
(1)
Loan maturities are based on the remaining maturities under contractual terms.
(2)
Includes loans accounted for under the fair value option.
(3)
Loan maturities include non-U.S. commercial and commercial real estate loans.

(6)Represents non-U.S. credit card loans, which were included in assets of business held for sale on the Consolidated Balance Sheet.

89 Bank of America


Table II
Nonperforming Loans, Leases and Foreclosed Properties (1)
 December 31
(Dollars in millions)20202019201820172016
Consumer     
Residential mortgage$2,005 $1,470 $1,893 $2,476 $3,056 
Home equity649 536 1,893 2,644 2,918 
Direct/Indirect consumer71 47 56 46 28 
Other consumer — — — 
Total consumer (2)
2,725 2,053 3,842 5,166 6,004 
Commercial   
U.S. commercial1,243 1,094 794 814 1,256 
Non-U.S. commercial418 43 80 299 279 
Commercial real estate404 280 156 112 72 
Commercial lease financing87 32 18 24 36 
 2,152 1,449 1,048 1,249 1,643 
U.S. small business commercial75 50 54 55 60 
Total commercial (3)
2,227 1,499 1,102 1,304 1,703 
Total nonperforming loans and leases4,952 3,552 4,944 6,470 7,707 
Foreclosed properties164 285 300 288 377 
Total nonperforming loans, leases and foreclosed properties$5,116 $3,837 $5,244 $6,758 $8,084 
(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 million and $1.2 billion at December 31, 2020, 2019, 2018, 2017 and 2016, respectively.
(2)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.
(3)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)
 December 31
(Dollars in millions)20202019201820172016
Consumer     
Residential mortgage (2)
$762 $1,088 $1,884 $3,230 $4,793 
Credit card903 1,042 994 900 782 
Non-U.S. credit card — — — 66 
Direct/Indirect consumer33 33 38 40 34 
Other consumer — — — 
Total consumer1,698 2,163 2,916 4,170 5,679 
Commercial   
U.S. commercial 228 106 197 144 106 
Non-U.S. commercial10 — 
Commercial real estate6 19 
Commercial lease financing25 20 29 19 19 
 269 153 230 170 137 
U.S. small business commercial115 97 84 75 71 
Total commercial384 250 314 245 208 
Total accruing loans and leases past due 90 days or more$2,082 $2,413 $3,230 $4,415 $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.

Bank of America 20179490


Table IV
Selected Loan Maturity Data (1, 2)
 December 31, 2020
(Dollars in millions)Due in One
Year or Less
Due After One Year Through Five YearsDue After
Five Years
Total
U.S. commercial$82,577 $198,898 $46,642 $328,117 
U.S. commercial real estate14,073 37,552 5,552 57,177 
Non-U.S. and other (3)
33,196 54,488 8,989 96,673 
Total selected loans$129,846 $290,938 $61,183 $481,967 
Percent of total27 %60 %13 %100 %
Sensitivity of selected loans to changes in interest rates for loans due after one year:    
Fixed interest rates $46,911 $32,280  
Floating or adjustable interest rates 244,027 28,903  
Total $290,938 $61,183  
(1)Loan maturities are based on the remaining maturities under contractual terms.
(2)Includes loans accounted for under the fair value option.
(3)Loan maturities include non-U.S. commercial and commercial real estate loans.
Table V
Allowance for Credit Losses (1)
(Dollars in millions)20202019201820172016
Allowance for loan and lease losses, January 1$12,358 $9,601 $10,393 $11,237 $12,234 
Loans and leases charged off   
Residential mortgage(40)(93)(207)(188)(403)
Home equity(58)(429)(483)(582)(752)
Credit card(2,967)(3,535)(3,345)(2,968)(2,691)
Non-U.S. credit card (2)
 — — (103)(238)
Direct/Indirect consumer(372)(518)(495)(491)(392)
Other consumer(307)(249)(197)(212)(232)
Total consumer charge-offs(3,744)(4,824)(4,727)(4,544)(4,708)
U.S. commercial (3)
(1,163)(650)(575)(589)(567)
Non-U.S. commercial(168)(115)(82)(446)(133)
Commercial real estate(275)(31)(10)(24)(10)
Commercial lease financing(69)(26)(8)(16)(30)
Total commercial charge-offs(1,675)(822)(675)(1,075)(740)
Total loans and leases charged off(5,419)(5,646)(5,402)(5,619)(5,448)
Recoveries of loans and leases previously charged off   
Residential mortgage70 140 179 288 272 
Home equity131 787 485 369 347 
Credit card618 587 508 455 422 
Non-U.S. credit card (2)
 — — 28 63 
Direct/Indirect consumer250 309 300 277 258 
Other consumer23 15 15 49 27 
Total consumer recoveries1,092 1,838 1,487 1,466 1,389 
U.S. commercial (4)
178 122 120 142 175 
Non-U.S. commercial13 31 14 13 
Commercial real estate5 15 41 
Commercial lease financing10 11 
Total commercial recoveries206 160 152 174 238 
Total recoveries of loans and leases previously charged off1,298 1,998 1,639 1,640 1,627 
Net charge-offs(4,121)(3,648)(3,763)(3,979)(3,821)
Provision for loan and lease losses10,565 3,574 3,262 3,381 3,581 
Other (5)
 (111)(291)(246)(514)
Total allowance for loan and lease losses, December 3118,802 9,416 9,601 10,393 11,480 
Less: Allowance included in assets of business held for sale (6)
 — — — (243)
Allowance for loan and lease losses, December 3118,802 9,416 9,601 10,393 11,237 
Reserve for unfunded lending commitments, January 11,123 797 777 762 646 
Provision for unfunded lending commitments755 16 20 15 16 
Other (5)
 — — — 100 
Reserve for unfunded lending commitments, December 311,878 813 797 777 762 
Allowance for credit losses, December 31$20,680 $10,229 $10,398 $11,170 $11,999 
(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.
(4)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.
(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.
91 Bank of America



Table VAllowance for Credit Losses (continued)
(Dollars in millions)20202019201820172016
Loan and allowance ratios (7):
Loans and leases outstanding at December 31 (8)
$921,180 $975,091 $942,546 $931,039 $908,812 
Allowance for loan and lease losses as a percentage of total loans and leases outstanding at December 31 (8)
2.04 %0.97 %1.02 %1.12 %1.26 %
Consumer allowance for loan and lease losses as a percentage of total consumer loans and leases outstanding at December 31 (9)
2.35 0.98 1.08 1.18 1.36 
Commercial allowance for loan and lease losses as a percentage of total commercial loans and leases outstanding at December 31 (10)
1.77 0.96 0.97 1.05 1.16 
Average loans and leases outstanding (8)
$974,281 $951,583 $927,531 $911,988 $892,255 
Net charge-offs as a percentage of average loans and leases outstanding (8)
0.42 %0.38 %0.41 %0.44 %0.43 %
Allowance for loan and lease losses as a percentage of total nonperforming loans and leases at December 31380 265 194 161 149 
Ratio of the allowance for loan and lease losses at December 31 to net charge-offs4.56 2.58 2.55 2.61 3.00 
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)
$9,854 $4,151 $4,031 $3,971 $3,951 
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)
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)
 December 31
20202019201820172016
(Dollars in millions)AmountPercent
of Total
AmountPercent
of Total
AmountPercent
of Total
AmountPercent
of Total
AmountPercent
of Total
Allowance for loan and lease losses          
Residential mortgage$459 2.44 %$325 3.45 %$422 4.40 %$701 6.74 %$1,012 8.82 %
Home equity399 2.12 221 2.35 506 5.27 1,019 9.80 1,738 15.14 
Credit card8,420 44.79 3,710 39.39 3,597 37.47 3,368 32.41 2,934 25.56 
Non-U.S. credit card  — — — — — — 243 2.12 
Direct/Indirect consumer752 4.00 234 2.49 248 2.58 264 2.54 244 2.13 
Other consumer41 0.22 52 0.55 29 0.30 31 0.30 51 0.44 
Total consumer10,071 53.57 4,542 48.23 4,802 50.02 5,383 51.79 6,222 54.21 
U.S. commercial (2)
5,043 26.82 3,015 32.02 3,010 31.35 3,113 29.95 3,326 28.97 
Non-U.S. commercial1,241 6.60 658 6.99 677 7.05 803 7.73 874 7.61 
Commercial real estate2,285 12.15 1,042 11.07 958 9.98 935 9.00 920 8.01 
Commercial lease financing162 0.86 159 1.69 154 1.60 159 1.53 138 1.20 
Total commercial8,731 46.43 4,874 51.77 4,799 49.98 5,010 48.21 5,258 45.79 
Total allowance for loan and lease losses18,802 100.00 %9,416 100.00 %9,601 100.00 %10,393 100.00 %11,480 100.00 %
Less: Allowance included in assets of business held for sale (3)
 — — — (243)
Allowance for loan and lease losses18,802 9,416 9,601 10,393 11,237 
Reserve for unfunded lending commitments1,878 813  797 777 762 
Allowance for credit losses$20,680 $10,229  $10,398 $11,170 $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 Statements.
(2)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.
Bank of America 92


Item 7A. Quantitative and Qualitative Disclosures about Market Risk
See Market Risk Management on page 7678 in the MD&A and the sections referenced therein for Quantitative and Qualitative Disclosures about Market Risk.
Item 8. Financial Statements and Supplementary Data
Item 8. Financial Statements and Supplementary Data
Table of Contents
Table of Contents
Page



9593Bank of America 2017







Report of Management on Internal Control Over Financial Reporting
The management of Bank of America Corporation is responsible for establishing and maintaining adequate internal control over financial reporting.
The Corporation’s internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with accounting principles generally accepted in the United States of America. The Corporation’s internal control over financial reporting includes those policies and procedures that (i) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the Corporation; (ii) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with accounting principles generally accepted in the United States of America, and that receipts and expenditures of the Corporation are being made only in accordance with authorizations of management and directors of the Corporation; and (iii) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use, or disposition of the Corporation’s assets that could have a material effect on the financial statements.
Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

Management assessed the effectiveness of the Corporation’s internal control over financial reporting as of December 31, 20172020 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, 2017,2020, the Corporation’s internal control over financial reporting is effective.
The Corporation’s internal control over financial reporting as of December 31, 20172020 has been audited by PricewaterhouseCoopers, LLP, an independent registered public accounting firm, as stated in their accompanying report which expresses an unqualified opinion on the effectiveness of the Corporation’s internal control over financial reporting as of December 31, 2017.2020.
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Brian T. Moynihan
Chairman, Chief Executive Officer and President


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Paul M. Donofrio
Chief Financial Officer



Bank of America 20179694



Report of Independent Registered Public Accounting Firm
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, 20172020 and December 31, 2016,2019, 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, 2017,2020, including the related notes (collectively referred to as the “consolidated financial statements”). We also have audited the Corporation’sCorporation's internal control over financial reporting as of December 31, 2017,2020, 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, 20172020 and December 31, 2016,2019, and the results of theirits operations and theirits cash flows for each of the three years in the period ended December 31, 20172020 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, 2017,2020, based on criteria established in Internal Control - Integrated Framework (2013) issued by the COSO.
Change Inin Accounting Principle
As discussed in Note 1 to the consolidated financial statements, the Corporation changed the manner in which it accounts for the determination of whencredit losses on certain stock-based compensation awards are considered authorized for purposes of determining their service inception date.financial instruments in 2020.
Basis for Opinions
The Corporation’s management is responsible 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’sCorporation'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”)(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 maintained in all material respects.
Our audits of the consolidated financial statements included performing 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 regarding the amounts and disclosures in the consolidated financial statements. Our audits also included evaluating the
accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the consolidated financial statements. Our audit of internal control over financial reporting included obtaining an understanding of internal control over financial reporting, assessing the risk that a material weakness exists, and testing and evaluating the design and operating effectiveness of internal control based on the assessed risk. Our audits also included performing such other procedures as we considered necessary in the circumstances. We believe that our audits provide a reasonable basis for our opinions.
Definition and Limitations of Internal Control over Financial Reporting
A company’s internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles. A company’s internal control over financial reporting includes those policies and procedures that (i) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of 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 $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
95 Bank of America


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 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. 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 others. Further, the Corporation considers the inherent uncertainty in quantitative models that are built on historical data.
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 auditor judgment, subjectivity and effort in performing 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.
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. These procedures also included, among others, testing management’s process for estimating the allowance for loan losses, including (i) evaluating the appropriateness of the loss forecast models and methodology, (ii) evaluating the 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 also included the involvement of professionals with specialized
skill and knowledge to assist in evaluating the appropriateness of certain loss forecast models, the reasonableness of economic forecast scenarios and related weightings and the reasonableness of certain qualitative reserves.
Valuation of Certain Level 3 Financial Instruments
As described in Notes 1 and 20 to the consolidated financial statements, the Corporation carries certain 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 judgment or estimation. The Corporation determines the fair value of Level 3 financial instruments using pricing models, discounted cash flow 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 be determined using quantitative-based extrapolations or other internal methodologies which incorporate management estimates and available market information.
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 procedures, including the involvement of professionals with specialized skill and knowledge to assist in evaluating certain audit evidence.
Addressing the matter involved performing procedures and evaluating audit evidence in connection with forming our overall opinion on the consolidated financial statements. These procedures included testing the effectiveness of controls relating to the valuation of financial instruments, including controls related to valuation models, significant unobservable inputs, and data. These procedures also included, among others, the involvement of professionalswith specialized skill and knowledge to assist in developing an independent estimate of fair value for a sample of these certain financial instruments and comparison of management’s estimate to the independently developed estimate of fair value. Developing the independent estimate involved testing the completeness and accuracy of data provided by management and evaluating the reasonableness of management’s assumptions used to develop the significant unobservable inputs.

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Charlotte, North Carolina
February 22, 201824, 2021


We have served as the Corporation’s auditor since 1958.





97Bank of America 201796




Bank of America Corporation and Subsidiaries
Consolidated Statement of Income
(In millions, except per share information)202020192018
Net interest income 
Interest income$51,585 $71,236 $66,769 
Interest expense8,225 22,345 18,607 
Net interest income43,360 48,891 48,162 
Noninterest income 
Fees and commissions34,551 33,015 33,078 
Market making and similar activities8,355 9,034 9,008 
Other income(738)304 772 
Total noninterest income42,168 42,353 42,858 
Total revenue, net of interest expense85,528 91,244 91,020 
Provision for credit losses11,320 3,590 3,282 
Noninterest expense
Compensation and benefits32,725 31,977 31,880 
Occupancy and equipment7,141 6,588 6,380 
Information processing and communications5,222 4,646 4,555 
Product delivery and transaction related3,433 2,762 2,857 
Marketing1,701 1,934 1,674 
Professional fees1,694 1,597 1,699 
Other general operating3,297 5,396 4,109 
Total noninterest expense55,213 54,900 53,154 
Income before income taxes18,995 32,754 34,584 
Income tax expense1,101 5,324 6,437 
Net income$17,894 $27,430 $28,147 
Preferred stock dividends1,421 1,432 1,451 
Net income applicable to common shareholders$16,473 $25,998 $26,696 
Per common share information 
Earnings$1.88 $2.77 $2.64 
Diluted earnings1.87 2.75 2.61 
Average common shares issued and outstanding8,753.2 9,390.5 10,096.5 
Average diluted common shares issued and outstanding8,796.9 9,442.9 10,236.9 
      
Consolidated Statement of Income
      
(Dollars in millions, except per share information)2017 2016 2015
Interest income 
  
  
Loans and leases$36,221
 $33,228
 $31,918
Debt securities10,471
 9,167
 9,178
Federal funds sold and securities borrowed or purchased under agreements to resell2,390
 1,118
 988
Trading account assets4,474
 4,423
 4,397
Other interest income4,023
 3,121
 3,026
Total interest income57,579
 51,057
 49,507
      
Interest expense 
  
  
Deposits1,931
 1,015
 861
Short-term borrowings3,538
 2,350
 2,387
Trading account liabilities1,204
 1,018
 1,343
Long-term debt6,239
 5,578
 5,958
Total interest expense12,912
 9,961
 10,549
Net interest income44,667
 41,096
 38,958
      
Noninterest income 
  
  
Card income5,902
 5,851
 5,959
Service charges7,818
 7,638
 7,381
Investment and brokerage services13,281
 12,745
 13,337
Investment banking income6,011
 5,241
 5,572
Trading account profits7,277
 6,902
 6,473
Mortgage banking income224
 1,853
 2,364
Gains on sales of debt securities255
 490
 1,138
Other income1,917
 1,885
 1,783
Total noninterest income42,685
 42,605
 44,007
Total revenue, net of interest expense87,352
 83,701
 82,965
      
Provision for credit losses3,396
 3,597
 3,161
      
Noninterest expense 
  
  
Personnel31,642
 31,748
 32,751
Occupancy4,009
 4,038
 4,093
Equipment1,692
 1,804
 2,039
Marketing1,746
 1,703
 1,811
Professional fees1,888
 1,971
 2,264
Data processing3,139
 3,007
 3,115
Telecommunications699
 746
 823
Other general operating9,928
 10,066
 10,721
Total noninterest expense54,743
 55,083
 57,617
Income before income taxes29,213
 25,021
 22,187
Income tax expense10,981
 7,199
 6,277
Net income$18,232
 $17,822
 $15,910
Preferred stock dividends1,614
 1,682
 1,483
Net income applicable to common shareholders$16,618
 $16,140
 $14,427
      
Per common share information 
  
  
Earnings$1.63
 $1.57
 $1.38
Diluted earnings1.56
 1.49
 1.31
Dividends paid0.39
 0.25
 0.20
Average common shares issued and outstanding (in thousands)10,195,646
 10,284,147
 10,462,282
Average diluted common shares issued and outstanding (in thousands)10,778,428
 11,046,806
 11,236,230
Consolidated Statement of Comprehensive Income
(Dollars in millions)202020192018
Net income$17,894 $27,430 $28,147 
Other comprehensive income (loss), net-of-tax:
Net change in debt securities4,799 5,875 (3,953)
Net change in debit valuation adjustments(498)(963)749 
Net change in derivatives826 616 (53)
Employee benefit plan adjustments(98)136 (405)
Net change in foreign currency translation adjustments(52)(86)(254)
Other comprehensive income (loss)4,977 5,578 (3,916)
Comprehensive income$22,871 $33,008 $24,231 
See accompanying Notes to Consolidated Financial Statements.

97Bank of America 201798



Bank of America Corporation and Subsidiaries
      
Consolidated Statement of Comprehensive Income  
      
(Dollars in millions)2017 2016 2015
Net income$18,232
 $17,822
 $15,910
Other comprehensive income (loss), net-of-tax:     
Net change in debt and marketable equity securities61
 (1,345) (1,580)
Net change in debit valuation adjustments(293) (156) 615
Net change in derivatives64
 182
 584
Employee benefit plan adjustments288
 (524) 394
Net change in foreign currency translation adjustments86
 (87) (123)
Other comprehensive income (loss)206
 (1,930) (110)
Comprehensive income$18,438
 $15,892
 $15,800



Consolidated Balance Sheet
December 31
(Dollars in millions)20202019
Assets
Cash and due from banks$36,430 $30,152 
Interest-bearing deposits with the Federal Reserve, non-U.S. central banks and other banks344,033 131,408 
Cash and cash equivalents380,463 161,560 
Time deposits placed and other short-term investments6,546 7,107 
Federal funds sold and securities borrowed or purchased under agreements to resell
   (includes $108,856 and $50,364 measured at fair value)
304,058 274,597 
Trading account assets (includes $91,510 and $90,946 pledged as collateral)
198,854 229,826 
Derivative assets47,179 40,485 
Debt securities: 
Carried at fair value246,601 256,467 
Held-to-maturity, at cost (fair value – $448,180 and $219,821)
438,249 215,730 
Total debt securities684,850 472,197 
Loans and leases (includes $6,681 and $8,335 measured at fair value)
927,861 983,426 
Allowance for loan and lease losses(18,802)(9,416)
Loans and leases, net of allowance909,059 974,010 
Premises and equipment, net11,000 10,561 
Goodwill68,951 68,951 
Loans held-for-sale (includes $1,585 and $3,709 measured at fair value)
9,243 9,158 
Customer and other receivables64,221 55,937 
Other assets (includes $15,718 and $15,518 measured at fair value)
135,203 129,690 
Total assets$2,819,627 $2,434,079 
Liabilities  
Deposits in U.S. offices:  
Noninterest-bearing$650,674 $403,305 
Interest-bearing (includes $481 and $508 measured at fair value)
1,038,341 940,731 
Deposits in non-U.S. offices:
Noninterest-bearing17,698 13,719 
Interest-bearing88,767 77,048 
Total deposits1,795,480 1,434,803 
Federal funds purchased and securities loaned or sold under agreements to repurchase
   (includes $135,391 and $16,008 measured at fair value)
170,323 165,109 
Trading account liabilities71,320 83,270 
Derivative liabilities45,526 38,229 
Short-term borrowings (includes $5,874 and $3,941 measured at fair value)
19,321 24,204 
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)
181,799 182,798 
Long-term debt (includes $32,200 and $34,975 measured at fair value)
262,934 240,856 
Total liabilities2,546,703 2,169,269 
Commitments and contingencies (Note 6 – Securitizations and Other Variable Interest Entities
   and Note 12 – Commitments and Contingencies)
00
Shareholders’ equity 
Preferred stock, $0.01 par value; authorized – 100,000,000 shares; issued and outstanding – 3,931,440 and 3,887,440 shares
24,510 23,401 
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
85,982 91,723 
Retained earnings164,088 156,319 
Accumulated other comprehensive income (loss)(1,656)(6,633)
Total shareholders’ equity272,924 264,810 
Total liabilities and shareholders’ equity$2,819,627 $2,434,079 
Assets of consolidated variable interest entities included in total assets above (isolated to settle the liabilities of the variable interest entities)
Trading account assets$5,225 $5,811 
Loans and leases23,636 38,837 
Allowance for loan and lease losses(1,693)(807)
Loans and leases, net of allowance21,943 38,030 
All other assets1,387 540 
Total assets of consolidated variable interest entities$28,555 $44,381 
Liabilities of consolidated variable interest entities included in total liabilities above  
Short-term borrowings (includes $22 and $0 of non-recourse short-term borrowings)
$454 $2,175 
Long-term debt (includes $7,053 and $8,717 of non-recourse debt)
7,053 8,718 
All other liabilities (includes $16 and $19 of non-recourse liabilities)
16 22 
Total liabilities of consolidated variable interest entities$7,523 $10,915 
See accompanying Notes to Consolidated Financial Statements.

99Bank of America 201798




Bank of America Corporation and Subsidiaries
    
Consolidated Balance Sheet
  
 December 31
(Dollars in millions)2017 2016
Assets 
  
Cash and due from banks$29,480
 $30,719
Interest-bearing deposits with the Federal Reserve, non-U.S. central banks and other banks127,954
 117,019
Cash and cash equivalents157,434
 147,738
Time deposits placed and other short-term investments11,153
 9,861
Federal funds sold and securities borrowed or purchased under agreements to resell (includes $52,906 and $49,750 measured at fair value)
212,747
 198,224
Trading account assets (includes $106,274 and $106,057 pledged as collateral)
209,358
 180,209
Derivative assets37,762
 42,512
Debt securities: 
  
Carried at fair value (includes $29,830 and $29,804 pledged as collateral)
315,117
 313,660
Held-to-maturity, at cost (fair value – $123,299 and $115,285; $6,007 and $8,233 pledged as collateral)
125,013
 117,071
Total debt securities440,130
 430,731
Loans and leases (includes $5,710 and $7,085 measured at fair value and $40,051 and $31,805 pledged as collateral)
936,749
 906,683
Allowance for loan and lease losses(10,393) (11,237)
Loans and leases, net of allowance926,356
 895,446
Premises and equipment, net9,247
 9,139
Mortgage servicing rights2,302
 2,747
Goodwill68,951
 68,969
Loans held-for-sale (includes $2,156 and $4,026 measured at fair value)
11,430
 9,066
Customer and other receivables61,623
 58,759
Assets of business held for sale (includes $619 measured at fair value at December 31, 2016)
 10,670
Other assets (includes $20,279 and $13,802 measured at fair value)
132,741
 123,996
Total assets$2,281,234
 $2,188,067
    
Assets of consolidated variable interest entities included in total assets above (isolated to settle the liabilities of the variable interest entities)
Trading account assets$6,521
 $5,773
Loans and leases48,929
 56,001
Allowance for loan and lease losses(1,016) (1,032)
Loans and leases, net of allowance47,913
 54,969
Loans held-for-sale27
 188
All other assets1,694
 1,596
Total assets of consolidated variable interest entities$56,155
 $62,526

Consolidated Statement of Changes in Shareholders’ Equity
Preferred
Stock
Common Stock and
Additional Paid-in Capital
Retained
Earnings
Accumulated
Other
Comprehensive
Income (Loss)
Total
Shareholders’
Equity
(In millions)SharesAmount
Balance, December 31, 2017$22,323 10,287.3 $138,089 $113,816 $(7,082)$267,146 
Cumulative adjustment for adoption of hedge accounting
standard
(32)57 25 
Adoption of accounting standard related to certain tax effects
stranded in accumulated other comprehensive income (loss)
1,270 (1,270)
Net income   28,147 28,147 
Net change in debt securities    (3,953)(3,953)
Net change in debit valuation adjustments749 749 
Net change in derivatives    (53)(53)
Employee benefit plan adjustments    (405)(405)
Net change in foreign currency translation adjustments   (254)(254)
Dividends declared:    
Common (5,424) (5,424)
Preferred  (1,451) (1,451)
Issuance of preferred stock4,515 4,515 
Redemption of preferred stock(4,512)(4,512)
Common stock issued under employee plans, net, and other58.2 901 (12) 889 
Common stock repurchased(676.2)(20,094)(20,094)
Balance, December 31, 2018$22,326 9,669.3 $118,896 $136,314 $(12,211)$265,325 
Cumulative adjustment for adoption of lease accounting
standard
165 165 
Net income27,430 27,430 
Net change in debt securities5,875 5,875 
Net change in debit valuation adjustments(963)(963)
Net change in derivatives616 616 
Employee benefit plan adjustments136 136 
Net change in foreign currency translation adjustments(86)(86)
Dividends declared:
Common(6,146)(6,146)
Preferred(1,432)(1,432)
Issuance of preferred stock3,643 3,643 
Redemption of preferred stock(2,568)(2,568)
Common stock issued under employee plans, net, and other123.3 971 (12)959 
Common stock repurchased(956.5)(28,144)(28,144)
Balance, December 31, 2019$23,401 8,836.1 $91,723 $156,319 $(6,633)$264,810 
Cumulative adjustment for adoption of credit loss accounting
standard
(2,406)(2,406)
Net income17,894 17,894 
Net change in debt securities4,799 4,799 
Net change in debit valuation adjustments(498)(498)
Net change in derivatives826 826 
Employee benefit plan adjustments(98)(98)
Net change in foreign currency translation adjustments(52)(52)
Dividends declared:
Common(6,289)(6,289)
Preferred(1,421)(1,421)
Issuance of preferred stock2,181 2,181 
Redemption of preferred stock(1,072)(1,072)
Common stock issued under employee plans, net, and other41.7 1,284 (9)1,275 
Common stock repurchased(227.0)(7,025)(7,025)
Balance, December 31, 2020$24,510 8,650.8 $85,982 $164,088 $(1,656)$272,924 
See accompanying Notes to Consolidated Financial Statements.

99Bank of America 2017100



Bank of America Corporation and Subsidiaries
    
Consolidated Balance Sheet (continued)
  
 December 31
(Dollars in millions)2017 2016
Liabilities 
  
Deposits in U.S. offices: 
  
Noninterest-bearing$430,650
 $438,125
Interest-bearing (includes $449 and $731 measured at fair value)
796,576
 750,891
Deposits in non-U.S. offices:   
Noninterest-bearing14,024
 12,039
Interest-bearing68,295
 59,879
Total deposits1,309,545
 1,260,934
Federal funds purchased and securities loaned or sold under agreements to repurchase (includes $36,182 and $35,766 measured at fair value)
176,865
 170,291
Trading account liabilities81,187
 63,031
Derivative liabilities34,300
 39,480
Short-term borrowings (includes $1,494 and $2,024 measured at fair value)
32,666
 23,944
Accrued expenses and other liabilities (includes $22,840 and $14,630 measured at fair value and $777 and $762 of reserve for unfunded lending commitments)
152,123
 147,369
Long-term debt (includes $31,786 and $30,037 measured at fair value)
227,402
 216,823
Total liabilities2,014,088
 1,921,872
Commitments and contingencies (Note 6 – Securitizations and Other Variable Interest Entities, Note 7 – Representations and Warranties Obligations and Corporate Guarantees and Note 10 – Commitments and Contingencies)


 

Shareholders’ equity 
  
Preferred stock, $0.01 par value; authorized – 100,000,000 shares; issued and outstanding – 3,837,683 and 3,887,329 shares
22,323
 25,220
Common stock and additional paid-in capital, $0.01 par value; authorized – 12,800,000,000 shares; issued and outstanding – 10,287,302,431 and 10,052,625,604 shares
138,089
 147,038
Retained earnings113,816
 101,225
Accumulated other comprehensive income (loss)(7,082) (7,288)
Total shareholders’ equity267,146
 266,195
Total liabilities and shareholders’ equity$2,281,234
 $2,188,067
    
Liabilities of consolidated variable interest entities included in total liabilities above 
  
Short-term borrowings$312
 $348
Long-term debt (includes $9,872 and $10,417 of non-recourse debt)
9,873
 10,646
All other liabilities (includes $34 and $38 of non-recourse liabilities)
37
 41
Total liabilities of consolidated variable interest entities$10,222
 $11,035
Consolidated Statement of Cash Flows
(Dollars in millions)202020192018
Operating activities   
Net income$17,894 $27,430 $28,147 
Adjustments to reconcile net income to net cash provided by operating activities:   
Provision for credit losses11,320 3,590 3,282 
Gains on sales of debt securities(411)(217)(154)
Depreciation and amortization1,843 1,729 2,063 
Net amortization of premium/discount on debt securities4,101 2,066 1,824 
Deferred income taxes(1,737)2,435 3,041 
Stock-based compensation2,031 1,974 1,729 
Impairment of equity method investment0 2,072 
Loans held-for-sale:
Originations and purchases(19,657)(28,874)(28,071)
Proceeds from sales and paydowns of loans originally classified as held for sale and instruments
from related securitization activities
19,049 30,191 28,972 
Net change in:
Trading and derivative assets/liabilities16,942 7,920 (23,673)
Other assets(12,883)(11,113)11,920 
Accrued expenses and other liabilities(4,385)16,363 13,010 
Other operating activities, net3,886 6,211 (2,570)
Net cash provided by operating activities37,993 61,777 39,520 
Investing activities   
Net change in:
Time deposits placed and other short-term investments561 387 3,659 
Federal funds sold and securities borrowed or purchased under agreements to resell(29,461)(13,466)(48,384)
Debt securities carried at fair value:
Proceeds from sales77,524 52,006 5,117 
Proceeds from paydowns and maturities91,084 79,114 78,513 
Purchases(194,877)(152,782)(76,640)
Held-to-maturity debt securities:
Proceeds from paydowns and maturities93,835 34,770 18,789 
Purchases(257,535)(37,115)(35,980)
Loans and leases:
Proceeds from sales of loans originally classified as held for investment and instruments
from related securitization activities
13,351 12,201 21,365 
Purchases(5,229)(5,963)(4,629)
Other changes in loans and leases, net36,571 (46,808)(31,292)
Other investing activities, net(3,489)(2,974)(1,986)
Net cash used in investing activities(177,665)(80,630)(71,468)
Financing activities   
Net change in:
Deposits360,677 53,327 71,931 
Federal funds purchased and securities loaned or sold under agreements to repurchase5,214 (21,879)10,070 
Short-term borrowings(4,893)4,004 (12,478)
Long-term debt:
Proceeds from issuance57,013 52,420 64,278 
Retirement(47,948)(50,794)(53,046)
Preferred stock:
Proceeds from issuance2,181 3,643 4,515 
Redemption(1,072)(2,568)(4,512)
Common stock repurchased(7,025)(28,144)(20,094)
Cash dividends paid(7,727)(5,934)(6,895)
Other financing activities, net(601)(698)(651)
Net cash provided by financing activities355,819 3,377 53,118 
Effect of exchange rate changes on cash and cash equivalents2,756 (368)(1,200)
Net increase (decrease) in cash and cash equivalents218,903 (15,844)19,970 
Cash and cash equivalents at January 1161,560 177,404 157,434 
Cash and cash equivalents at December 31$380,463 $161,560 $177,404 
Supplemental cash flow disclosures
Interest paid$8,662 $22,196 $19,087 
Income taxes paid, net2,894 4,359 2,470 
See accompanying Notes to Consolidated Financial Statements.

101Bank of America 2017



Bank of America Corporation and Subsidiaries
            
Consolidated Statement of Changes in Shareholders’ Equity
            
 
Preferred
Stock
 
Common Stock and
Additional Paid-in Capital
 
Retained
Earnings
 
Accumulated
Other
Comprehensive
Income (Loss)
 
Total
Shareholders’
Equity
(Dollars in millions, shares in thousands) Shares Amount   
Balance, December 31, 2014$19,309
 10,516,542
 $153,458
 $74,731
 $(4,022) $243,476
Cumulative adjustment for accounting change related to debit valuation adjustments 
  
  
 1,226
 (1,226) 
Cumulative adjustment for accounting change related to retirement-eligible stock-based compensation expense 
  
   (635) 

 (635)
Net income 
  
  
 15,910
   15,910
Net change in debt and marketable equity securities 
  
  
  
 (1,580) (1,580)
Net change in debit valuation adjustments        615
 615
Net change in derivatives 
  
  
  
 584
 584
Employee benefit plan adjustments 
  
  
  
 394
 394
Net change in foreign currency translation adjustments 
  
  
   (123) (123)
Dividends declared: 
  
  
    
  
Common   
   (2,091)  
 (2,091)
Preferred   
  
 (1,483)  
 (1,483)
Issuance of preferred stock2,964
         2,964
Common stock issued under employee plans, net, and related tax effects  4,054
 (42)  
  
 (42)
Common stock repurchased  (140,331) (2,374)     (2,374)
Balance, December 31, 2015$22,273
 10,380,265
 $151,042
 $87,658
 $(5,358) $255,615
Net income      17,822
   17,822
Net change in debt and marketable equity securities        (1,345) (1,345)
Net change in debit valuation adjustments        (156) (156)
Net change in derivatives        182
 182
Employee benefit plan adjustments        (524) (524)
Net change in foreign currency translation adjustments        (87) (87)
Dividends declared:           
Common      (2,573)   (2,573)
Preferred      (1,682)   (1,682)
Issuance of preferred stock2,947
         2,947
Common stock issued under employee plans, net, and related tax effects  5,111
 1,108
     1,108
Common stock repurchased  (332,750) (5,112)     (5,112)
Balance, December 31, 2016$25,220
 10,052,626
 $147,038
 $101,225
 $(7,288) $266,195
Net income      18,232
   18,232
Net change in debt and marketable equity securities        61
 61
Net change in debit valuation adjustments        (293) (293)
Net change in derivatives        64
 64
Employee benefit plan adjustments        288
 288
Net change in foreign currency translation adjustments        86
 86
Dividends declared:           
Common      (4,027)   (4,027)
Preferred      (1,578)   (1,578)
Common stock issued in connection with exercise of warrants and exchange of preferred stock(2,897) 700,000
 2,933
 (36)   
Common stock issued under employee plans, net and other  43,329
 932
     932
Common stock repurchased  (508,653) (12,814)     (12,814)
Balance, December 31, 2017$22,323
 10,287,302
 $138,089
 $113,816
 $(7,082) $267,146
See accompanying Notes to Consolidated Financial Statements.

Bank of America 2017102100


Bank of America Corporation and Subsidiaries
      
Consolidated Statement of Cash Flows
      
      
(Dollars in millions)2017 2016 2015
Operating activities 
  
  
Net income$18,232
 $17,822
 $15,910
Adjustments to reconcile net income to net cash provided by operating activities: 
  
  
Provision for credit losses3,396
 3,597
 3,161
Gains on sales of debt securities(255) (490) (1,138)
Depreciation and premises improvements amortization1,482
 1,511
 1,555
Amortization of intangibles621
 730
 834
Net amortization of premium/discount on debt securities2,251
 3,134
 2,613
Deferred income taxes8,175
 5,793
 2,967
Stock-based compensation1,649
 1,367
 (89)
Loans held-for-sale:     
Originations and purchases(43,506) (33,107) (37,933)
Proceeds from sales and paydowns of loans originally classified as held-for-sale40,059
 31,376
 36,204
Net change in:     
Trading and derivative instruments(13,939) (866) 2,550
Other assets(19,859) (13,802) 2,645
Accrued expenses and other liabilities4,673
 (35) 730
Other operating activities, net7,424
 1,331
 (1,612)
Net cash provided by operating activities10,403
 18,361
 28,397
Investing activities 
  
  
Net change in:     
Time deposits placed and other short-term investments(1,292) (2,117) 50
Federal funds sold and securities borrowed or purchased under agreements to resell(14,523) (5,742) (659)
Debt securities carried at fair value:     
Proceeds from sales73,353
 71,547
 137,569
Proceeds from paydowns and maturities93,874
 108,592
 92,498
Purchases(166,975) (189,061) (219,412)
Held-to-maturity debt securities:     
Proceeds from paydowns and maturities16,653
 18,677
 12,872
Purchases(25,088) (39,899) (36,575)
Loans and leases:     
Proceeds from sales11,761
 18,230
 22,316
Purchases(6,846) (12,283) (12,629)
Other changes in loans and leases, net(41,104) (31,194) (51,895)
Other investing activities, net8,180
 107
 294
Net cash used in investing activities(52,007) (63,143) (55,571)
Financing activities 
  
  
Net change in:     
Deposits48,611
 63,675
 78,347
Federal funds purchased and securities loaned or sold under agreements to repurchase7,024
 (4,000) (26,986)
Short-term borrowings8,538
 (4,014) (3,074)
Long-term debt:     
Proceeds from issuance53,486
 35,537
 43,670
Retirement of long-term debt(49,553) (51,849) (40,365)
Preferred stock: Proceeds from issuance
 2,947
 2,964
Common stock repurchased(12,814) (5,112) (2,374)
Cash dividends paid(5,700) (4,194) (3,574)
Other financing activities, net(397) (63) (73)
Net cash provided by financing activities49,195
 32,927
 48,535
Effect of exchange rate changes on cash and cash equivalents2,105
 240
 (597)
Net increase (decrease) in cash and cash equivalents9,696
 (11,615) 20,764
Cash and cash equivalents at January 1147,738
 159,353
 138,589
Cash and cash equivalents at December 31$157,434
 $147,738
 $159,353
Supplemental cash flow disclosures     
Interest paid$12,852
 $10,510
 $10,623
Income taxes paid3,297
 1,633
 2,326
Income taxes refunded(62) (590) (151)

See accompanying Notes to Consolidated Financial Statements.

103Bank of America 2017




Bank of America Corporation and Subsidiaries
Notes to Consolidated Financial Statements
NOTE 1 Summary of Significant Accounting Principles
Bank of America Corporation, a bank holding company and a financial holding company, provides a diverse range of financial services and products throughout the U.S. and in certain international markets. The term “the Corporation” as used herein may refer to Bank of America Corporation, individually, Bank of America Corporation and its subsidiaries, or certain of Bank of America Corporation’s subsidiaries or affiliates.
Principles of Consolidation and Basis of Presentation
The Consolidated Financial Statements include the accounts of the Corporation and its majority-owned subsidiaries and those variable interest entities (VIEs) where the Corporation is the primary beneficiary. Intercompany accounts and transactions have been eliminated. Results of operations of acquired companies are included from the dates of acquisition, and for VIEs, from the dates that the Corporation became the primary beneficiary. Assets held in an agency or fiduciary capacity are not included in the Consolidated Financial Statements. The Corporation accounts for investments in companies for which it owns a voting interest and for which it has the ability to exercise significant influence over operating and financing decisions using the equity method of accounting. These investments are included in other assets. Equity method investments are subject to impairment testing, and the Corporation’s proportionate share of income or loss is included in other income.
The preparation of the Consolidated Financial Statements in conformity with accounting principles generally accepted in the United States of America (GAAP) requires management to make estimates and assumptions that affect reported amounts and disclosures. RealizedActual results could materially differ from those estimates and assumptions. Certain prior-period amounts have been reclassified to conform to current period presentation.
On June 1, 2017, the Corporation completed the sale of its non-U.S. consumer credit card business to a third party. The Corporation has indemnified the purchaser for substantially all payment protection insurance (PPI) exposure above reserves assumed by the purchaser. The impact of the sale was an after-tax gain of $103 million, and is presented in the Consolidated Statement of Income as other income of $793 million and an income tax expense of $690 million. The income tax expense was related to gains on the derivatives used to hedge the currency risk of the net investment. Total cash proceeds from the sale were $10.9 billion. The assets of the business sold primarily included consumer credit card receivables of $9.8 billion and $9.2 billion at June 1, 2017 and December 31, 2016 and goodwill of $775 million at both of those period ends. This business was includedin All Other.
Change in Tax Law
On December 22, 2017, the President signed into law the Tax Cuts and Jobs Act (the Tax Act) which made significant changes to federal income tax law including, among other things, reducing the statutory corporate income tax rate to 21 percent from 35 percent and changing the taxation of the Corporation’s non-U.S. business activities. On the same date, the Securities and Exchange Commission issued Staff Accounting Bulletin No. 118 which
specifies, among other things, that reasonable estimates of the income tax effects of the Tax Act should be used, if determinable. The Corporation has accounted for the effects of the Tax Act using reasonable estimates based on currently available information and its interpretations thereof. This accounting may change due to, among other things, changes in interpretations the Corporation has made and the issuance of new tax or accounting guidance. GAAP requires that the effects of a change in tax rate from revaluing deferred tax assets and deferred tax liabilities be recognized upon enactment, resulting in $1.9 billion of estimated incremental income tax expense recognized in 2017. The change in tax rate also resulted in a downward valuation adjustment, primarily related to tax-advantaged energy investments, of $946 million recorded in other income.
Change in Accounting Method
GAAP requires that stock-based compensation awards be expensed over the service period (the period they are earned), based on their grant-date fair value. Awards to retirement-eligible employees have no future service requirement, and historically, the Corporation has deemed these awards to be authorized on the grant date, resulting in full recognition of the related expense at that time. Effective October 1, 2017, the Corporation changed its accounting method for determining when these awards are deemed authorized, changing from the grant date to the beginning of the year preceding the grant date when the incentive award plans are generally approved. As a result, the estimated value of the awards is now expensed ratably over the year preceding the grant date. The Corporation believes this change is a preferable method of accounting as it is consistent with the accounting method used by several peer institutions for similar awards and results in an improved pattern of expense recognition. 
Adoption of this change is voluntary and has been adopted retrospectively with all prior periods presented herein being restated. The change in accounting method resulted in a decrease in retained earnings of $635 million at January 1, 2015. All other effects of the change on the Consolidated Statement of Income and diluted earnings per share were not material for any period presented; additionally, the impact of the change in accounting method was not material to any interim periods. The change affected consolidated financial information and All Other; it did not affect the business segments.
The following Notes have been impacted by the change in accounting method: Note 13 – Shareholders’ Equity, Note 15 – Earnings Per Common Share, Note 16 – Regulatory Requirements and Restrictions and Note 18 – Stock-based Compensation Plans.
New Accounting PronouncementsStandards
Accounting for Share-based Compensation
Effective January 1, 2017, the Corporation adopted the new accounting standard that simplifies certain aspects of the accounting for share-based payment transactions, including income tax consequences, classification of awards as either equity or liabilities and classification on the statement of cash flows. Under this new accounting standard, all excess tax benefits and tax deficiencies on the delivery of share-based awards are recognized as discrete items in income tax expense or benefit in the Consolidated Statement of Income. Previously such amounts were recorded in shareholders’ equity. The adoption of this new accounting standard resulted in $236 million of tax benefits upon the delivery of share-settled awards in 2017.

Bank of America 2017104


Revenue Recognition
Effective January 1, 2018, the Corporation adopted the new accounting standard for recognizing revenue from contracts with customers. The new standard does not impact the timing or measurement of the Corporation’s revenue recognition asit is consistent with the Corporation’s existing accounting for contracts within the scope of the new standard. However, beginning prospectively in 2018, the Corporation’s presentation of certain costs, which are primarily related to underwriting activities, will be presented as operating expenses under the new standard rather than presented net in investment banking income, resulting in an expected increase to both line items of approximately $200 million for the year. The new accounting standard does not have a material impact on the Corporation’s consolidated financial position or results of operations and will not have a material impact on the disclosures in the Notes to the Consolidated Financial Statements.
Hedge Accounting
Effective January 1, 2018, the Corporation early adopted the new standard that simplifies and expands the ability to apply hedge accounting to certain risk management activities. The accounting standard does not have a material impact on the Corporation’s consolidated financial position or results of operations and will not have a material impact on the disclosures in the Notes to the Consolidated Financial Statements. The Corporation recognized an insignificant cumulative-effect adjustment to its January 1, 2018 opening retained earnings to reflect the impact of applying the new standard to certain outstanding hedge strategies, mainly related to fair value hedges of fixed-rate debt instruments.
Recognition and Measurement of Financial Assets and Financial Liabilities
The Financial Accounting Standards Board (FASB) issued a new accounting standard on recognition and measurement of financial instruments, including certain equity investments and financial liabilities recorded at fair value under the fair value option. Effective January 1, 2015, the Corporation early adopted the provisions related to debit valuation adjustments (DVA) on financial liabilities accounted for under the fair value option. The Corporation adopted the remaining provisions on January 1, 2018, which will not have a material impact on the Corporation’s consolidated financial position, results of operations or disclosures in the Notes to the Consolidated Financial Statements.
Tax Effects in Accumulated Other Comprehensive Income
The FASB issued a new accounting standard effective on January 1, 2019, with early adoption permitted, that addresses certain tax effects in accumulated other comprehensive income (OCI) related to the Tax Act. Under this new accounting standard, those tax effects, representing the difference between the newly enacted federal tax rate of 21 percent and the historical tax rate, may, at the entity’s election, be reclassified from accumulated OCI to retained earnings. The new accounting standard can be applied retrospectively to each period in which the effects of the change in federal tax rate are recognized or applied at the beginning of the period of adoption. The new accounting standard will not have a material impact on the Corporation’s consolidated financial position, results of operations or disclosures in the Notes to the Consolidated Financial Statements.
Lease Accounting
The FASB issued a new accounting standard effective on January 1, 2019 that requires substantially all leases to be recorded as assets and liabilities on the balance sheet. On January 5, 2018, the FASB issued an exposure draft proposing an amendment to the standard that, if approved, would permit companies the option to apply the provisions of the new lease standard either prospectively as of the effective date, without adjusting comparative periods presented, or using a modified retrospective transition applicable to all prior periods presented. The Corporation is in the process of reviewing its existing lease portfolios, including certain service contracts for embedded leases, to evaluate the impact of the standard on the consolidated financial statements, as well as the impact to regulatory capital and risk-weighted assets. The effect of the adoption will depend on the lease portfolio at the time of transition and the transition options ultimately available; however, the Corporation does not expect the new accounting standard to have a material impact on its consolidated financial position, results of operations or disclosures in the Notes to the Consolidated Financial Statements.
AccountingAllowance for Financial Instruments -- Credit Losses
The FASB issued aOn January 1, 2020, the Corporation adopted the new accounting standard effective on January 1, 2020, with early adoption permitted on January 1, 2019, that will requirerequires the earlier recognitionmeasurement of credit losses on loans and other financial instruments based on an expected loss model, replacing the incurred loss model that is currently in use. The standard also requires expanded credit quality disclosures, including credit quality indicators disaggregated by vintage. The Corporation is in the process of identifying and implementing required changes to loan loss estimation models and processes and evaluating the impact of this new accounting standard, which at the date of adoption is expected to increase the allowance for credit losses with a resulting negative adjustment to retained earnings.
Significant Accounting Principles
Cash and Cash Equivalents
Cash and cash equivalents include cashbe based on hand, cash itemsmanagement’s best estimate of lifetime ECL inherent in the processCorporation’s relevant financial assets. Upon adoption of collection, cash segregated under federal and other brokerage regulations, and amounts due from correspondent banks, the Federal Reserve Bank and certain non-U.S. central banks.
Securities Financing Agreements
Securities borrowed or purchased under agreements to resell and securities loaned or sold under agreements to repurchase (securities financing agreements) are treated as collateralized financing transactions except in instances where the transaction is required to be accounted for as individual sale and purchase transactions. Generally, these agreements are recorded at acquisition or sale price plus accrued interest, except for certain securities financing agreements thatnew accounting standard, the Corporation accountsrecorded 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, 2020and December 31, 2019 (prior to the adoption of the CECL accounting standard).
Table 42Allocation of the Allowance for Credit Losses by Product Type
AmountPercent of
Total
Percent of
Loans and
Leases
Outstanding (1)
AmountPercent of
Total
Percent of
Loans and
Leases
Outstanding
(1)
AmountPercent of
Total
Percent of
Loans and
Leases
Outstanding (1)
(Dollars in millions)December 31, 2020January 1, 2020December 31, 2019
Allowance for loan and lease losses      
Residential mortgage$459 2.44 %0.21 %$212 1.72 %0.09 %$325 3.45 %0.14 %
Home equity399 2.12 1.16 228 1.84 0.57 221 2.35 0.55 
Credit card8,420 44.79 10.70 6,809 55.10 6.98 3,710 39.39 3.80 
Direct/Indirect consumer752 4.00 0.82 566 4.58 0.62 234 2.49 0.26 
Other consumer41 0.22 n/m55 0.45 n/m52 0.55 n/m
Total consumer10,071 53.57 2.35 7,870 63.69 1.69 4,542 48.23 0.98 
U.S. commercial (2)
5,043 26.82 1.55 2,723 22.03 0.84 3,015 32.02 0.94 
Non-U.S. commercial1,241 6.60 1.37 668 5.41 0.64 658 6.99 0.63 
Commercial real estate2,285 12.15 3.79 1,036 8.38 1.65 1,042 11.07 1.66 
Commercial lease financing162 0.86 0.95 61 0.49 0.31 159 1.69 0.80 
Total commercial8,731 46.43 1.77 4,488 36.31 0.88 4,874 51.77 0.96 
Allowance for loan and lease losses18,802 100.00 %2.04 12,358 100.00 %1.27 9,416 100.00 %0.97 
Reserve for unfunded lending commitments1,878 1,123 813  
Allowance for credit losses$20,680 $13,481 $10,229 
(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. Changes in the fair value of securities financing agreements that areConsumer loans accounted for under the fair value option are recordedinclude 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.
(2)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
Net charge-offs for 2020 were $4.1 billion compared to $3.6 billion in trading account profits2019 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 incurred losses. For more information on 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 Statement of Income.Financial Statements.

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Table 43Allowance for Credit Losses
(Dollars in millions)20202019
Allowance for loan and lease losses, January 1$12,358 $9,601 
Loans and leases charged off
Residential mortgage(40)(93)
Home equity(58)(429)
Credit card(2,967)(3,535)
Direct/Indirect consumer(372)(518)
Other consumer(307)(249)
Total consumer charge-offs(3,744)(4,824)
U.S. commercial (1)
(1,163)(650)
Non-U.S. commercial(168)(115)
Commercial real estate(275)(31)
Commercial lease financing(69)(26)
Total commercial charge-offs(1,675)(822)
Total loans and leases charged off(5,419)(5,646)
Recoveries of loans and leases previously charged off
Residential mortgage70 140 
Home equity131 787 
Credit card618 587 
Direct/Indirect consumer250 309 
Other consumer23 15 
Total consumer recoveries1,092 1,838 
U.S. commercial (2)
178 122 
Non-U.S. commercial13 31 
Commercial real estate5 
Commercial lease financing10 
Total commercial recoveries206 160 
Total recoveries of loans and leases previously charged off1,298 1,998 
Net charge-offs(4,121)(3,648)
Provision for loan and lease losses10,565 3,574 
Other (111)
Allowance for loan and lease losses, December 3118,802 9,416 
Reserve for unfunded lending commitments, January 11,123 797 
Provision for unfunded lending commitments755 16 
Reserve for unfunded lending commitments, December 311,878 813 
Allowance for credit losses, December 31$20,680 $10,229 
Loan and allowance ratios:
Loans and leases outstanding at December 31 (3)
$921,180 $975,091 
Allowance for loan and lease losses as a percentage of total loans and leases outstanding at December 31 (3)
2.04 %0.97 %
Consumer allowance for loan and lease losses as a percentage of total consumer loans and leases outstanding at December 31 (4)
2.35 0.98 
Commercial allowance for loan and lease losses as a percentage of total commercial loans and leases outstanding at December 31 (5)
1.77 0.96 
Average loans and leases outstanding (3)
$974,281 $951,583 
Annualized net charge-offs as a percentage of average loans and leases outstanding (3)
0.42 %0.38 %
Allowance for loan and lease losses as a percentage of total nonperforming loans and leases at December 31380 265 
Ratio of the allowance for loan and lease losses at December 31 to net charge-offs4.56 2.58 
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)
$9,854 $4,151 
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)
181 %148 %
(1)Includes U.S. small business commercial charge-offs of $321 million in 2020 compared to $320 million in 2019.
(2)Includes U.S. small business commercial recoveries of $54 million in 2020 compared to $48 million in 2019.
(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.
10577 Bank of America


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 82.
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 25.
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 requirements and monitors the effective challenge in the model validation process across the Corporation.
Interest Rate Risk
Interest rate risk represents exposures to instruments whose values vary with the level or volatility of interest rates. These instruments include, but are not limited to, loans, debt securities, certain trading-related assets and liabilities, deposits, borrowings and derivatives. Hedging instruments used to mitigate these risks include derivatives such as options, futures, forwards and swaps.
Foreign Exchange Risk
Foreign exchange risk represents exposures to changes in the values of current holdings and future cash flows denominated in currencies other than the U.S. dollar. The types of instruments exposed to this risk include investments in non-U.S. subsidiaries, foreign currency-denominated loans and securities, future cash flows in foreign currencies arising from foreign exchange transactions, foreign currency-denominated debt and various foreign exchange derivatives whose values fluctuate with changes in the level or volatility of currency exchange rates or non-U.S. interest rates. Hedging instruments used to mitigate this risk include foreign exchange options, currency swaps, futures, forwards, and foreign currency-denominated debt and deposits.
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 84.
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 further exacerbated if expected hedging or pricing correlations are compromised by disproportionate demand or lack of demand for certain instruments. We utilize various risk mitigating techniques as discussed in more detail in Trading Risk Management.
Trading Risk Management
To evaluate risks in our trading activities, we focus on the actual and potential volatility of revenues generated by individual positions as well as portfolios of positions. Various techniques and procedures are utilized to enable the most complete understanding of these risks. Quantitative measures of market risk are evaluated on a daily basis from a single position to the portfolio of the Corporation. These measures include sensitivities of positions to various market risk factors, such as the potential impact on revenue from a one basis point change in interest rates, and statistical measures utilizing both actual and hypothetical market moves, such as VaR and stress testing. Periods of extreme market stress influence the reliability of these techniques to varying degrees. Qualitative evaluations of market risk utilize the suite of quantitative risk measures while understanding each of their respective limitations. Additionally, risk managers independently evaluate the risk of the portfolios under the current market environment and potential future environments.
VaR is a common statistic used to measure market risk as it allows the aggregation of market risk factors, including the effects of portfolio diversification. A VaR model simulates the value of a portfolio under a range of scenarios in order to generate a distribution of potential gains and losses. VaR represents the loss a portfolio is not expected to exceed more than a certain number of times per period, based on a specified holding period, confidence level and window of historical data. We use one VaR model consistently across the trading portfolios and it uses a historical simulation approach based on a three-year window of historical data. Our primary VaR statistic is equivalent to a 99 percent confidence level, which means that for a VaR with a one-day holding period, there should not be losses in excess of VaR, on average, 99 out of 100 trading days.
Within any VaR model, there are significant and numerous assumptions that will differ from company to company. The accuracy of a VaR model depends on the availability and quality of historical data for each of the risk factors in the portfolio. A VaR model may require additional modeling assumptions for new products that do not have the necessary historical market data or for less liquid positions for which accurate daily prices
are not consistently available. For positions with insufficient historical data for the VaR calculation, the process for establishing an appropriate proxy is based on fundamental and statistical analysis of the new product or less liquid position. This analysis identifies reasonable alternatives that replicate both the expected volatility and correlation to other market risk factors that the missing data would be expected to experience.
VaR may not be indicative of realized revenue volatility as changes in market conditions or in the composition of the portfolio can have a material impact on the results. In particular, the historical data used for the VaR calculation might indicate higher or lower levels of portfolio diversification than will be experienced. In order for the VaR model to reflect current market conditions, we update the historical data underlying our VaR model on a weekly basis, or more frequently during periods of market stress, and regularly review the assumptions underlying the model. A minor portion of risks related to our trading positions is not included in VaR. These risks are reviewed as part of our ICAAP. For more information regarding ICAAP, see Capital Management on page 50.
Global Risk Management continually reviews, evaluates and enhances our VaR model so that it reflects the material risks in our trading portfolio. Changes to the VaR model are reviewed and approved prior to implementation and any material changes are reported to management through the appropriate management committees.
Trading limits on quantitative risk measures, including VaR, are independently set by Global Markets Risk Management and reviewed on a regular basis so that trading limits remain relevant and within our overall risk appetite for market risks. Trading limits are reviewed in the context of market liquidity, volatility and strategic business priorities. Trading limits are set at both a granular level to allow for extensive coverage of risks as well as at aggregated portfolios to account for correlations among risk factors. All trading limits are approved at least annually. Approved trading limits are stored and tracked in a centralized limits management system. Trading limit excesses are communicated to management for review. Certain quantitative market risk measures and corresponding limits have been identified as critical in the Corporation’s policyRisk Appetite Statement. These risk appetite limits are reported on a daily basis and are approved at least annually by the ERC and the Board.
In periods of market stress, Global Markets senior leadership communicates daily to discuss losses, key risk positions and any limit excesses. As a result of this process, the businesses may selectively reduce risk.
Table 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
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.
Table 44Market Risk VaR for Trading Activities
20202019
(Dollars in millions)Year
End
Average
High (1)
Low (1)
Year
End
Average
High (1)
Low (1)
Foreign exchange$8 $7 $25 $2 $$$13 $
Interest rate30 19 39 7 25 24 49 14 
Credit79 58 91 25 26 23 32 16 
Equity20 24 162 12 29 22 33 14 
Commodities4 6 12 3 31 
Portfolio diversification(72)(61)  (47)(49)— — 
Total covered positions portfolio69 53 171 27 41 32 47 24 
Impact from less liquid exposures52 27   — — — 
Total covered positions and less liquid trading positions portfolio121 80 169 30 41 35 53 27 
Fair value option loans52 52 84 7 10 13 
Fair value option hedges11 13 17 9 10 10 17 
Fair value option portfolio diversification(17)(24)  (9)(10)— — 
Total fair value option portfolio46 41 86 9 10 16 
Portfolio diversification(4)(15)  (5)(7)— — 
Total market-based portfolio$163 $106 171 32 $45 $38 56 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.
bac-20201231_g3.jpg
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 45Average Market Risk VaR for Trading Activities – 99 percent and 95 percent VaR Statistics
20202019
(Dollars in millions)99 percent95 percent99 percent95 percent
Foreign exchange$7 $4 $$
Interest rate19 9 24 15 
Credit58 18 23 15 
Equity24 13 22 11 
Commodities6 3 
Portfolio diversification(61)(26)(49)(29)
Total covered positions portfolio53 21 32 18 
Impact from less liquid exposures27 2 
Total covered positions and less liquid trading positions portfolio80 23 35 20 
Fair value option loans52 13 10 
Fair value option hedges13 7 10 
Fair value option portfolio diversification(24)(8)(10)(5)
Total fair value option portfolio41 12 10 
Portfolio diversification(15)(6)(7)(5)
Total market-based portfolio$106 $29 $38 $21 
Backtesting
The accuracy of the VaR methodology is evaluated by backtesting, which compares the daily VaR results, utilizing a one-day holding period, against a comparable subset of trading revenue. A backtesting excess occurs when a trading loss exceeds the VaR for the corresponding day. These excesses are evaluated to understand the positions and market moves that produced the trading loss with a goal to ensure that the VaR methodology accurately represents those losses. We expect the frequency of trading losses in excess of VaR to be in line with the confidence level of the VaR statistic being tested. For example, with a 99 percent confidence level, we expect one trading loss in excess of VaR every 100 days or between two to three trading losses in excess of VaR over the course of a year. The number of backtesting excesses observed can differ from the statistically expected number of excesses if the current level of market volatility is materially different than the level of market volatility that existed during the three years of historical data used in the VaR calculation.
The trading revenue used for backtesting is defined by regulatory agencies in order to most closely align with the VaR component of the regulatory capital calculation. This revenue differs from total trading-related revenue in that it excludes revenue from trading activities that either do not generate market risk or the market risk cannot be included in VaR. Some examples of the types of revenue excluded for backtesting are fees, commissions, reserves, net interest income and intra-day trading revenues.
We conduct daily backtesting on the VaR results used for regulatory capital calculations as well as the VaR results for key legal entities, regions and risk factors. These results are reported to senior market risk management. Senior management regularly reviews and evaluates the results of these tests.
During 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.
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.
bac-20201231_g4.jpg
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 consolidated capital and liquidity planning. For more information, see Managing Risk on page 47.
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 monitormanage interest rate risk so that movements in interest rates do not significantly adversely affect earnings and capital.
Table 46 presents the market valuespot and 12-month forward rates used in our baseline forecasts at December 31, 2020 and 2019.
Table 46Forward Rates
December 31, 2020
 Federal
Funds
Three-month
LIBOR
10-Year
Swap
Spot rates0.25 %0.24 %0.93 %
12-month forward rates0.25 0.19 1.06 
December 31, 2019
Spot rates1.75 %1.91 %1.90 %
12-month forward rates1.50 1.62 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 principal amount loaned under resale agreementscurrent 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 obtain collateral from or return collateral pledged to counterparties when appropriate. Securities financing agreements do not create
material credit riskdown-rate scenarios primarily due to these collateral provisions; therefore, an allowance for loan losses is unnecessary.
In transactions wherecontinued deposit growth invested in long-term securities. We continue to be asset sensitive to a parallel upward move in interest rates with the Corporation acts asmajority of that impact coming from the lender in a securities lending agreement and receives securities that can be pledged or sold as collateral, it recognizes an asset onshort end of 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, 2017 and 2016,yield curve. Additionally, higher interest rates impact the fair value of this collateral was $561.9 billiondebt securities and, $452.1 billion, of which $476.1 billionaccordingly, for debt securities classified as AFS, may adversely affect accumulated OCI and $372.0 billion was sold or repledged. The primary source of this collateralthus capital levels under the Basel 3 capital rules. Under instantaneous upward parallel shifts, the near-term adverse impact to Basel 3 capital is securities borrowed or purchased under agreementsreduced over time by offsetting positive impacts to resell.net interest income. For more information on Basel 3, see Capital Management – Regulatory Capital on page 51.
Table 47Estimated Banking Book Net Interest Income Sensitivity to Curve Changes
Short
Rate (bps)
Long
Rate (bps)
December 31
(Dollars in millions)20202019
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— 6,321 2,641 
Long-end
instantaneous change
— -25 (1,686)(653)
Steepeners  
Short-end
instantaneous change
-25 — (1,084)(844)
Long-end
instantaneous change
— +1004,333 1,561 
The Corporation also pledges company-ownedsensitivity analysis in Table 47 assumes that we take no action in response to these rate shocks and does not assume any change in other macroeconomic variables normally correlated with changes in interest rates. As part of our ALM activities, we use securities, certain residential mortgages, and loansinterest 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 collateralan efficient tool to manage our interest rate and foreign exchange risk. We use derivatives to hedge the variability in transactions that include repurchase agreements, securities loaned, publiccash flows or changes in fair value on our balance sheet due to interest rate 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 counterpartiesforeign exchange components. For more information on our hedging
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activities, see Note 3 – Derivatives to the transactions, is parenthetically disclosed on the Consolidated Balance Sheet.Financial Statements.
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 assetsOur interest rate contracts are included on the Consolidated Balance Sheet in Assets of Consolidated VIEs.
generally non-leveraged generic interest rate and foreign exchange basis swaps, options, futures and forwards. In addition, we use foreign exchange contracts, including cross-currency interest rate swaps, foreign currency futures contracts, foreign currency forward contracts and options to mitigate the Corporation obtains collateral in connectionforeign exchange risk associated 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 or quoted market prices for similarforeign currency-denominated assets and liabilities. If these market prices
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 not available, fair values are estimated based on dealer quotes, pricing models, discounted cash flow methodologies, or similar techniques where the determinationcurrent assessment of fair value may require significant management judgment or estimation. Realized gainseconomic and losses are recorded on a trade-date basis. Realized and unrealized gains and losses are recognized in trading account profits.
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
(referred to as other risk management activities). The Corporation managesfinancial 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 sensitivity predominantlyswaps increased while pay-fixed interest swaps decreased, primarily driven by lower swap rates on hedges of U.S. dollar long-term debt.
Table 48Asset and Liability Management Interest Rate and Foreign Exchange Contracts
December 31, 2020
Expected Maturity
(Dollars in millions, average estimated duration in years)Fair
Value
Total20212022202320242025ThereafterAverage
Estimated
Duration
Receive-fixed interest rate swaps (1)
$14,885        8.08 
Notional amount��$269,015 $11,050 $20,908 $30,654 $31,317 $32,898 $142,188 
Weighted-average fixed-rate1.54 %3.25 %0.91 %1.48 %1.17 %1.07 %1.69 %
Pay-fixed interest rate swaps (1)
(5,502)       6.52 
Notional amount $252,698 $7,562 $21,667 $24,671 $24,406 $32,052 $142,340  
Weighted-average fixed-rate0.89 %0.57 %0.10 %1.28 %0.86 %0.68 %1.00 %
Same-currency basis swaps (2)
(235)        
Notional amount $223,659 $18,769 $12,245 $9,747 $22,737 $28,222 $131,939  
Foreign exchange basis swaps (1, 3, 4)
(1,014)  
Notional amount 112,465 27,424 16,038 8,066 3,819 4,446 52,672  
Foreign exchange contracts (1, 4, 5)
349  
Notional amount (6)
(42,490)(69,299)2,841 2,505 4,735 4,369 12,359 
Futures and forward rate contracts47 
Notional amount14,255 14,255      
Option products   
Notional amount 17   17     
Net ALM contracts$8,530         
83 Bank of America


Table 48Asset and Liability Management Interest Rate and Foreign Exchange Contracts (continued)
  December 31, 2019
  Expected Maturity
(Dollars in millions, average estimated duration in years)Fair
Value
Total20202021202220232024ThereafterAverage
Estimated
Duration
Receive-fixed interest rate swaps (1)
$12,370        6.47 
Notional amount $215,123 $16,347 $14,642 $21,616 $36,356 $21,257 $104,905 
Weighted-average fixed-rate2.68 %2.68 %3.17 %2.48 %2.36 %2.55 %2.79 %
Pay-fixed interest rate swaps (1)
(2,669)       6.99 
Notional amount $69,586 $4,344 $2,117 $— $13,993 $8,194 $40,938  
Weighted-average fixed-rate2.36 %2.16 %2.15 %— %2.52 %2.26 %2.35 %
Same-currency basis swaps (2)
(290)        
Notional amount $152,160 $18,857 $18,590 $4,306 $2,017 $14,567 $93,823  
Foreign exchange basis swaps (1, 3, 4)
(1,258)  
Notional amount 113,529 23,639 24,215 14,611 7,111 3,521 40,432  
Foreign exchange contracts (1, 4, 5)
414  
Notional amount (6)
(53,106)(79,315)4,539 2,674 2,340 4,432 12,224 
Option products—   
Notional amount 15 — — — 15 — —  
Net ALM contracts$8,567         
(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 50.
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 appropriate Board-level committees in support of Global Compliance and Operational Risk’s responsibilities for conducting independent oversight of our compliance and operational risk management activities. The Board provides oversight of compliance risk through its Audit Committee and the ERC, and operational risk through the ERC.
A key operational risk facing the Corporation is information security, which includes cybersecurity. Cybersecurity 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 integrity of our, 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 withinternal 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.
The Corporation manages reputational risk 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
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 risk is 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.
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
85 Bank of America


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.
The Corporation's estimate of lifetime ECL includes the use of derivatives. Derivatives utilized byquantitative models that incorporate forward-looking macroeconomic scenarios that are applied over the contractual life of the loan portfolios, adjusted for expected prepayments and borrower-controlled extension options. 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 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 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.
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, factors the Corporation considers include swaps, futureschanges in lending policies and forward settlement contracts,procedures, business conditions, the nature and option contracts.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 others. Further, the Corporation considers the inherent uncertainty in quantitative models that are built on historical data.
All derivatives are recordedThe 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. 
As described above, the process to determine the allowance for credit losses 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
and Leases and Allowance for Credit Losses to the Consolidated Balance Sheet atFinancial 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 taking into considerationmeasurements of financial instruments and MSRs based on the effectsthree-level fair value hierarchy in the accounting standards.
The fair values of legally enforceable master netting agreementsassets 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 allowinformation 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 Corporation to settle positive and negative positions and offset cash collateral heldvaluation process. In keeping with the same counterparty on a net basis. For exchange-traded contracts,prudent application of estimates and management judgment in determining the fair value of assets and liabilities, we have in place various processes and controls that include: a model validation policy that requires review and approval of quantitative models used for deal pricing, financial statement 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 quoted market prices in active or inactive markets or is derived from observable market- based pricing parameters, similarvaluation techniques that require inputs that are both unobservable and are significant to those applied to over-the-counter (OTC) derivatives. For non-exchange traded contracts,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 based on dealer quotes,determined using pricing models, discounted cash flow methodologies or similar techniques for which the determination of fair value may requirerequires significant management judgment or estimation.
Valuations of derivative assets and liabilities reflect the valueLevel 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 instrument including counterparty credit risk. Thesefair 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 also takeof the assets and
Bank of America 86


liabilities became unobservable or observable, respectively, in the current marketplace. For more information on transfers into accountand out of Level 3 during 2020, 2019 and 2018, see Note 20 – Fair Value Measurements to the Corporation’s own credit standing.Consolidated Financial Statements.
Trading DerivativesAccrued Income Taxes and Other Risk Management ActivitiesDeferred Tax Assets
Derivatives held for trading purposes are included in derivativeAccrued income taxes, reported as a component of either other assets or derivativeaccrued 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 fair value included in trading account profits.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.
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 pertainsSee Note 19 – Income Taxes to an item that is reported at fair value through earnings so that the effect of measuring the derivative instrument and the asset or liability to which the risk exposure pertains will offset in the Consolidated StatementFinancial Statements for a table of Incomesignificant tax attributes and additional information. For more information, see page 16 under Part I. Item 1A. Risk Factors – Regulatory, Compliance and Legal.
Goodwill and Intangible Assets
The nature of and accounting for goodwill and intangible assets are discussed in Note 1 – Summary of Significant Accounting Principles, and Note 7 – Goodwill and Intangible Assets to the extent effective. The changes inConsolidated Financial Statements.

We completed our annual goodwill impairment test as of June 30, 2020. In performing that test, we compared the fair value of derivatives that serveeach reporting unit to mitigate certain risks associated with mortgage servicing rights (MSRs), interest rate lock commitments (IRLCs) and first mortgage loans held-for-sale (LHFS) that are originatedits estimated carrying value as measured by the Corporation are recorded in mortgage banking income. Changes inallocated equity. We estimated the fair value of derivatives that serveeach reporting unit based on the income approach (which utilizes the present value of cash flows to mitigateestimate 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 foreign currency risk are includeduncertainty in other income. Credit derivatives are also used by the Corporationcash flow forecasts, the financial markets and industries similar to mitigateeach of the risk associated with various credit exposures. The changes inreporting units.
Under the market multiplier approach, we estimated the fair value of these derivatives are includedthe individual reporting units utilizing various market multiples, primarily various pricing multiples, from comparable publicly-traded companies in other income.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.
Derivatives Used For Hedge Accounting Purposes (Accounting Hedges)
For accounting hedges,Based on the Corporation formally documents at inception all relationships between hedging instruments and hedged items, as well asresults of the risk management objectives and strategies for undertaking various accounting hedges. Additionally, the Corporation primarily uses regression analysis at the inception of a hedge and fortest, we determined that each reporting period thereafterunit’s estimated fair value exceeded its respective carrying value and that the goodwill assigned to assess whethereach reporting unit was not impaired. The fair values of the derivative used in an accounting hedge transaction is expectedreporting units as a percentage of their carrying values ranged from 109 percent to be213 percent. It currently remains difficult to estimate the future economic impacts related to the pandemic. If economic and has been highly effective in offsetting changesmarket conditions (both in the fair value or cash flows ofU.S. and internationally) deteriorate, our reporting units could be negatively impacted, which could change our key assumptions and related estimates and may result in a hedged item or forecasted transaction. The Corporation discontinues hedge accounting when it is determined that a derivative is not expectedfuture impairment charge.
Certain Contingent Liabilities
For more information on the complex judgments associated with certain contingent liabilities, see Note 12 – Commitments and Contingencies 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.Consolidated Financial Statements.

87 Bank of America


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)20202019201820172016
Reconciliation of average shareholders’ equity to average tangible shareholders’ equity and average tangible common shareholders’ equity     
Shareholders’ equity$267,309 $267,889 $264,748 $271,289 $265,843 
Goodwill(68,951)(68,951)(68,951)(69,286)(69,750)
Intangible assets (excluding MSRs)(1,862)(1,721)(2,058)(2,652)(3,382)
Related deferred tax liabilities821 773 906 1,463 1,644 
Tangible shareholders’ equity$197,317 $197,990 $194,645 $200,814 $194,355 
Preferred stock(23,624)(23,036)(22,949)(24,188)(24,656)
Tangible common shareholders’ equity$173,693 $174,954 $171,696 $176,626 $169,699 
Reconciliation of year-end shareholders’ equity to year-end tangible shareholders’ equity and year-end tangible common shareholders’ equity     
Shareholders’ equity$272,924 $264,810 $265,325 $267,146 $266,195 
Goodwill(68,951)(68,951)(68,951)(68,951)(69,744)
Intangible assets (excluding MSRs)(2,151)(1,661)(1,774)(2,312)(2,989)
Related deferred tax liabilities920 713 858 943 1,545 
Tangible shareholders’ equity$202,742 $194,911 $195,458 $196,826 $195,007 
Preferred stock(24,510)(23,401)(22,326)(22,323)(25,220)
Tangible common shareholders’ equity$178,232 $171,510 $173,132 $174,503 $169,787 
Reconciliation of year-end assets to year-end tangible assets     
Assets$2,819,627 $2,434,079 $2,354,507 $2,281,234 $2,188,067 
Goodwill(68,951)(68,951)(68,951)(68,951)(69,744)
Intangible assets (excluding MSRs)(2,151)(1,661)(1,774)(2,312)(2,989)
Related deferred tax liabilities920 713 858 943 1,545 
Tangible assets$2,749,445 $2,364,180 $2,284,640 $2,210,914 $2,116,879 
(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 31.
Table 50
Quarterly Reconciliations to GAAP Financial Measures (1)
2020 Quarters2019 Quarters
(Dollars in millions)FourthThirdSecondFirstFourthThirdSecondFirst
Reconciliation of average shareholders’ equity to average tangible shareholders’ equity and average tangible common shareholders’ equity        
Shareholders’ equity$271,020 $267,323 $266,316 $264,534 $266,900 $270,430 $267,975 $266,217 
Goodwill(68,951)(68,951)(68,951)(68,951)(68,951)(68,951)(68,951)(68,951)
Intangible assets (excluding MSRs)(2,173)(1,976)(1,640)(1,655)(1,678)(1,707)(1,736)(1,763)
Related deferred tax liabilities910 855 790 728 730 752 770 841 
Tangible shareholders’ equity$200,806 $197,251 $196,515 $194,656 $197,001 $200,524 $198,058 $196,344 
Preferred stock(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$272,924 $268,850 $265,637 $264,918 $264,810 $268,387 $271,408 $267,010 
Goodwill(68,951)(68,951)(68,951)(68,951)(68,951)(68,951)(68,951)(68,951)
Intangible assets (excluding MSRs)(2,151)(2,185)(1,630)(1,646)(1,661)(1,690)(1,718)(1,747)
Related deferred tax liabilities920 910 789 790 713 734 756 773 
Tangible shareholders’ equity$202,742 $198,624 $195,845 $195,111 $194,911 $198,480 $201,495 $197,085 
Preferred stock(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$2,819,627 $2,738,452 $2,741,688 $2,619,954 $2,434,079 $2,426,330 $2,395,892 $2,377,164 
Goodwill(68,951)(68,951)(68,951)(68,951)(68,951)(68,951)(68,951)(68,951)
Intangible assets (excluding MSRs)(2,151)(2,185)(1,630)(1,646)(1,661)(1,690)(1,718)(1,747)
Related deferred tax liabilities920 910 789 790 713 734 756 773 
Tangible assets$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 31.

Bank of America 88






Table IOutstanding Loans and Leases
  December 31
(Dollars in millions)20202019201820172016
Consumer     
Residential mortgage$223,555 $236,169 $208,557 $203,811 $191,797 
Home equity34,311 40,208 48,286 57,744 66,443 
Credit card78,708 97,608 98,338 96,285 92,278 
Non-U.S. credit card — — — 9,214 
Direct/Indirect consumer (1)
91,363 90,998 91,166 96,342 95,962 
Other consumer (2)
124 192 202 166 626 
Total consumer loans excluding loans accounted for under the fair value option428,061 465,175 446,549 454,348 456,320 
Consumer loans accounted for under the fair value option (3)
735 594 682 928 1,051 
Total consumer428,796 465,769 447,231 455,276 457,371 
Commercial
U.S. commercial288,728 307,048 299,277 284,836 270,372 
Non-U.S. commercial90,460 104,966 98,776 97,792 89,397 
Commercial real estate (4)
60,364 62,689 60,845 58,298 57,355 
Commercial lease financing17,098 19,880 22,534 22,116 22,375 
456,650 494,583 481,432 463,042 439,499 
U.S. small business commercial (5)
36,469 15,333 14,565 13,649 12,993 
Total commercial loans excluding loans accounted for under the fair value option493,119 509,916 495,997 476,691 452,492 
Commercial loans accounted for under the fair value option (3)
5,946 7,741 3,667 4,782 6,034 
Total commercial499,065 517,657 499,664 481,473 458,526 
Less: Loans of business held for sale (6)
 — — — (9,214)
Total loans and leases$927,861 $983,426 $946,895 $936,749 $906,683 
Fair value hedges are used to protect against changes in the fair value(1)Includes primarily auto and specialty lending loans and leases of the Corporation’s assets$46.4 billion, $50.4 billion, $50.1 billion, $52.4 billion and liabilities that are attributable to interest rate or foreign exchange volatility. Changes in the fair value$50.7 billion, U.S. securities-based lending loans of derivatives designated as fair value hedges are recorded in earnings, together$41.1 billion, $36.7 billion, $37.0 billion, $39.8 billion and in the same income statement line item with changes in the fair value$40.1 billion and non-U.S. consumer loans of the related hedged item. If a derivative instrument in a fair value hedge is terminated or the hedge designation removed, the previous adjustments to the carrying value of the hedged asset or liability are subsequently accounted for in the same manner as other components of the carrying value of that asset or liability. For interest-earning assets$3.0 billion, $2.8 billion, $2.9 billion, $3.0 billion and interest-bearing liabilities, such adjustments are amortized to earnings over the remaining life of the respective asset or liability.$3.0 billion at December 31, 2020, 2019, 2018, 2017 and 2016, respectively.
Cash flow hedges are used primarily to minimize the variability in cash flows of assets and liabilities, or forecasted transactions caused by interest rate or foreign exchange rate fluctuations. Changes in the fair value of derivatives used in cash flow hedges are recorded in accumulated OCI and are reclassified into the line item in the income statement in which the hedged item is recorded in the same period the hedged item affects earnings. Hedge ineffectiveness and gains and losses on the component of a derivative excluded in assessing hedge effectiveness are recorded in the same income statement line 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 fair value of derivatives designated as net investment hedges of foreign operations, to the extent effective, are recorded as a component of accumulated OCI.
Securities
Debt securities are reported on the Consolidated Balance Sheet at their trade date. Their classification is dependent on the purpose for which the assets were acquired. Debt securities purchased for use in the Corporation’s trading activities are reported in trading account assets at fair value with unrealized gains and losses included in trading account profits. (2)Substantially all of other debt securities purchased are used in the Corporation’s assetconsumer at December 31, 2020, 2019, 2018 and liability management (ALM) activities and are reported on the Consolidated Balance Sheet as either debt securities carried2017 is consumer overdrafts. Other consumer at fair value or as debt securities held-to-maturity (HTM). Debt securities carried at fair value are either available-for-sale (AFS) securities with unrealized gains and losses net-of-tax included in accumulated OCI or carried at fair value with unrealized gains and losses reported in other income. Debt securities HTM, which are certain debt securities that management has the intent and ability to hold to maturity, are reported at amortized cost.December 31, 2016 also includes consumer finance loans of $465 million.
The Corporation regularly evaluates each AFS and HTM debt security where the value has declined below amortized cost to assess whether the decline in fair value is other than temporary. In determining whether an impairment is other than temporary, the Corporation considers the severity and duration of the decline in fair value, the length of time expected for recovery, the financial condition of the issuer, and other qualitative factors, as well as whether the Corporation either plans to sell the security or it is more-likely-than-not that it will be required to sell the security before recovery of the amortized cost. For AFS debt securities the Corporation intends to hold, an analysis is performed to determine how much of the decline in fair value is related to the issuer’s credit and how much is related to market factors (e.g., interest rates). If any of the decline in fair value is due to credit, an other-than-temporary impairment (OTTI) loss is recognized in the Consolidated Statement of Income for that amount. If any of the decline in fair value is related to market factors, that amount is recognized in accumulated OCI. In certain instances, the credit
loss may exceed the total decline in fair value, in which case, the difference is due to market factors and is recognized as an unrealized gain in accumulated OCI. If the Corporation intends to sell or believes it is more-likely-than-not that it will be required to sell the debt security, it is written down to fair value as an OTTI loss.
Interest on debt securities, including amortization of premiums and accretion of discounts, is included in interest income. Premiums and discounts are amortized or accreted to interest income at a constant effective yield over the contractual lives of the securities. Realized gains and losses from the sales of debt securities are determined using the specific identification method.
Marketable equity securities are classified based on management’s intention on the date of purchase and recorded on the Consolidated Balance Sheet as of the trade date. Marketable equity securities that are bought and held principally for the purpose of resale in the near term are classified as trading and are carried at fair value with unrealized gains and losses included in trading account profits. Other marketable equity securities are accounted for as AFS and classified in other assets. All AFS marketable equity securities are carried at fair value with net unrealized gains and losses included in accumulated OCI, net-of-tax. If there is an other-than-temporary decline in the fair value of any individual AFS marketable equity security, the cost basis is reduced and the Corporation reclassifies the associated net unrealized loss out of accumulated OCI with a corresponding charge to other income. Dividend income on AFS marketable equity securities is included in other income. Realized gains and losses on the sale of all AFS marketable equity securities, which are recorded in other income, are determined using the specific identification method.
Loans and Leases
Loans, with the exception of(3)Consumer loans accounted for under the fair value option are measuredinclude 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 historical costDecember 31, 2020, 2019, 2018, 2017 and reported at their outstanding principal balances net of any unearned income, charge-offs, unamortized deferred fees and costs on originated2016, respectively. Commercial loans andaccounted for purchased loans, net of any unamortized premiums or discounts. Loan origination fees and certain direct origination costs are deferred and recognized as adjustments to interest income over the lives of the related loans. Unearned income, discounts and premiums are amortized to interest income using a level yield methodology. The Corporation elects to account for certain consumer and commercial loans under the fair value option with changesinclude 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.
(4)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.
(5)Includes card-related products.
(6)Represents non-U.S. credit card loans, which were included in assets of business held for sale on the Consolidated Balance Sheet.

89 Bank of America


Table II
Nonperforming Loans, Leases and Foreclosed Properties (1)
 December 31
(Dollars in millions)20202019201820172016
Consumer     
Residential mortgage$2,005 $1,470 $1,893 $2,476 $3,056 
Home equity649 536 1,893 2,644 2,918 
Direct/Indirect consumer71 47 56 46 28 
Other consumer — — — 
Total consumer (2)
2,725 2,053 3,842 5,166 6,004 
Commercial   
U.S. commercial1,243 1,094 794 814 1,256 
Non-U.S. commercial418 43 80 299 279 
Commercial real estate404 280 156 112 72 
Commercial lease financing87 32 18 24 36 
 2,152 1,449 1,048 1,249 1,643 
U.S. small business commercial75 50 54 55 60 
Total commercial (3)
2,227 1,499 1,102 1,304 1,703 
Total nonperforming loans and leases4,952 3,552 4,944 6,470 7,707 
Foreclosed properties164 285 300 288 377 
Total nonperforming loans, leases and foreclosed properties$5,116 $3,837 $5,244 $6,758 $8,084 
(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 million and $1.2 billion at December 31, 2020, 2019, 2018, 2017 and 2016, respectively.
(2)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.
(3)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)
 December 31
(Dollars in millions)20202019201820172016
Consumer     
Residential mortgage (2)
$762 $1,088 $1,884 $3,230 $4,793 
Credit card903 1,042 994 900 782 
Non-U.S. credit card — — — 66 
Direct/Indirect consumer33 33 38 40 34 
Other consumer — — — 
Total consumer1,698 2,163 2,916 4,170 5,679 
Commercial   
U.S. commercial 228 106 197 144 106 
Non-U.S. commercial10 — 
Commercial real estate6 19 
Commercial lease financing25 20 29 19 19 
 269 153 230 170 137 
U.S. small business commercial115 97 84 75 71 
Total commercial384 250 314 245 208 
Total accruing loans and leases past due 90 days or more$2,082 $2,413 $3,230 $4,415 $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 reported in other income.option.
Under applicable(2)Balances are fully-insured loans.

Bank of America 90


Table IV
Selected Loan Maturity Data (1, 2)
 December 31, 2020
(Dollars in millions)Due in One
Year or Less
Due After One Year Through Five YearsDue After
Five Years
Total
U.S. commercial$82,577 $198,898 $46,642 $328,117 
U.S. commercial real estate14,073 37,552 5,552 57,177 
Non-U.S. and other (3)
33,196 54,488 8,989 96,673 
Total selected loans$129,846 $290,938 $61,183 $481,967 
Percent of total27 %60 %13 %100 %
Sensitivity of selected loans to changes in interest rates for loans due after one year:    
Fixed interest rates $46,911 $32,280  
Floating or adjustable interest rates 244,027 28,903  
Total $290,938 $61,183  
(1)Loan maturities are based on the remaining maturities under contractual terms.
(2)Includes loans accounted for under the fair value option.
(3)Loan maturities include non-U.S. commercial and commercial real estate loans.
Table V
Allowance for Credit Losses (1)
(Dollars in millions)20202019201820172016
Allowance for loan and lease losses, January 1$12,358 $9,601 $10,393 $11,237 $12,234 
Loans and leases charged off   
Residential mortgage(40)(93)(207)(188)(403)
Home equity(58)(429)(483)(582)(752)
Credit card(2,967)(3,535)(3,345)(2,968)(2,691)
Non-U.S. credit card (2)
 — — (103)(238)
Direct/Indirect consumer(372)(518)(495)(491)(392)
Other consumer(307)(249)(197)(212)(232)
Total consumer charge-offs(3,744)(4,824)(4,727)(4,544)(4,708)
U.S. commercial (3)
(1,163)(650)(575)(589)(567)
Non-U.S. commercial(168)(115)(82)(446)(133)
Commercial real estate(275)(31)(10)(24)(10)
Commercial lease financing(69)(26)(8)(16)(30)
Total commercial charge-offs(1,675)(822)(675)(1,075)(740)
Total loans and leases charged off(5,419)(5,646)(5,402)(5,619)(5,448)
Recoveries of loans and leases previously charged off   
Residential mortgage70 140 179 288 272 
Home equity131 787 485 369 347 
Credit card618 587 508 455 422 
Non-U.S. credit card (2)
 — — 28 63 
Direct/Indirect consumer250 309 300 277 258 
Other consumer23 15 15 49 27 
Total consumer recoveries1,092 1,838 1,487 1,466 1,389 
U.S. commercial (4)
178 122 120 142 175 
Non-U.S. commercial13 31 14 13 
Commercial real estate5 15 41 
Commercial lease financing10 11 
Total commercial recoveries206 160 152 174 238 
Total recoveries of loans and leases previously charged off1,298 1,998 1,639 1,640 1,627 
Net charge-offs(4,121)(3,648)(3,763)(3,979)(3,821)
Provision for loan and lease losses10,565 3,574 3,262 3,381 3,581 
Other (5)
 (111)(291)(246)(514)
Total allowance for loan and lease losses, December 3118,802 9,416 9,601 10,393 11,480 
Less: Allowance included in assets of business held for sale (6)
 — — — (243)
Allowance for loan and lease losses, December 3118,802 9,416 9,601 10,393 11,237 
Reserve for unfunded lending commitments, January 11,123 797 777 762 646 
Provision for unfunded lending commitments755 16 20 15 16 
Other (5)
 — — — 100 
Reserve for unfunded lending commitments, December 311,878 813 797 777 762 
Allowance for credit losses, December 31$20,680 $10,229 $10,398 $11,170 $11,999 
(1)On January 1, 2020, the Corporation adopted the CECL accounting guidance,standard, which increased the allowance for reporting purposes, the loan and lease portfolio is categorizedlosses by portfolio segment$2.9 billion and within each portfolio segment,the reserve for unfunded lending commitments by class$310 million. For more information, see Note 1 – Summary of financing receivables. A portfolio segment is defined asSignificant Accounting Principles to the level at which an entity develops and documents a systematic methodologyConsolidated Financial Statements.
(2)Represents amounts related 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 U.S. credit card, non-U.S. credit card (soldloan portfolio, which was sold in 2017), 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 and2017.
(3)Includes U.S. small business commercial.commercial charge-offs of $321 million, $320 million, $287 million, $258 million and $253 million in 2020, 2019, 2018, 2017 and 2016, respectively.
(4)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.
(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.

91 Bank of America


Table VAllowance for Credit Losses (continued)
(Dollars in millions)20202019201820172016
Loan and allowance ratios (7):
Loans and leases outstanding at December 31 (8)
$921,180 $975,091 $942,546 $931,039 $908,812 
Allowance for loan and lease losses as a percentage of total loans and leases outstanding at December 31 (8)
2.04 %0.97 %1.02 %1.12 %1.26 %
Consumer allowance for loan and lease losses as a percentage of total consumer loans and leases outstanding at December 31 (9)
2.35 0.98 1.08 1.18 1.36 
Commercial allowance for loan and lease losses as a percentage of total commercial loans and leases outstanding at December 31 (10)
1.77 0.96 0.97 1.05 1.16 
Average loans and leases outstanding (8)
$974,281 $951,583 $927,531 $911,988 $892,255 
Net charge-offs as a percentage of average loans and leases outstanding (8)
0.42 %0.38 %0.41 %0.44 %0.43 %
Allowance for loan and lease losses as a percentage of total nonperforming loans and leases at December 31380 265 194 161 149 
Ratio of the allowance for loan and lease losses at December 31 to net charge-offs4.56 2.58 2.55 2.61 3.00 
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)
$9,854 $4,151 $4,031 $3,971 $3,951 
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)
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)
 December 31
20202019201820172016
(Dollars in millions)AmountPercent
of Total
AmountPercent
of Total
AmountPercent
of Total
AmountPercent
of Total
AmountPercent
of Total
Allowance for loan and lease losses          
Residential mortgage$459 2.44 %$325 3.45 %$422 4.40 %$701 6.74 %$1,012 8.82 %
Home equity399 2.12 221 2.35 506 5.27 1,019 9.80 1,738 15.14 
Credit card8,420 44.79 3,710 39.39 3,597 37.47 3,368 32.41 2,934 25.56 
Non-U.S. credit card  — — — — — — 243 2.12 
Direct/Indirect consumer752 4.00 234 2.49 248 2.58 264 2.54 244 2.13 
Other consumer41 0.22 52 0.55 29 0.30 31 0.30 51 0.44 
Total consumer10,071 53.57 4,542 48.23 4,802 50.02 5,383 51.79 6,222 54.21 
U.S. commercial (2)
5,043 26.82 3,015 32.02 3,010 31.35 3,113 29.95 3,326 28.97 
Non-U.S. commercial1,241 6.60 658 6.99 677 7.05 803 7.73 874 7.61 
Commercial real estate2,285 12.15 1,042 11.07 958 9.98 935 9.00 920 8.01 
Commercial lease financing162 0.86 159 1.69 154 1.60 159 1.53 138 1.20 
Total commercial8,731 46.43 4,874 51.77 4,799 49.98 5,010 48.21 5,258 45.79 
Total allowance for loan and lease losses18,802 100.00 %9,416 100.00 %9,601 100.00 %10,393 100.00 %11,480 100.00 %
Less: Allowance included in assets of business held for sale (3)
 — — — (243)
Allowance for loan and lease losses18,802 9,416 9,601 10,393 11,237 
Reserve for unfunded lending commitments1,878 813  797 777 762 
Allowance for credit losses$20,680 $10,229  $10,398 $11,170 $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 Statements.
(2)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.
Bank of America 92


Item 7A. Quantitative and Qualitative Disclosures about Market Risk
See Market Risk Management on page 78 in the MD&A and the sections referenced therein for Quantitative and Qualitative Disclosures about Market Risk.
Item 8. Financial Statements and Supplementary Data
Table of Contents
93 Bank of America




Report of Management on Internal Control Over Financial Reporting
The management of Bank of America Corporation is responsible for establishing and maintaining adequate internal control over financial reporting.
The Corporation’s internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with accounting principles generally accepted in the United States of America. The Corporation’s internal control over financial reporting includes those policies and procedures that (i) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the Corporation; (ii) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with accounting principles generally accepted in the United States of America, and that receipts and expenditures of the Corporation are being made only in accordance with authorizations of management and directors of the Corporation; and (iii) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use, or disposition of the Corporation’s assets that could have a material effect on the financial statements.
Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

Management assessed the effectiveness of the Corporation’s internal control over financial reporting as of December 31, 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.
The Corporation’s internal control over financial reporting as of December 31, 2020 has been audited by PricewaterhouseCoopers, LLP, an independent registered public accounting firm, as stated in their accompanying report which expresses an unqualified opinion on the effectiveness of the Corporation’s internal control over financial reporting as of December 31, 2020.
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Brian T. Moynihan
Chairman, Chief Executive Officer and President

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Paul M. Donofrio
Chief Financial Officer

Bank of America 201794




Report of Independent Registered Public Accounting Firm
Purchased Credit-impaired LoansTo the Board of Directors and Shareholders of Bank of America Corporation:
Purchased loans with evidenceOpinions on the Financial Statements and Internal Control over Financial Reporting
We have audited the accompanying consolidated balance sheets of credit quality deteriorationBank of America Corporation and its subsidiaries (the “Corporation”) as of December 31, 2020 and 2019, and the purchase date for which it is probable that the Corporation will not receive all contractually required payments receivable are accounted for as purchased credit-impaired (PCI) loans. Evidencerelated consolidated statements of credit quality deterioration since origination may include past due status, refreshed credit scoresincome, comprehensive income, changes in shareholders’ equity and refreshed loan-to-value (LTV) ratios. At acquisition, PCI loans are recorded at fair value with no allowance for credit losses, and accounted for individually or aggregated in pools based on similar risk characteristics such as credit risk, collateral type and interest rate risk. The Corporation estimates the amount and timing of expected cash flows for each loan or pool of loans. The expected cash flows in excess of the amount paid forthree years in the loans isperiod ended December 31, 2020, including the related notes (collectively referred to as the accretable yield“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 in Note 1 to the consolidated financial statements, the Corporation changed the manner in which it accounts for credit losses on certain financial instruments in 2020.
Basis for Opinions
The Corporation’s management is responsible 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 maintained in all material respects. Our audits of the consolidated financial statements included performing 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 regarding the amounts and disclosures in the consolidated financial statements. Our audits also included evaluating the
accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the consolidated financial statements. Our audit of internal control over financial reporting included obtaining an understanding of internal control over financial reporting, assessing the risk that a material weakness exists, and testing and evaluating the design and operating effectiveness of internal control based on the assessed risk. Our audits also included performing such other procedures as we considered necessary in the circumstances. We believe that our audits provide a reasonable basis for our opinions.
Definition and Limitations of Internal Control over Financial Reporting
A company’s internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles. A company’s internal control over financial reporting includes those policies and procedures that (i) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the company; (ii) provide reasonable assurance that transactions are recorded as interest income over the remaining estimated lifenecessary to permit preparation of financial statements in accordance with generally accepted accounting principles, and that receipts and expenditures of the loan or poolcompany are being made only in accordance with authorizations of loans. The excessmanagement and directors of the PCI loans’ contractual principalcompany; and interest(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 cash flowscredit 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 $921.2 billion, which excludes loans accounted for under the fair value option. For commercial and consumer card loans, the expected credit loss is referred toestimated using quantitative methods
95 Bank of America


that consider a variety of factors such as historical loss experience, the nonaccretable difference. Overcurrent credit quality of the portfolio as well as an economic outlook over the life of the PCI loans, the expected cash flows continue to be estimated using models that incorporate management’s estimate of current assumptions such as default rates,loan. In its loss severity and prepayment speeds. If, upon subsequent valuation,forecasting framework, the Corporation determines it is probable thatincorporates forward looking information through the present valueuse of macroeconomic scenarios applied over the forecasted life of the expected cash flows has decreased,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. The scenarios that are chosen and the amount of weighting given to each scenario depend on a charge to the provision for credit losses is recorded with a corresponding increasevariety 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 credit losses. If it is probableloan losses are qualitative reserves to cover losses that there is a significant increaseare expected but, in the present valueCorporation'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 expected cash flows,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 others. Further, the Corporation considers the inherent uncertainty in quantitative models that are built on historical data.
The principal considerations for our determination that performing procedures relating to the allowance for creditloan and lease losses for the commercial and consumer card portfolios is reduced or, if there is no remaining allowance for credit lossesa critical audit matter are (i) the significant judgment and estimation by management in developing lifetime economic forecast scenarios, related weightings to these PCI loans,each scenario and certain qualitative reserves, which in turn led to a high degree of auditor judgment, subjectivity and effort in performing procedures and in evaluating audit evidence obtained, and (ii) the accretable yield is increased through a reclassification from nonaccretable difference, resultingaudit effort involved professionals with specialized skill and knowledge to assist in a prospective increaseevaluating certain audit evidence.
Addressing the matter involved performing procedures and evaluating audit evidence in interest income. Reclassificationsconnection with forming our overall opinion on the consolidated financial statements. These procedures included testing the effectiveness of controls relating to or from nonaccretable difference can also occur for changes in the PCI loans’ estimated lives. If a loan within a PCI pool is sold, foreclosed, forgiven or the expectation of any future proceeds is remote, the loan is removed from the pool at its proportional carrying value. If the loan’s recovery value is less than the loan’s carrying value, the difference is first applied against the PCI pool’s nonaccretable difference and then against the allowance for creditloan and lease losses, including controls over the evaluation and approval of models, forecast scenarios and related weightings, and qualitative reserves. These procedures also included, among others, testing management’s process for estimating the allowance for loan losses, including (i) evaluating the appropriateness of the loss forecast models and methodology, (ii) evaluating the 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 also included the involvement of professionals with specialized
Leases
skill and knowledge to assist in evaluating the appropriateness of certain loss forecast models, the reasonableness of economic forecast scenarios and related weightings and the reasonableness of certain qualitative reserves.
Valuation of Certain Level 3 Financial Instruments
As described in Notes 1 and 20 to the consolidated financial statements, the Corporation carries certain 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 judgment or estimation. The Corporation determines the fair value of Level 3 financial instruments using pricing models, discounted cash flow 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 be determined using quantitative-based extrapolations or other internal methodologies which incorporate management estimates and available market information.
The Corporation provides equipment financingprincipal considerations for our determination that performing procedures relating to its customers throughthe valuation of certain Level 3 financial instruments is a variety of lease arrangements. Direct financing leasescritical audit matter are carried at the aggregate of lease payments receivable plus estimated residualsignificant 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 procedures, including the leased property less unearnedinvolvement of professionals with specialized skill and knowledge to assist in evaluating certain audit evidence.
Addressing the matter involved performing procedures and evaluating audit evidence in connection with forming our overall opinion on the consolidated financial statements. These procedures included testing the effectiveness of controls relating to the valuation of financial instruments, including controls related to valuation models, significant unobservable inputs, and data. These procedures also included, among others, the involvement of professionalswith specialized skill and knowledge to assist in developing an independent estimate of fair value for a sample of these certain financial instruments and comparison of management’s estimate to the independently developed estimate of fair value. Developing the independent estimate involved testing the completeness and accuracy of data provided by management and evaluating the reasonableness of management’s assumptions used to develop the significant unobservable inputs.

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Charlotte, North Carolina
February 24, 2021

We have served as the Corporation’s auditor since 1958.


Bank of America 96


Bank of America Corporation and Subsidiaries
Consolidated Statement of Income
(In millions, except per share information)202020192018
Net interest income 
Interest income$51,585 $71,236 $66,769 
Interest expense8,225 22,345 18,607 
Net interest income43,360 48,891 48,162 
Noninterest income 
Fees and commissions34,551 33,015 33,078 
Market making and similar activities8,355 9,034 9,008 
Other income(738)304 772 
Total noninterest income42,168 42,353 42,858 
Total revenue, net of interest expense85,528 91,244 91,020 
Provision for credit losses11,320 3,590 3,282 
Noninterest expense
Compensation and benefits32,725 31,977 31,880 
Occupancy and equipment7,141 6,588 6,380 
Information processing and communications5,222 4,646 4,555 
Product delivery and transaction related3,433 2,762 2,857 
Marketing1,701 1,934 1,674 
Professional fees1,694 1,597 1,699 
Other general operating3,297 5,396 4,109 
Total noninterest expense55,213 54,900 53,154 
Income before income taxes18,995 32,754 34,584 
Income tax expense1,101 5,324 6,437 
Net income$17,894 $27,430 $28,147 
Preferred stock dividends1,421 1,432 1,451 
Net income applicable to common shareholders$16,473 $25,998 $26,696 
Per common share information 
Earnings$1.88 $2.77 $2.64 
Diluted earnings1.87 2.75 2.61 
Average common shares issued and outstanding8,753.2 9,390.5 10,096.5 
Average diluted common shares issued and outstanding8,796.9 9,442.9 10,236.9 
Consolidated Statement of Comprehensive Income
(Dollars in millions)202020192018
Net income$17,894 $27,430 $28,147 
Other comprehensive income (loss), net-of-tax:
Net change in debt securities4,799 5,875 (3,953)
Net change in debit valuation adjustments(498)(963)749 
Net change in derivatives826 616 (53)
Employee benefit plan adjustments(98)136 (405)
Net change in foreign currency translation adjustments(52)(86)(254)
Other comprehensive income (loss)4,977 5,578 (3,916)
Comprehensive income$22,871 $33,008 $24,231 
See accompanying Notes to Consolidated Financial Statements.
97 Bank of America


Bank of America Corporation and Subsidiaries
Consolidated Balance Sheet
December 31
(Dollars in millions)20202019
Assets
Cash and due from banks$36,430 $30,152 
Interest-bearing deposits with the Federal Reserve, non-U.S. central banks and other banks344,033 131,408 
Cash and cash equivalents380,463 161,560 
Time deposits placed and other short-term investments6,546 7,107 
Federal funds sold and securities borrowed or purchased under agreements to resell
   (includes $108,856 and $50,364 measured at fair value)
304,058 274,597 
Trading account assets (includes $91,510 and $90,946 pledged as collateral)
198,854 229,826 
Derivative assets47,179 40,485 
Debt securities: 
Carried at fair value246,601 256,467 
Held-to-maturity, at cost (fair value – $448,180 and $219,821)
438,249 215,730 
Total debt securities684,850 472,197 
Loans and leases (includes $6,681 and $8,335 measured at fair value)
927,861 983,426 
Allowance for loan and lease losses(18,802)(9,416)
Loans and leases, net of allowance909,059 974,010 
Premises and equipment, net11,000 10,561 
Goodwill68,951 68,951 
Loans held-for-sale (includes $1,585 and $3,709 measured at fair value)
9,243 9,158 
Customer and other receivables64,221 55,937 
Other assets (includes $15,718 and $15,518 measured at fair value)
135,203 129,690 
Total assets$2,819,627 $2,434,079 
Liabilities  
Deposits in U.S. offices:  
Noninterest-bearing$650,674 $403,305 
Interest-bearing (includes $481 and $508 measured at fair value)
1,038,341 940,731 
Deposits in non-U.S. offices:
Noninterest-bearing17,698 13,719 
Interest-bearing88,767 77,048 
Total deposits1,795,480 1,434,803 
Federal funds purchased and securities loaned or sold under agreements to repurchase
   (includes $135,391 and $16,008 measured at fair value)
170,323 165,109 
Trading account liabilities71,320 83,270 
Derivative liabilities45,526 38,229 
Short-term borrowings (includes $5,874 and $3,941 measured at fair value)
19,321 24,204 
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)
181,799 182,798 
Long-term debt (includes $32,200 and $34,975 measured at fair value)
262,934 240,856 
Total liabilities2,546,703 2,169,269 
Commitments and contingencies (Note 6 – Securitizations and Other Variable Interest Entities
   and Note 12 – Commitments and Contingencies)
00
Shareholders’ equity 
Preferred stock, $0.01 par value; authorized – 100,000,000 shares; issued and outstanding – 3,931,440 and 3,887,440 shares
24,510 23,401 
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
85,982 91,723 
Retained earnings164,088 156,319 
Accumulated other comprehensive income (loss)(1,656)(6,633)
Total shareholders’ equity272,924 264,810 
Total liabilities and shareholders’ equity$2,819,627 $2,434,079 
Assets of consolidated variable interest entities included in total assets above (isolated to settle the liabilities of the variable interest entities)
Trading account assets$5,225 $5,811 
Loans and leases23,636 38,837 
Allowance for loan and lease losses(1,693)(807)
Loans and leases, net of allowance21,943 38,030 
All other assets1,387 540 
Total assets of consolidated variable interest entities$28,555 $44,381 
Liabilities of consolidated variable interest entities included in total liabilities above  
Short-term borrowings (includes $22 and $0 of non-recourse short-term borrowings)
$454 $2,175 
Long-term debt (includes $7,053 and $8,717 of non-recourse debt)
7,053 8,718 
All other liabilities (includes $16 and $19 of non-recourse liabilities)
16 22 
Total liabilities of consolidated variable interest entities$7,523 $10,915 
See accompanying Notes to Consolidated Financial Statements.
Bank of America 98


Bank of America Corporation and Subsidiaries
Consolidated Statement of Changes in Shareholders’ Equity
Preferred
Stock
Common Stock and
Additional Paid-in Capital
Retained
Earnings
Accumulated
Other
Comprehensive
Income (Loss)
Total
Shareholders’
Equity
(In millions)SharesAmount
Balance, December 31, 2017$22,323 10,287.3 $138,089 $113,816 $(7,082)$267,146 
Cumulative adjustment for adoption of hedge accounting
standard
(32)57 25 
Adoption of accounting standard related to certain tax effects
stranded in accumulated other comprehensive income (loss)
1,270 (1,270)
Net income   28,147 28,147 
Net change in debt securities    (3,953)(3,953)
Net change in debit valuation adjustments749 749 
Net change in derivatives    (53)(53)
Employee benefit plan adjustments    (405)(405)
Net change in foreign currency translation adjustments   (254)(254)
Dividends declared:    
Common (5,424) (5,424)
Preferred  (1,451) (1,451)
Issuance of preferred stock4,515 4,515 
Redemption of preferred stock(4,512)(4,512)
Common stock issued under employee plans, net, and other58.2 901 (12) 889 
Common stock repurchased(676.2)(20,094)(20,094)
Balance, December 31, 2018$22,326 9,669.3 $118,896 $136,314 $(12,211)$265,325 
Cumulative adjustment for adoption of lease accounting
standard
165 165 
Net income27,430 27,430 
Net change in debt securities5,875 5,875 
Net change in debit valuation adjustments(963)(963)
Net change in derivatives616 616 
Employee benefit plan adjustments136 136 
Net change in foreign currency translation adjustments(86)(86)
Dividends declared:
Common(6,146)(6,146)
Preferred(1,432)(1,432)
Issuance of preferred stock3,643 3,643 
Redemption of preferred stock(2,568)(2,568)
Common stock issued under employee plans, net, and other123.3 971 (12)959 
Common stock repurchased(956.5)(28,144)(28,144)
Balance, December 31, 2019$23,401 8,836.1 $91,723 $156,319 $(6,633)$264,810 
Cumulative adjustment for adoption of credit loss accounting
standard
(2,406)(2,406)
Net income17,894 17,894 
Net change in debt securities4,799 4,799 
Net change in debit valuation adjustments(498)(498)
Net change in derivatives826 826 
Employee benefit plan adjustments(98)(98)
Net change in foreign currency translation adjustments(52)(52)
Dividends declared:
Common(6,289)(6,289)
Preferred(1,421)(1,421)
Issuance of preferred stock2,181 2,181 
Redemption of preferred stock(1,072)(1,072)
Common stock issued under employee plans, net, and other41.7 1,284 (9)1,275 
Common stock repurchased(227.0)(7,025)(7,025)
Balance, December 31, 2020$24,510 8,650.8 $85,982 $164,088 $(1,656)$272,924 
See accompanying Notes to Consolidated Financial Statements.
99 Bank of America


Bank of America Corporation and Subsidiaries
Consolidated Statement of Cash Flows
(Dollars in millions)202020192018
Operating activities   
Net income$17,894 $27,430 $28,147 
Adjustments to reconcile net income to net cash provided by operating activities:   
Provision for credit losses11,320 3,590 3,282 
Gains on sales of debt securities(411)(217)(154)
Depreciation and amortization1,843 1,729 2,063 
Net amortization of premium/discount on debt securities4,101 2,066 1,824 
Deferred income taxes(1,737)2,435 3,041 
Stock-based compensation2,031 1,974 1,729 
Impairment of equity method investment0 2,072 
Loans held-for-sale:
Originations and purchases(19,657)(28,874)(28,071)
Proceeds from sales and paydowns of loans originally classified as held for sale and instruments
from related securitization activities
19,049 30,191 28,972 
Net change in:
Trading and derivative assets/liabilities16,942 7,920 (23,673)
Other assets(12,883)(11,113)11,920 
Accrued expenses and other liabilities(4,385)16,363 13,010 
Other operating activities, net3,886 6,211 (2,570)
Net cash provided by operating activities37,993 61,777 39,520 
Investing activities   
Net change in:
Time deposits placed and other short-term investments561 387 3,659 
Federal funds sold and securities borrowed or purchased under agreements to resell(29,461)(13,466)(48,384)
Debt securities carried at fair value:
Proceeds from sales77,524 52,006 5,117 
Proceeds from paydowns and maturities91,084 79,114 78,513 
Purchases(194,877)(152,782)(76,640)
Held-to-maturity debt securities:
Proceeds from paydowns and maturities93,835 34,770 18,789 
Purchases(257,535)(37,115)(35,980)
Loans and leases:
Proceeds from sales of loans originally classified as held for investment and instruments
from related securitization activities
13,351 12,201 21,365 
Purchases(5,229)(5,963)(4,629)
Other changes in loans and leases, net36,571 (46,808)(31,292)
Other investing activities, net(3,489)(2,974)(1,986)
Net cash used in investing activities(177,665)(80,630)(71,468)
Financing activities   
Net change in:
Deposits360,677 53,327 71,931 
Federal funds purchased and securities loaned or sold under agreements to repurchase5,214 (21,879)10,070 
Short-term borrowings(4,893)4,004 (12,478)
Long-term debt:
Proceeds from issuance57,013 52,420 64,278 
Retirement(47,948)(50,794)(53,046)
Preferred stock:
Proceeds from issuance2,181 3,643 4,515 
Redemption(1,072)(2,568)(4,512)
Common stock repurchased(7,025)(28,144)(20,094)
Cash dividends paid(7,727)(5,934)(6,895)
Other financing activities, net(601)(698)(651)
Net cash provided by financing activities355,819 3,377 53,118 
Effect of exchange rate changes on cash and cash equivalents2,756 (368)(1,200)
Net increase (decrease) in cash and cash equivalents218,903 (15,844)19,970 
Cash and cash equivalents at January 1161,560 177,404 157,434 
Cash and cash equivalents at December 31$380,463 $161,560 $177,404 
Supplemental cash flow disclosures
Interest paid$8,662 $22,196 $19,087 
Income taxes paid, net2,894 4,359 2,470 
See accompanying Notes to Consolidated Financial Statements.
Bank of America 100


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. Leveraged leases, which are a form
The preparation of financing leases, arethe 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 net of non-recourse debt. Unearned income on leveragedamounts and direct financing leases is accreteddisclosures. Actual results could materially differ from those estimates and assumptions. Certain prior-period amounts have been reclassified to interest income over the lease terms using methods that approximate the interest method.conform to current period presentation.
New Accounting Standards
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, 2020and December 31, 2019 (prior to the adoption of the CECL accounting standard).
Table 42Allocation of the Allowance for Credit Losses by Product Type
AmountPercent of
Total
Percent of
Loans and
Leases
Outstanding (1)
AmountPercent of
Total
Percent of
Loans and
Leases
Outstanding
(1)
AmountPercent of
Total
Percent of
Loans and
Leases
Outstanding (1)
(Dollars in millions)December 31, 2020January 1, 2020December 31, 2019
Allowance for loan and lease losses      
Residential mortgage$459 2.44 %0.21 %$212 1.72 %0.09 %$325 3.45 %0.14 %
Home equity399 2.12 1.16 228 1.84 0.57 221 2.35 0.55 
Credit card8,420 44.79 10.70 6,809 55.10 6.98 3,710 39.39 3.80 
Direct/Indirect consumer752 4.00 0.82 566 4.58 0.62 234 2.49 0.26 
Other consumer41 0.22 n/m55 0.45 n/m52 0.55 n/m
Total consumer10,071 53.57 2.35 7,870 63.69 1.69 4,542 48.23 0.98 
U.S. commercial (2)
5,043 26.82 1.55 2,723 22.03 0.84 3,015 32.02 0.94 
Non-U.S. commercial1,241 6.60 1.37 668 5.41 0.64 658 6.99 0.63 
Commercial real estate2,285 12.15 3.79 1,036 8.38 1.65 1,042 11.07 1.66 
Commercial lease financing162 0.86 0.95 61 0.49 0.31 159 1.69 0.80 
Total commercial8,731 46.43 1.77 4,488 36.31 0.88 4,874 51.77 0.96 
Allowance for loan and lease losses18,802 100.00 %2.04 12,358 100.00 %1.27 9,416 100.00 %0.97 
Reserve for unfunded lending commitments1,878 1,123 813  
Allowance for credit losses$20,680 $13,481 $10,229 
(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.
(2)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
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 incurred losses. For more information on 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.
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Table 43Allowance for Credit Losses
(Dollars in millions)20202019
Allowance for loan and lease losses, January 1$12,358 $9,601 
Loans and leases charged off
Residential mortgage(40)(93)
Home equity(58)(429)
Credit card(2,967)(3,535)
Direct/Indirect consumer(372)(518)
Other consumer(307)(249)
Total consumer charge-offs(3,744)(4,824)
U.S. commercial (1)
(1,163)(650)
Non-U.S. commercial(168)(115)
Commercial real estate(275)(31)
Commercial lease financing(69)(26)
Total commercial charge-offs(1,675)(822)
Total loans and leases charged off(5,419)(5,646)
Recoveries of loans and leases previously charged off
Residential mortgage70 140 
Home equity131 787 
Credit card618 587 
Direct/Indirect consumer250 309 
Other consumer23 15 
Total consumer recoveries1,092 1,838 
U.S. commercial (2)
178 122 
Non-U.S. commercial13 31 
Commercial real estate5 
Commercial lease financing10 
Total commercial recoveries206 160 
Total recoveries of loans and leases previously charged off1,298 1,998 
Net charge-offs(4,121)(3,648)
Provision for loan and lease losses10,565 3,574 
Other (111)
Allowance for loan and lease losses, December 3118,802 9,416 
Reserve for unfunded lending commitments, January 11,123 797 
Provision for unfunded lending commitments755 16 
Reserve for unfunded lending commitments, December 311,878 813 
Allowance for credit losses, December 31$20,680 $10,229 
Loan and allowance ratios:
Loans and leases outstanding at December 31 (3)
$921,180 $975,091 
Allowance for loan and lease losses as a percentage of total loans and leases outstanding at December 31 (3)
2.04 %0.97 %
Consumer allowance for loan and lease losses as a percentage of total consumer loans and leases outstanding at December 31 (4)
2.35 0.98 
Commercial allowance for loan and lease losses as a percentage of total commercial loans and leases outstanding at December 31 (5)
1.77 0.96 
Average loans and leases outstanding (3)
$974,281 $951,583 
Annualized net charge-offs as a percentage of average loans and leases outstanding (3)
0.42 %0.38 %
Allowance for loan and lease losses as a percentage of total nonperforming loans and leases at December 31380 265 
Ratio of the allowance for loan and lease losses at December 31 to net charge-offs4.56 2.58 
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)
$9,854 $4,151 
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)
181 %148 %
(1)Includes U.S. small business commercial charge-offs of $321 million in 2020 compared to $320 million in 2019.
(2)Includes U.S. small business commercial recoveries of $54 million in 2020 compared to $48 million in 2019.
(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.
77 Bank of America


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 82.
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 25.
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 requirements and monitors the effective challenge in the model validation process across the Corporation.
Interest Rate Risk
Interest rate risk represents exposures to instruments whose values vary with the level or volatility of interest rates. These instruments include, but are not limited to, loans, debt securities, certain trading-related assets and liabilities, deposits, borrowings and derivatives. Hedging instruments used to mitigate these risks include derivatives such as options, futures, forwards and swaps.
Foreign Exchange Risk
Foreign exchange risk represents exposures to changes in the values of current holdings and future cash flows denominated in currencies other than the U.S. dollar. The types of instruments exposed to this risk include investments in non-U.S. subsidiaries, foreign currency-denominated loans and securities, future cash flows in foreign currencies arising from foreign exchange transactions, foreign currency-denominated debt and various foreign exchange derivatives whose values fluctuate with changes in the level or volatility of currency exchange rates or non-U.S. interest rates. Hedging instruments used to mitigate this risk include foreign exchange options, currency swaps, futures, forwards, and foreign currency-denominated debt and deposits.
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 84.
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
Bank of America 78


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 further exacerbated if expected hedging or pricing correlations are compromised by disproportionate demand or lack of demand for certain instruments. We utilize various risk mitigating techniques as discussed in more detail in Trading Risk Management.
Trading Risk Management
To evaluate risks in our trading activities, we focus on the actual and potential volatility of revenues generated by individual positions as well as portfolios of positions. Various techniques and procedures are utilized to enable the most complete understanding of these risks. Quantitative measures of market risk are evaluated on a daily basis from a single position to the portfolio of the Corporation. These measures include sensitivities of positions to various market risk factors, such as the potential impact on revenue from a one basis point change in interest rates, and statistical measures utilizing both actual and hypothetical market moves, such as VaR and stress testing. Periods of extreme market stress influence the reliability of these techniques to varying degrees. Qualitative evaluations of market risk utilize the suite of quantitative risk measures while understanding each of their respective limitations. Additionally, risk managers independently evaluate the risk of the portfolios under the current market environment and potential future environments.
VaR is a common statistic used to measure market risk as it allows the aggregation of market risk factors, including the effects of portfolio diversification. A VaR model simulates the value of a portfolio under a range of scenarios in order to generate a distribution of potential gains and losses. VaR represents the loss a portfolio is not expected to exceed more than a certain number of times per period, based on a specified holding period, confidence level and window of historical data. We use one VaR model consistently across the trading portfolios and it uses a historical simulation approach based on a three-year window of historical data. Our primary VaR statistic is equivalent to a 99 percent confidence level, which means that for a VaR with a one-day holding period, there should not be losses in excess of VaR, on average, 99 out of 100 trading days.
Within any VaR model, there are significant and numerous assumptions that will differ from company to company. The accuracy of a VaR model depends on the availability and quality of historical data for each of the risk factors in the portfolio. A VaR model may require additional modeling assumptions for new products that do not have the necessary historical market data or for less liquid positions for which accurate daily prices
are not consistently available. For positions with insufficient historical data for the VaR calculation, the process for establishing an appropriate proxy is based on fundamental and statistical analysis of the new product or less liquid position. This analysis identifies reasonable alternatives that replicate both the expected volatility and correlation to other market risk factors that the missing data would be expected to experience.
VaR may not be indicative of realized revenue volatility as changes in market conditions or in the composition of the portfolio can have a material impact on the results. In particular, the historical data used for the VaR calculation might indicate higher or lower levels of portfolio diversification than will be experienced. In order for the VaR model to reflect current market conditions, we update the historical data underlying our VaR model on a weekly basis, or more frequently during periods of market stress, and regularly review the assumptions underlying the model. A minor portion of risks related to our trading positions is not included in VaR. These risks are reviewed as part of our ICAAP. For more information regarding ICAAP, see Capital Management on page 50.
Global Risk Management continually reviews, evaluates and enhances our VaR model so that it reflects the material risks in our trading portfolio. Changes to the VaR model are reviewed and approved prior to implementation and any material changes are reported to management through the appropriate management committees.
Trading limits on quantitative risk measures, including VaR, are independently set by Global Markets Risk Management and reviewed on a regular basis so that trading limits remain relevant and within our overall risk appetite for market risks. Trading limits are reviewed in the context of market liquidity, volatility and strategic business priorities. Trading limits are set at both a granular level to allow for extensive coverage of risks as well as at aggregated portfolios to account for correlations among risk factors. All trading limits are approved at least annually. Approved trading limits are stored and tracked in a centralized limits management system. Trading limit excesses are communicated to management for review. Certain quantitative market risk measures and corresponding limits have been identified as critical in the Corporation’s Risk Appetite Statement. These risk appetite limits are reported on a daily basis and are approved at least annually by the ERC and the Board.
In periods of market stress, Global Markets senior leadership communicates daily to discuss losses, key risk positions and any limit excesses. As a result of this process, the businesses may selectively reduce risk.
Table 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
79 Bank of America


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
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.
Table 44Market Risk VaR for Trading Activities
20202019
(Dollars in millions)Year
End
Average
High (1)
Low (1)
Year
End
Average
High (1)
Low (1)
Foreign exchange$8 $7 $25 $2 $$$13 $
Interest rate30 19 39 7 25 24 49 14 
Credit79 58 91 25 26 23 32 16 
Equity20 24 162 12 29 22 33 14 
Commodities4 6 12 3 31 
Portfolio diversification(72)(61)  (47)(49)— — 
Total covered positions portfolio69 53 171 27 41 32 47 24 
Impact from less liquid exposures52 27   — — — 
Total covered positions and less liquid trading positions portfolio121 80 169 30 41 35 53 27 
Fair value option loans52 52 84 7 10 13 
Fair value option hedges11 13 17 9 10 10 17 
Fair value option portfolio diversification(17)(24)  (9)(10)— — 
Total fair value option portfolio46 41 86 9 10 16 
Portfolio diversification(4)(15)  (5)(7)— — 
Total market-based portfolio$163 $106 171 32 $45 $38 56 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.
bac-20201231_g3.jpg
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 45Average Market Risk VaR for Trading Activities – 99 percent and 95 percent VaR Statistics
20202019
(Dollars in millions)99 percent95 percent99 percent95 percent
Foreign exchange$7 $4 $$
Interest rate19 9 24 15 
Credit58 18 23 15 
Equity24 13 22 11 
Commodities6 3 
Portfolio diversification(61)(26)(49)(29)
Total covered positions portfolio53 21 32 18 
Impact from less liquid exposures27 2 
Total covered positions and less liquid trading positions portfolio80 23 35 20 
Fair value option loans52 13 10 
Fair value option hedges13 7 10 
Fair value option portfolio diversification(24)(8)(10)(5)
Total fair value option portfolio41 12 10 
Portfolio diversification(15)(6)(7)(5)
Total market-based portfolio$106 $29 $38 $21 
Backtesting
The accuracy of the VaR methodology is evaluated by backtesting, which compares the daily VaR results, utilizing a one-day holding period, against a comparable subset of trading revenue. A backtesting excess occurs when a trading loss exceeds the VaR for the corresponding day. These excesses are evaluated to understand the positions and market moves that produced the trading loss with a goal to ensure that the VaR methodology accurately represents those losses. We expect the frequency of trading losses in excess of VaR to be in line with the confidence level of the VaR statistic being tested. For example, with a 99 percent confidence level, we expect one trading loss in excess of VaR every 100 days or between two to three trading losses in excess of VaR over the course of a year. The number of backtesting excesses observed can differ from the statistically expected number of excesses if the current level of market volatility is materially different than the level of market volatility that existed during the three years of historical data used in the VaR calculation.
The trading revenue used for backtesting is defined by regulatory agencies in order to most closely align with the VaR component of the regulatory capital calculation. This revenue differs from total trading-related revenue in that it excludes revenue from trading activities that either do not generate market risk or the market risk cannot be included in VaR. Some examples of the types of revenue excluded for backtesting are fees, commissions, reserves, net interest income and intra-day trading revenues.
We conduct daily backtesting on the VaR results used for regulatory capital calculations as well as the VaR results for key legal entities, regions and risk factors. These results are reported to senior market risk management. Senior management regularly reviews and evaluates the results of these tests.
During 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.
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.
bac-20201231_g4.jpg
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
81 Bank of America


severe point during a crisis is selected for each historical scenario. Hypothetical scenarios provide estimated portfolio impacts from potential future market stress events. Scenarios are reviewed and updated in response to changing positions and new economic or political information. In addition, new or ad hoc scenarios are developed to address specific potential market events or particular vulnerabilities in the portfolio. The stress tests are reviewed on a regular basis and the results are presented to senior management.
Stress testing for the trading portfolio is integrated with enterprise-wide stress testing and incorporated into the limits framework. The macroeconomic scenarios used for enterprise-wide stress testing purposes differ from the typical trading portfolio scenarios in that they have a longer time horizon and the results are forecasted over multiple periods for use in consolidated capital and liquidity planning. For more information, see Managing Risk on page 47.
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 46Forward Rates
December 31, 2020
 Federal
Funds
Three-month
LIBOR
10-Year
Swap
Spot rates0.25 %0.24 %0.93 %
12-month forward rates0.25 0.19 1.06 
December 31, 2019
Spot rates1.75 %1.91 %1.90 %
12-month forward rates1.50 1.62 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 51.
Table 47Estimated Banking Book Net Interest Income Sensitivity to Curve Changes
Short
Rate (bps)
Long
Rate (bps)
December 31
(Dollars in millions)20202019
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— 6,321 2,641 
Long-end
instantaneous change
— -25 (1,686)(653)
Steepeners  
Short-end
instantaneous change
-25 — (1,084)(844)
Long-end
instantaneous change
— +1004,333 1,561 
The sensitivity analysis in Table 47 assumes that we take no action in response to these rate shocks and does not assume any change in other macroeconomic variables normally correlated with changes in interest rates. As part of our ALM activities, we use securities, certain residential mortgages, and interest rate and foreign exchange derivatives in managing interest rate sensitivity.
The behavior of our deposits portfolio in the baseline forecast and in alternate interest rate scenarios is a key assumption in our projected estimates of net interest income. The sensitivity analysis in Table 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 exchange contracts, including cross-currency interest rate swaps, foreign currency futures contracts, foreign currency forward contracts and options to mitigate the foreign exchange risk associated with foreign currency-denominated assets and liabilities.
Changes to the composition of our derivatives portfolio during 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 48Asset and Liability Management Interest Rate and Foreign Exchange Contracts
December 31, 2020
Expected Maturity
(Dollars in millions, average estimated duration in years)Fair
Value
Total20212022202320242025ThereafterAverage
Estimated
Duration
Receive-fixed interest rate swaps (1)
$14,885        8.08 
Notional amount��$269,015 $11,050 $20,908 $30,654 $31,317 $32,898 $142,188 
Weighted-average fixed-rate1.54 %3.25 %0.91 %1.48 %1.17 %1.07 %1.69 %
Pay-fixed interest rate swaps (1)
(5,502)       6.52 
Notional amount $252,698 $7,562 $21,667 $24,671 $24,406 $32,052 $142,340  
Weighted-average fixed-rate0.89 %0.57 %0.10 %1.28 %0.86 %0.68 %1.00 %
Same-currency basis swaps (2)
(235)        
Notional amount $223,659 $18,769 $12,245 $9,747 $22,737 $28,222 $131,939  
Foreign exchange basis swaps (1, 3, 4)
(1,014)  
Notional amount 112,465 27,424 16,038 8,066 3,819 4,446 52,672  
Foreign exchange contracts (1, 4, 5)
349  
Notional amount (6)
(42,490)(69,299)2,841 2,505 4,735 4,369 12,359 
Futures and forward rate contracts47 
Notional amount14,255 14,255      
Option products   
Notional amount 17   17     
Net ALM contracts$8,530         
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Table 48Asset and Liability Management Interest Rate and Foreign Exchange Contracts (continued)
  December 31, 2019
  Expected Maturity
(Dollars in millions, average estimated duration in years)Fair
Value
Total20202021202220232024ThereafterAverage
Estimated
Duration
Receive-fixed interest rate swaps (1)
$12,370        6.47 
Notional amount $215,123 $16,347 $14,642 $21,616 $36,356 $21,257 $104,905 
Weighted-average fixed-rate2.68 %2.68 %3.17 %2.48 %2.36 %2.55 %2.79 %
Pay-fixed interest rate swaps (1)
(2,669)       6.99 
Notional amount $69,586 $4,344 $2,117 $— $13,993 $8,194 $40,938  
Weighted-average fixed-rate2.36 %2.16 %2.15 %— %2.52 %2.26 %2.35 %
Same-currency basis swaps (2)
(290)        
Notional amount $152,160 $18,857 $18,590 $4,306 $2,017 $14,567 $93,823  
Foreign exchange basis swaps (1, 3, 4)
(1,258)  
Notional amount 113,529 23,639 24,215 14,611 7,111 3,521 40,432  
Foreign exchange contracts (1, 4, 5)
414  
Notional amount (6)
(53,106)(79,315)4,539 2,674 2,340 4,432 12,224 
Option products—   
Notional amount 15 — — — 15 — —  
Net ALM contracts$8,567         
(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 50.
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 appropriate Board-level committees in support of Global Compliance and Operational Risk’s responsibilities for conducting independent oversight of our compliance and operational risk management activities. The Board provides oversight of compliance risk through its Audit Committee and the ERC, and operational risk through the ERC.
A key operational risk facing the Corporation is information security, which includes cybersecurity. Cybersecurity 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 integrity of our, 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 withinternal 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.
The Corporation manages reputational risk 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
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 risk is 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.
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
85 Bank of America


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.
The Corporation's estimate of lifetime ECL includes the use of quantitative models that incorporate forward-looking macroeconomic scenarios that are applied over the contractual life of the loan portfolios, adjusted for expected prepayments and borrower-controlled extension options. 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 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 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.
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, factors 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 others. Further, the Corporation considers the inherent uncertainty in quantitative models that are built on historical data.
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. 
As described above, the process to determine the allowance for credit losses 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
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.
The fair values of assets and liabilities may include adjustments, such as market liquidity and credit quality, where appropriate. Valuations of products using models or other techniques are sensitive to assumptions used for the significant inputs. Where market data is available, the inputs used for valuation reflect that information as of our valuation date. Inputs to valuation models are considered unobservable if they are supported by little or no market activity. In periods of extreme volatility, lessened liquidity or in illiquid markets, there may be more variability in market pricing or a lack of market data to use in the valuation process. In keeping with the prudent application of estimates and management judgment in determining the fair value of assets and liabilities, we have in place various processes and controls that include: a model validation policy that requires review and approval of quantitative models used for deal pricing, financial statement 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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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 to the Consolidated Financial Statements.
Accrued Income Taxes and Deferred Tax Assets
Accrued income taxes, reported as a component of either other assets or accrued expenses and other liabilities on the Consolidated Balance Sheet, represent the net amount of current income taxes we expect to pay to or receive from various taxing jurisdictions attributable to our operations to date. We currently file income tax returns in more than 100 jurisdictions and consider many factors, including statutory, judicial and regulatory guidance, in estimating the appropriate accrued income taxes for each jurisdiction.
Net deferred tax assets, reported as a component of other assets on the Consolidated Balance Sheet, represent the net decrease in taxes expected to be paid in the future because of net operating loss (NOL) and tax credit carryforwards and because of future reversals of temporary differences in the bases of assets and liabilities as measured by tax laws and their bases as reported in the financial statements. NOL and tax credit carryforwards result in reductions to future tax liabilities, and many of these attributes can expire if not utilized within certain periods. We consider the need for valuation allowances to reduce net deferred tax assets to the amounts that we estimate are more likely than not to be realized.
Consistent with the applicable accounting guidance, we monitor relevant tax authorities and change our estimates of accrued income taxes and/or net deferred tax assets due to changes in income tax laws and their interpretation by the courts and regulatory authorities. These revisions of our estimates, which also may result from our income tax planning and from the resolution of income tax audit matters, may be material to our operating results for any given period.
See Note 19 – Income Taxes to the Consolidated Financial Statements for a table of significant tax attributes and additional information. For more information, see page 16 under Part I. Item 1A. Risk Factors – Regulatory, Compliance and Legal.
Goodwill and Intangible Assets
The nature of and accounting for goodwill and intangible assets are discussed in Note 1 – Summary of Significant Accounting Principles, and Note 7 – Goodwill and Intangible Assets to the Consolidated Financial Statements.

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 (both in the U.S. and 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.
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.
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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)20202019201820172016
Reconciliation of average shareholders’ equity to average tangible shareholders’ equity and average tangible common shareholders’ equity     
Shareholders’ equity$267,309 $267,889 $264,748 $271,289 $265,843 
Goodwill(68,951)(68,951)(68,951)(69,286)(69,750)
Intangible assets (excluding MSRs)(1,862)(1,721)(2,058)(2,652)(3,382)
Related deferred tax liabilities821 773 906 1,463 1,644 
Tangible shareholders’ equity$197,317 $197,990 $194,645 $200,814 $194,355 
Preferred stock(23,624)(23,036)(22,949)(24,188)(24,656)
Tangible common shareholders’ equity$173,693 $174,954 $171,696 $176,626 $169,699 
Reconciliation of year-end shareholders’ equity to year-end tangible shareholders’ equity and year-end tangible common shareholders’ equity     
Shareholders’ equity$272,924 $264,810 $265,325 $267,146 $266,195 
Goodwill(68,951)(68,951)(68,951)(68,951)(69,744)
Intangible assets (excluding MSRs)(2,151)(1,661)(1,774)(2,312)(2,989)
Related deferred tax liabilities920 713 858 943 1,545 
Tangible shareholders’ equity$202,742 $194,911 $195,458 $196,826 $195,007 
Preferred stock(24,510)(23,401)(22,326)(22,323)(25,220)
Tangible common shareholders’ equity$178,232 $171,510 $173,132 $174,503 $169,787 
Reconciliation of year-end assets to year-end tangible assets     
Assets$2,819,627 $2,434,079 $2,354,507 $2,281,234 $2,188,067 
Goodwill(68,951)(68,951)(68,951)(68,951)(69,744)
Intangible assets (excluding MSRs)(2,151)(1,661)(1,774)(2,312)(2,989)
Related deferred tax liabilities920 713 858 943 1,545 
Tangible assets$2,749,445 $2,364,180 $2,284,640 $2,210,914 $2,116,879 
(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 31.
Table 50
Quarterly Reconciliations to GAAP Financial Measures (1)
2020 Quarters2019 Quarters
(Dollars in millions)FourthThirdSecondFirstFourthThirdSecondFirst
Reconciliation of average shareholders’ equity to average tangible shareholders’ equity and average tangible common shareholders’ equity        
Shareholders’ equity$271,020 $267,323 $266,316 $264,534 $266,900 $270,430 $267,975 $266,217 
Goodwill(68,951)(68,951)(68,951)(68,951)(68,951)(68,951)(68,951)(68,951)
Intangible assets (excluding MSRs)(2,173)(1,976)(1,640)(1,655)(1,678)(1,707)(1,736)(1,763)
Related deferred tax liabilities910 855 790 728 730 752 770 841 
Tangible shareholders’ equity$200,806 $197,251 $196,515 $194,656 $197,001 $200,524 $198,058 $196,344 
Preferred stock(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$272,924 $268,850 $265,637 $264,918 $264,810 $268,387 $271,408 $267,010 
Goodwill(68,951)(68,951)(68,951)(68,951)(68,951)(68,951)(68,951)(68,951)
Intangible assets (excluding MSRs)(2,151)(2,185)(1,630)(1,646)(1,661)(1,690)(1,718)(1,747)
Related deferred tax liabilities920 910 789 790 713 734 756 773 
Tangible shareholders’ equity$202,742 $198,624 $195,845 $195,111 $194,911 $198,480 $201,495 $197,085 
Preferred stock(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$2,819,627 $2,738,452 $2,741,688 $2,619,954 $2,434,079 $2,426,330 $2,395,892 $2,377,164 
Goodwill(68,951)(68,951)(68,951)(68,951)(68,951)(68,951)(68,951)(68,951)
Intangible assets (excluding MSRs)(2,151)(2,185)(1,630)(1,646)(1,661)(1,690)(1,718)(1,747)
Related deferred tax liabilities920 910 789 790 713 734 756 773 
Tangible assets$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 31.

Bank of America 88




Table IOutstanding Loans and Leases
  December 31
(Dollars in millions)20202019201820172016
Consumer     
Residential mortgage$223,555 $236,169 $208,557 $203,811 $191,797 
Home equity34,311 40,208 48,286 57,744 66,443 
Credit card78,708 97,608 98,338 96,285 92,278 
Non-U.S. credit card — — — 9,214 
Direct/Indirect consumer (1)
91,363 90,998 91,166 96,342 95,962 
Other consumer (2)
124 192 202 166 626 
Total consumer loans excluding loans accounted for under the fair value option428,061 465,175 446,549 454,348 456,320 
Consumer loans accounted for under the fair value option (3)
735 594 682 928 1,051 
Total consumer428,796 465,769 447,231 455,276 457,371 
Commercial
U.S. commercial288,728 307,048 299,277 284,836 270,372 
Non-U.S. commercial90,460 104,966 98,776 97,792 89,397 
Commercial real estate (4)
60,364 62,689 60,845 58,298 57,355 
Commercial lease financing17,098 19,880 22,534 22,116 22,375 
456,650 494,583 481,432 463,042 439,499 
U.S. small business commercial (5)
36,469 15,333 14,565 13,649 12,993 
Total commercial loans excluding loans accounted for under the fair value option493,119 509,916 495,997 476,691 452,492 
Commercial loans accounted for under the fair value option (3)
5,946 7,741 3,667 4,782 6,034 
Total commercial499,065 517,657 499,664 481,473 458,526 
Less: Loans of business held for sale (6)
 — — — (9,214)
Total loans and leases$927,861 $983,426 $946,895 $936,749 $906,683 
(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.
(4)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.
(5)Includes card-related products.
(6)Represents non-U.S. credit card loans, which were included in assets of business held for sale on the Consolidated Balance Sheet.

89 Bank of America


Table II
Nonperforming Loans, Leases and Foreclosed Properties (1)
 December 31
(Dollars in millions)20202019201820172016
Consumer     
Residential mortgage$2,005 $1,470 $1,893 $2,476 $3,056 
Home equity649 536 1,893 2,644 2,918 
Direct/Indirect consumer71 47 56 46 28 
Other consumer — — — 
Total consumer (2)
2,725 2,053 3,842 5,166 6,004 
Commercial   
U.S. commercial1,243 1,094 794 814 1,256 
Non-U.S. commercial418 43 80 299 279 
Commercial real estate404 280 156 112 72 
Commercial lease financing87 32 18 24 36 
 2,152 1,449 1,048 1,249 1,643 
U.S. small business commercial75 50 54 55 60 
Total commercial (3)
2,227 1,499 1,102 1,304 1,703 
Total nonperforming loans and leases4,952 3,552 4,944 6,470 7,707 
Foreclosed properties164 285 300 288 377 
Total nonperforming loans, leases and foreclosed properties$5,116 $3,837 $5,244 $6,758 $8,084 
(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 million and $1.2 billion at December 31, 2020, 2019, 2018, 2017 and 2016, respectively.
(2)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.
(3)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)
 December 31
(Dollars in millions)20202019201820172016
Consumer     
Residential mortgage (2)
$762 $1,088 $1,884 $3,230 $4,793 
Credit card903 1,042 994 900 782 
Non-U.S. credit card — — — 66 
Direct/Indirect consumer33 33 38 40 34 
Other consumer — — — 
Total consumer1,698 2,163 2,916 4,170 5,679 
Commercial   
U.S. commercial 228 106 197 144 106 
Non-U.S. commercial10 — 
Commercial real estate6 19 
Commercial lease financing25 20 29 19 19 
 269 153 230 170 137 
U.S. small business commercial115 97 84 75 71 
Total commercial384 250 314 245 208 
Total accruing loans and leases past due 90 days or more$2,082 $2,413 $3,230 $4,415 $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.

Bank of America 90


Table IV
Selected Loan Maturity Data (1, 2)
 December 31, 2020
(Dollars in millions)Due in One
Year or Less
Due After One Year Through Five YearsDue After
Five Years
Total
U.S. commercial$82,577 $198,898 $46,642 $328,117 
U.S. commercial real estate14,073 37,552 5,552 57,177 
Non-U.S. and other (3)
33,196 54,488 8,989 96,673 
Total selected loans$129,846 $290,938 $61,183 $481,967 
Percent of total27 %60 %13 %100 %
Sensitivity of selected loans to changes in interest rates for loans due after one year:    
Fixed interest rates $46,911 $32,280  
Floating or adjustable interest rates 244,027 28,903  
Total $290,938 $61,183  
(1)Loan maturities are based on the remaining maturities under contractual terms.
(2)Includes loans accounted for under the fair value option.
(3)Loan maturities include non-U.S. commercial and commercial real estate loans.
Table V
Allowance for Credit Losses (1)
(Dollars in millions)20202019201820172016
Allowance for loan and lease losses, January 1$12,358 $9,601 $10,393 $11,237 $12,234 
Loans and leases charged off   
Residential mortgage(40)(93)(207)(188)(403)
Home equity(58)(429)(483)(582)(752)
Credit card(2,967)(3,535)(3,345)(2,968)(2,691)
Non-U.S. credit card (2)
 — — (103)(238)
Direct/Indirect consumer(372)(518)(495)(491)(392)
Other consumer(307)(249)(197)(212)(232)
Total consumer charge-offs(3,744)(4,824)(4,727)(4,544)(4,708)
U.S. commercial (3)
(1,163)(650)(575)(589)(567)
Non-U.S. commercial(168)(115)(82)(446)(133)
Commercial real estate(275)(31)(10)(24)(10)
Commercial lease financing(69)(26)(8)(16)(30)
Total commercial charge-offs(1,675)(822)(675)(1,075)(740)
Total loans and leases charged off(5,419)(5,646)(5,402)(5,619)(5,448)
Recoveries of loans and leases previously charged off   
Residential mortgage70 140 179 288 272 
Home equity131 787 485 369 347 
Credit card618 587 508 455 422 
Non-U.S. credit card (2)
 — — 28 63 
Direct/Indirect consumer250 309 300 277 258 
Other consumer23 15 15 49 27 
Total consumer recoveries1,092 1,838 1,487 1,466 1,389 
U.S. commercial (4)
178 122 120 142 175 
Non-U.S. commercial13 31 14 13 
Commercial real estate5 15 41 
Commercial lease financing10 11 
Total commercial recoveries206 160 152 174 238 
Total recoveries of loans and leases previously charged off1,298 1,998 1,639 1,640 1,627 
Net charge-offs(4,121)(3,648)(3,763)(3,979)(3,821)
Provision for loan and lease losses10,565 3,574 3,262 3,381 3,581 
Other (5)
 (111)(291)(246)(514)
Total allowance for loan and lease losses, December 3118,802 9,416 9,601 10,393 11,480 
Less: Allowance included in assets of business held for sale (6)
 — — — (243)
Allowance for loan and lease losses, December 3118,802 9,416 9,601 10,393 11,237 
Reserve for unfunded lending commitments, January 11,123 797 777 762 646 
Provision for unfunded lending commitments755 16 20 15 16 
Other (5)
 — — — 100 
Reserve for unfunded lending commitments, December 311,878 813 797 777 762 
Allowance for credit losses, December 31$20,680 $10,229 $10,398 $11,170 $11,999 
(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.
(4)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.
(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.
91 Bank of America


Table VAllowance for Credit Losses (continued)
(Dollars in millions)20202019201820172016
Loan and allowance ratios (7):
Loans and leases outstanding at December 31 (8)
$921,180 $975,091 $942,546 $931,039 $908,812 
Allowance for loan and lease losses as a percentage of total loans and leases outstanding at December 31 (8)
2.04 %0.97 %1.02 %1.12 %1.26 %
Consumer allowance for loan and lease losses as a percentage of total consumer loans and leases outstanding at December 31 (9)
2.35 0.98 1.08 1.18 1.36 
Commercial allowance for loan and lease losses as a percentage of total commercial loans and leases outstanding at December 31 (10)
1.77 0.96 0.97 1.05 1.16 
Average loans and leases outstanding (8)
$974,281 $951,583 $927,531 $911,988 $892,255 
Net charge-offs as a percentage of average loans and leases outstanding (8)
0.42 %0.38 %0.41 %0.44 %0.43 %
Allowance for loan and lease losses as a percentage of total nonperforming loans and leases at December 31380 265 194 161 149 
Ratio of the allowance for loan and lease losses at December 31 to net charge-offs4.56 2.58 2.55 2.61 3.00 
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)
$9,854 $4,151 $4,031 $3,971 $3,951 
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)
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)
 December 31
20202019201820172016
(Dollars in millions)AmountPercent
of Total
AmountPercent
of Total
AmountPercent
of Total
AmountPercent
of Total
AmountPercent
of Total
Allowance for loan and lease losses          
Residential mortgage$459 2.44 %$325 3.45 %$422 4.40 %$701 6.74 %$1,012 8.82 %
Home equity399 2.12 221 2.35 506 5.27 1,019 9.80 1,738 15.14 
Credit card8,420 44.79 3,710 39.39 3,597 37.47 3,368 32.41 2,934 25.56 
Non-U.S. credit card  — — — — — — 243 2.12 
Direct/Indirect consumer752 4.00 234 2.49 248 2.58 264 2.54 244 2.13 
Other consumer41 0.22 52 0.55 29 0.30 31 0.30 51 0.44 
Total consumer10,071 53.57 4,542 48.23 4,802 50.02 5,383 51.79 6,222 54.21 
U.S. commercial (2)
5,043 26.82 3,015 32.02 3,010 31.35 3,113 29.95 3,326 28.97 
Non-U.S. commercial1,241 6.60 658 6.99 677 7.05 803 7.73 874 7.61 
Commercial real estate2,285 12.15 1,042 11.07 958 9.98 935 9.00 920 8.01 
Commercial lease financing162 0.86 159 1.69 154 1.60 159 1.53 138 1.20 
Total commercial8,731 46.43 4,874 51.77 4,799 49.98 5,010 48.21 5,258 45.79 
Total allowance for loan and lease losses18,802 100.00 %9,416 100.00 %9,601 100.00 %10,393 100.00 %11,480 100.00 %
Less: Allowance included in assets of business held for sale (3)
 — — — (243)
Allowance for loan and lease losses18,802 9,416 9,601 10,393 11,237 
Reserve for unfunded lending commitments1,878 813  797 777 762 
Allowance for credit losses$20,680 $10,229  $10,398 $11,170 $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 Statements.
(2)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.
Bank of America 92


Item 7A. Quantitative and Qualitative Disclosures about Market Risk
See Market Risk Management on page 78 in the MD&A and the sections referenced therein for Quantitative and Qualitative Disclosures about Market Risk.
Item 8. Financial Statements and Supplementary Data
Table of Contents
93 Bank of America




Report of Management on Internal Control Over Financial Reporting
The management of Bank of America Corporation is responsible for establishing and maintaining adequate internal control over financial reporting.
The Corporation’s internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with accounting principles generally accepted in the United States of America. The Corporation’s internal control over financial reporting includes those policies and procedures that (i) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the Corporation; (ii) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with accounting principles generally accepted in the United States of America, and that receipts and expenditures of the Corporation are being made only in accordance with authorizations of management and directors of the Corporation; and (iii) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use, or disposition of the Corporation’s assets that could have a material effect on the financial statements.
Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

Management assessed the effectiveness of the Corporation’s internal control over financial reporting as of December 31, 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.
The Corporation’s internal control over financial reporting as of December 31, 2020 has been audited by PricewaterhouseCoopers, LLP, an independent registered public accounting firm, as stated in their accompanying report which expresses an unqualified opinion on the effectiveness of the Corporation’s internal control over financial reporting as of December 31, 2020.
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Brian T. Moynihan
Chairman, Chief Executive Officer and President

bac-20201231_g6.jpg
Paul M. Donofrio
Chief Financial Officer

Bank of America 94


Report of Independent Registered Public Accounting Firm
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 in Note 1 to the consolidated financial statements, the Corporation changed the manner in which it accounts for credit losses on certain financial instruments in 2020.
Basis for Opinions
The Corporation’s management is responsible 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 maintained in all material respects. Our audits of the consolidated financial statements included performing 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 regarding the amounts and disclosures in the consolidated financial statements. Our audits also included evaluating the
accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the consolidated financial statements. Our audit of internal control over financial reporting included obtaining an understanding of internal control over financial reporting, assessing the risk that a material weakness exists, and testing and evaluating the design and operating effectiveness of internal control based on the assessed risk. Our audits also included performing such other procedures as we considered necessary in the circumstances. We believe that our audits provide a reasonable basis for our opinions.
Definition and Limitations of Internal Control over Financial Reporting
A company’s internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles. A company’s internal control over financial reporting includes those policies and procedures that (i) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of 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 probablethe 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 $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
95 Bank of America


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 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. 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 others. Further, the Corporation considers the inherent uncertainty in quantitative models that are built on historical data.
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 auditor judgment, subjectivity and effort in performing 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.
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. These procedures also included, among others, testing management’s process for estimating the allowance for loan losses, including (i) evaluating the appropriateness of the loss forecast models and methodology, (ii) evaluating the 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 also included the involvement of professionals with specialized
skill and knowledge to assist in evaluating the appropriateness of certain loss forecast models, the reasonableness of economic forecast scenarios and related weightings and the reasonableness of certain qualitative reserves.
Valuation of Certain Level 3 Financial Instruments
As described in Notes 1 and 20 to the consolidated financial statements, the Corporation carries certain 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 judgment or estimation. The Corporation determines the fair value of Level 3 financial instruments using pricing models, discounted cash flow 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 be determined using quantitative-based extrapolations or other internal methodologies which incorporate management estimates and available market information.
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 procedures, including the involvement of professionals with specialized skill and knowledge to assist in evaluating certain audit evidence.
Addressing the matter involved performing procedures and evaluating audit evidence in connection with forming our overall opinion on the consolidated financial statements. These procedures included testing the effectiveness of controls relating to the valuation of financial instruments, including controls related to valuation models, significant unobservable inputs, and data. These procedures also included, among others, the involvement of professionalswith specialized skill and knowledge to assist in developing an independent estimate of fair value for a sample of these certain financial instruments and comparison of management’s estimate to the independently developed estimate of fair value. Developing the independent estimate involved testing the completeness and accuracy of data provided by management and evaluating the reasonableness of management’s assumptions used to develop the significant unobservable inputs.

bac-20201231_g7.jpg

Charlotte, North Carolina
February 24, 2021

We have served as the Corporation’s auditor since 1958.


Bank of America 96


Bank of America Corporation and Subsidiaries
Consolidated Statement of Income
(In millions, except per share information)202020192018
Net interest income 
Interest income$51,585 $71,236 $66,769 
Interest expense8,225 22,345 18,607 
Net interest income43,360 48,891 48,162 
Noninterest income 
Fees and commissions34,551 33,015 33,078 
Market making and similar activities8,355 9,034 9,008 
Other income(738)304 772 
Total noninterest income42,168 42,353 42,858 
Total revenue, net of interest expense85,528 91,244 91,020 
Provision for credit losses11,320 3,590 3,282 
Noninterest expense
Compensation and benefits32,725 31,977 31,880 
Occupancy and equipment7,141 6,588 6,380 
Information processing and communications5,222 4,646 4,555 
Product delivery and transaction related3,433 2,762 2,857 
Marketing1,701 1,934 1,674 
Professional fees1,694 1,597 1,699 
Other general operating3,297 5,396 4,109 
Total noninterest expense55,213 54,900 53,154 
Income before income taxes18,995 32,754 34,584 
Income tax expense1,101 5,324 6,437 
Net income$17,894 $27,430 $28,147 
Preferred stock dividends1,421 1,432 1,451 
Net income applicable to common shareholders$16,473 $25,998 $26,696 
Per common share information 
Earnings$1.88 $2.77 $2.64 
Diluted earnings1.87 2.75 2.61 
Average common shares issued and outstanding8,753.2 9,390.5 10,096.5 
Average diluted common shares issued and outstanding8,796.9 9,442.9 10,236.9 
Consolidated Statement of Comprehensive Income
(Dollars in millions)202020192018
Net income$17,894 $27,430 $28,147 
Other comprehensive income (loss), net-of-tax:
Net change in debt securities4,799 5,875 (3,953)
Net change in debit valuation adjustments(498)(963)749 
Net change in derivatives826 616 (53)
Employee benefit plan adjustments(98)136 (405)
Net change in foreign currency translation adjustments(52)(86)(254)
Other comprehensive income (loss)4,977 5,578 (3,916)
Comprehensive income$22,871 $33,008 $24,231 
See accompanying Notes to Consolidated Financial Statements.
97 Bank of America


Bank of America Corporation and Subsidiaries
Consolidated Balance Sheet
December 31
(Dollars in millions)20202019
Assets
Cash and due from banks$36,430 $30,152 
Interest-bearing deposits with the Federal Reserve, non-U.S. central banks and other banks344,033 131,408 
Cash and cash equivalents380,463 161,560 
Time deposits placed and other short-term investments6,546 7,107 
Federal funds sold and securities borrowed or purchased under agreements to resell
   (includes $108,856 and $50,364 measured at fair value)
304,058 274,597 
Trading account assets (includes $91,510 and $90,946 pledged as collateral)
198,854 229,826 
Derivative assets47,179 40,485 
Debt securities: 
Carried at fair value246,601 256,467 
Held-to-maturity, at cost (fair value – $448,180 and $219,821)
438,249 215,730 
Total debt securities684,850 472,197 
Loans and leases (includes $6,681 and $8,335 measured at fair value)
927,861 983,426 
Allowance for loan and lease losses(18,802)(9,416)
Loans and leases, net of allowance909,059 974,010 
Premises and equipment, net11,000 10,561 
Goodwill68,951 68,951 
Loans held-for-sale (includes $1,585 and $3,709 measured at fair value)
9,243 9,158 
Customer and other receivables64,221 55,937 
Other assets (includes $15,718 and $15,518 measured at fair value)
135,203 129,690 
Total assets$2,819,627 $2,434,079 
Liabilities  
Deposits in U.S. offices:  
Noninterest-bearing$650,674 $403,305 
Interest-bearing (includes $481 and $508 measured at fair value)
1,038,341 940,731 
Deposits in non-U.S. offices:
Noninterest-bearing17,698 13,719 
Interest-bearing88,767 77,048 
Total deposits1,795,480 1,434,803 
Federal funds purchased and securities loaned or sold under agreements to repurchase
   (includes $135,391 and $16,008 measured at fair value)
170,323 165,109 
Trading account liabilities71,320 83,270 
Derivative liabilities45,526 38,229 
Short-term borrowings (includes $5,874 and $3,941 measured at fair value)
19,321 24,204 
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)
181,799 182,798 
Long-term debt (includes $32,200 and $34,975 measured at fair value)
262,934 240,856 
Total liabilities2,546,703 2,169,269 
Commitments and contingencies (Note 6 – Securitizations and Other Variable Interest Entities
   and Note 12 – Commitments and Contingencies)
00
Shareholders’ equity 
Preferred stock, $0.01 par value; authorized – 100,000,000 shares; issued and outstanding – 3,931,440 and 3,887,440 shares
24,510 23,401 
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
85,982 91,723 
Retained earnings164,088 156,319 
Accumulated other comprehensive income (loss)(1,656)(6,633)
Total shareholders’ equity272,924 264,810 
Total liabilities and shareholders’ equity$2,819,627 $2,434,079 
Assets of consolidated variable interest entities included in total assets above (isolated to settle the liabilities of the variable interest entities)
Trading account assets$5,225 $5,811 
Loans and leases23,636 38,837 
Allowance for loan and lease losses(1,693)(807)
Loans and leases, net of allowance21,943 38,030 
All other assets1,387 540 
Total assets of consolidated variable interest entities$28,555 $44,381 
Liabilities of consolidated variable interest entities included in total liabilities above  
Short-term borrowings (includes $22 and $0 of non-recourse short-term borrowings)
$454 $2,175 
Long-term debt (includes $7,053 and $8,717 of non-recourse debt)
7,053 8,718 
All other liabilities (includes $16 and $19 of non-recourse liabilities)
16 22 
Total liabilities of consolidated variable interest entities$7,523 $10,915 
See accompanying Notes to Consolidated Financial Statements.
Bank of America 98


Bank of America Corporation and Subsidiaries
Consolidated Statement of Changes in Shareholders’ Equity
Preferred
Stock
Common Stock and
Additional Paid-in Capital
Retained
Earnings
Accumulated
Other
Comprehensive
Income (Loss)
Total
Shareholders’
Equity
(In millions)SharesAmount
Balance, December 31, 2017$22,323 10,287.3 $138,089 $113,816 $(7,082)$267,146 
Cumulative adjustment for adoption of hedge accounting
standard
(32)57 25 
Adoption of accounting standard related to certain tax effects
stranded in accumulated other comprehensive income (loss)
1,270 (1,270)
Net income   28,147 28,147 
Net change in debt securities    (3,953)(3,953)
Net change in debit valuation adjustments749 749 
Net change in derivatives    (53)(53)
Employee benefit plan adjustments    (405)(405)
Net change in foreign currency translation adjustments   (254)(254)
Dividends declared:    
Common (5,424) (5,424)
Preferred  (1,451) (1,451)
Issuance of preferred stock4,515 4,515 
Redemption of preferred stock(4,512)(4,512)
Common stock issued under employee plans, net, and other58.2 901 (12) 889 
Common stock repurchased(676.2)(20,094)(20,094)
Balance, December 31, 2018$22,326 9,669.3 $118,896 $136,314 $(12,211)$265,325 
Cumulative adjustment for adoption of lease accounting
standard
165 165 
Net income27,430 27,430 
Net change in debt securities5,875 5,875 
Net change in debit valuation adjustments(963)(963)
Net change in derivatives616 616 
Employee benefit plan adjustments136 136 
Net change in foreign currency translation adjustments(86)(86)
Dividends declared:
Common(6,146)(6,146)
Preferred(1,432)(1,432)
Issuance of preferred stock3,643 3,643 
Redemption of preferred stock(2,568)(2,568)
Common stock issued under employee plans, net, and other123.3 971 (12)959 
Common stock repurchased(956.5)(28,144)(28,144)
Balance, December 31, 2019$23,401 8,836.1 $91,723 $156,319 $(6,633)$264,810 
Cumulative adjustment for adoption of credit loss accounting
standard
(2,406)(2,406)
Net income17,894 17,894 
Net change in debt securities4,799 4,799 
Net change in debit valuation adjustments(498)(498)
Net change in derivatives826 826 
Employee benefit plan adjustments(98)(98)
Net change in foreign currency translation adjustments(52)(52)
Dividends declared:
Common(6,289)(6,289)
Preferred(1,421)(1,421)
Issuance of preferred stock2,181 2,181 
Redemption of preferred stock(1,072)(1,072)
Common stock issued under employee plans, net, and other41.7 1,284 (9)1,275 
Common stock repurchased(227.0)(7,025)(7,025)
Balance, December 31, 2020$24,510 8,650.8 $85,982 $164,088 $(1,656)$272,924 
See accompanying Notes to Consolidated Financial Statements.
99 Bank of America


Bank of America Corporation and Subsidiaries
Consolidated Statement of Cash Flows
(Dollars in millions)202020192018
Operating activities   
Net income$17,894 $27,430 $28,147 
Adjustments to reconcile net income to net cash provided by operating activities:   
Provision for credit losses11,320 3,590 3,282 
Gains on sales of debt securities(411)(217)(154)
Depreciation and amortization1,843 1,729 2,063 
Net amortization of premium/discount on debt securities4,101 2,066 1,824 
Deferred income taxes(1,737)2,435 3,041 
Stock-based compensation2,031 1,974 1,729 
Impairment of equity method investment0 2,072 
Loans held-for-sale:
Originations and purchases(19,657)(28,874)(28,071)
Proceeds from sales and paydowns of loans originally classified as held for sale and instruments
from related securitization activities
19,049 30,191 28,972 
Net change in:
Trading and derivative assets/liabilities16,942 7,920 (23,673)
Other assets(12,883)(11,113)11,920 
Accrued expenses and other liabilities(4,385)16,363 13,010 
Other operating activities, net3,886 6,211 (2,570)
Net cash provided by operating activities37,993 61,777 39,520 
Investing activities   
Net change in:
Time deposits placed and other short-term investments561 387 3,659 
Federal funds sold and securities borrowed or purchased under agreements to resell(29,461)(13,466)(48,384)
Debt securities carried at fair value:
Proceeds from sales77,524 52,006 5,117 
Proceeds from paydowns and maturities91,084 79,114 78,513 
Purchases(194,877)(152,782)(76,640)
Held-to-maturity debt securities:
Proceeds from paydowns and maturities93,835 34,770 18,789 
Purchases(257,535)(37,115)(35,980)
Loans and leases:
Proceeds from sales of loans originally classified as held for investment and instruments
from related securitization activities
13,351 12,201 21,365 
Purchases(5,229)(5,963)(4,629)
Other changes in loans and leases, net36,571 (46,808)(31,292)
Other investing activities, net(3,489)(2,974)(1,986)
Net cash used in investing activities(177,665)(80,630)(71,468)
Financing activities   
Net change in:
Deposits360,677 53,327 71,931 
Federal funds purchased and securities loaned or sold under agreements to repurchase5,214 (21,879)10,070 
Short-term borrowings(4,893)4,004 (12,478)
Long-term debt:
Proceeds from issuance57,013 52,420 64,278 
Retirement(47,948)(50,794)(53,046)
Preferred stock:
Proceeds from issuance2,181 3,643 4,515 
Redemption(1,072)(2,568)(4,512)
Common stock repurchased(7,025)(28,144)(20,094)
Cash dividends paid(7,727)(5,934)(6,895)
Other financing activities, net(601)(698)(651)
Net cash provided by financing activities355,819 3,377 53,118 
Effect of exchange rate changes on cash and cash equivalents2,756 (368)(1,200)
Net increase (decrease) in cash and cash equivalents218,903 (15,844)19,970 
Cash and cash equivalents at January 1161,560 177,404 157,434 
Cash and cash equivalents at December 31$380,463 $161,560 $177,404 
Supplemental cash flow disclosures
Interest paid$8,662 $22,196 $19,087 
Income taxes paid, net2,894 4,359 2,470 
See accompanying Notes to Consolidated Financial Statements.
Bank of America 100


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 for credit losses was determined based on management’s estimate of probable incurred losses.

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
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 regulations, and amounts due from correspondent banks, the Federal Reserve Bank and certain non-U.S. central banks. Certain cash balances are restricted as to withdrawal or usage by legally binding contractual agreements or regulatory requirements.
Securities Financing Agreements
Securities borrowed or purchased under agreements to resell and securities loaned or sold under agreements to repurchase (securities financing agreements) are treated as collateralized financing transactions except in instances where the transaction is required to be accounted for as individual sale and purchase transactions. Generally, these agreements are recorded at acquisition or sale price plus accrued interest, except for securities financing agreements that the Corporation accounts for under the fair value option. Changes in the fair value of securities financing agreements that are accounted for under the fair value option are recorded in market making and similar activities in the Consolidated Statement of Income.
The Corporation’s policy is to monitor the market value of the principal amount loaned under resale agreements and obtain collateral from or return collateral pledged to counterparties when appropriate. Securities financing agreements do not create material credit risk due to these collateral provisions; therefore, an allowance for loan losses is not necessary.
In transactions where the Corporation acts as the lender in a securities lending agreement and receives securities that can be pledged or sold as collateral, it recognizes an asset on the Consolidated Balance Sheet at fair value, representing the securities received, and a liability, representing the obligation to return those securities.
Collateral
The Corporation accepts securities and loans as collateral that it is permitted by contract or practice to sell or repledge. At December 31, 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.
101 Bank of America


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 (referred to as other risk management activities). The Corporation manages interest rate and foreign currency exchange rate sensitivity predominantly through the use of derivatives. Derivatives utilized by the Corporation include swaps, futures and forward settlement contracts, and option contracts.
All derivatives are recorded on the Consolidated Balance Sheet at fair value, taking into consideration the effects of legally enforceable master netting agreements that allow the Corporation to settle positive and negative positions and offset cash collateral held with the same counterparty on a net basis. For exchange-traded contracts, fair value is based on quoted market prices in active or inactive markets or is derived from observable market-based pricing parameters, similar to those applied to over-the-counter (OTC) derivatives. For non-exchange traded contracts, fair value is based on dealer quotes, pricing models, discounted cash flow methodologies or similar techniques for which the determination of fair value may require significant management judgment or estimation.
Valuations of derivative assets and liabilities reflect the value of the instrument including counterparty credit risk. These values also take into account the Corporation’s own credit standing.
Trading Derivatives and Other Risk Management Activities
Derivatives held for trading purposes are included in derivative assets or derivative liabilities on the Consolidated Balance Sheet with changes in fair value included in market making and similar activities.
Derivatives used for other risk management activities are included in derivative assets or derivative liabilities. Derivatives used in other risk management activities have not been designated in qualifying accounting hedge relationships because they did not qualify or the risk that is being mitigated pertains to an item that is reported at fair value through earnings so that
the effect of measuring the derivative instrument and the asset or liability to which the risk exposure pertains will offset in the Consolidated Statement of Income to the extent effective. The changes in the fair value of derivatives that serve to mitigate certain risks associated with mortgage servicing rights (MSRs), interest rate lock commitments (IRLCs) and first-lien mortgage loans held-for-sale (LHFS) that are originated by the Corporation are recorded in other income. Changes in the fair value of derivatives that serve to mitigate interest rate risk and foreign currency risk are included in market making and similar activities. Credit derivatives are also used by the Corporation to mitigate the risk associated with various credit exposures. The changes in the fair value of these derivatives are included in market making and similar activities and other income.
Derivatives Used For Hedge Accounting Purposes (Accounting Hedges)
For accounting hedges, the Corporation formally documents at inception all relationships between hedging instruments and hedged items, as well as the risk management objectives and strategies for undertaking various accounting hedges. Additionally, the Corporation primarily uses regression analysis at the inception of a hedge and for each reporting period thereafter to assess whether the derivative used in an accounting hedge transaction is expected to be and has been highly effective in offsetting changes in the fair value or cash flows of a hedged item or forecasted transaction. The Corporation discontinues hedge accounting when it is determined that a derivative is not expected to be or has ceased to be highly effective as a hedge, and then reflects changes in fair value of the derivative in earnings after termination of the hedge relationship.
Fair value hedges are used to protect against changes in the fair value of the Corporation’s assets and liabilities that are attributable to interest rate or foreign exchange volatility. Changes in the fair value of derivatives designated as fair value hedges are recorded in earnings, together and in the same income statement line item with changes in the fair value of the related hedged item. If a derivative instrument in a fair value hedge is terminated or the hedge designation removed, the previous adjustments to the carrying value of the hedged asset or liability are subsequently accounted for in the same manner as other components of the carrying value of that asset or liability. For interest-earning assets and interest-bearing liabilities, such adjustments are amortized to earnings over the remaining life of the respective asset or liability.
Cash flow hedges are used primarily to minimize the variability in cash flows of assets and liabilities or forecasted transactions caused by interest rate or foreign exchange rate fluctuations. The Corporation also uses cash flow hedges to hedge the price risk associated with deferred compensation. Changes in the fair value of derivatives used in cash flow hedges are recorded in accumulated other comprehensive 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
Bank of America 102


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.
Equity securities with readily determinable fair values that are not held for trading purposes are carried at fair value with unrealized gains and losses included in other income. Equity securities that do not have readily determinable fair values are recorded at cost less impairment, if any, plus or minus qualifying observable price changes. These securities are reported in other assets.
Loans and Leases
Loans, with the exception of loans accounted for under the fair value option, are measured at historical cost and reported at their outstanding principal balances net of any unearned income, charge-offs, unamortized deferred fees and costs on originated loans, and for purchased loans, net of any unamortized premiums or discounts. Loan origination fees and certain direct origination costs are deferred and recognized as adjustments to interest income over the lives of the related loans. Unearned income, discounts and premiums are amortized to interest income using a level yield methodology. The Corporation elects to account for certain consumer and commercial loans under the fair value option with interest reported in interest income and changes in fair value reported in market making and similar activities or other income.
Under applicable accounting guidance, for reporting purposes, the loan and lease portfolio is categorized by portfolio segment and, within each portfolio segment, by class of financing receivables. A portfolio segment is defined as the level at which an entity develops and documents a systematic methodology to determine the allowance for credit losses, and a class of financing receivables is defined as the level of disaggregation of portfolio segments based on the initial measurement attribute, risk characteristics and methods for assessing risk. The Corporation’s 3 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 allowance for loan and lease losses represents the estimated probable credit lossesECL on funded consumer and commercial loans and leases whileis referred to as the reserveallowance 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 represents estimated probableis reported on the Consolidated Balance Sheet in accrued expenses and other liabilities. The provision for credit losses on theserelated to the loan and lease portfolio and unfunded credit instruments based on utilization assumptions. Lending-related credit exposures deemed to be uncollectible, excludinglending commitments is reported in the Consolidated Statement of Income.
For loans carried at fair value, are charged off against these accounts. Write-offs on PCI loans on which thereand leases, the ECL is a valuation allowance are recorded against the valuation allowance. For more information, see Purchased Credit-impaired Loans in this Note.
The Corporation performs periodic and systematic detailed reviews of its lending portfolios to identify credit risks and to assess the overall collectability of those portfolios. The allowance on certain homogeneous consumer loan portfolios, which generally consist of consumer real estate loans within the Consumer Real Estate portfolio segment and credit card loans within the Credit Card and Other Consumer portfolio segment, is based on aggregated portfolio segment evaluations generally by product type. Loss forecast models are utilized for these portfolios whichtypically estimated using quantitative methods that consider a variety of factors including,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 forecasting framework, 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, historical loss experience, estimated defaults or foreclosuresunemployment 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 trends, delinquencies, bankruptcies,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 conditions, credit scoresoutlook as discussed above. For purposes of computing this specific loss component of the allowance, larger impaired loans are evaluated individually and the amount of losssmaller impaired loans are evaluated as a pool.
Also included in the eventallowance 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 default.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
others. Further, the Corporation considers the inherent uncertainty in quantitative models that are built on historical data.
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 generally classifies consumer loans as 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.
The Corporation has identified the following 3 portfolio segments and measures the allowance for credit losses using the following methods.
Consumer Real Estate
To estimate ECL for consumer loans secured by residential real estate, using statistical modeling methodologies, the Corporation estimates the number of loans that will default based onover the individual loan attributes aggregated into poolslife of homogeneous loans with similar attributes.the existing portfolio, after factoring in estimated prepayments, using quantitative modeling methodologies. The attributes that are most significant toin estimating the probability of default and are used to estimate defaultsCorporation’s ECL include refreshed LTVloan-to-value (LTV) or, in the case of a subordinated lien, refreshed combined LTV (CLTV), borrower credit score, months since origination (referred to as vintage) and geography, all of which are further broken down by present collection status (whether the loan is current, delinquent, in default, or in bankruptcy). The severity or loss given default is estimated based on the refreshed LTV for first mortgages or CLTV for subordinated liens. The estimates are based on the Corporation’s historical experience with the loan portfolio, adjusted to reflect an assessment of environmental factors not yet reflected in the historical data underlyingeconomic outlook. The outlook on the loss estimates, such as changes inunemployment rate and consumer real estate values, localprices are key factors that impact the frequency and national economies, underwriting standardsseverity 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 regulatory environment. The probabilityECL associated with the undrawn portion of default models also incorporate recent experience with modification programs including re-defaults subsequent to modification, a loan’s default history prior to modification and the change in borrower payments post-modification. On home equity loans whereCorporation’s HELOCs, which can only be canceled by the Corporation holds only a second-lien position and foreclosure is not the best alternative, the loss severity is estimated at 100 percent.
if certain criteria are met. The allowance on certain commercial loans (except business card and certain small business loans)ECL associated with these unfunded lending commitments is calculated using loss rates delineated by risk ratingthe same models and product type. Factors considered when assessing loss rates include the valuemethodologies noted above and incorporate utilization assumptions at time of the underlying collateral, if applicable, the industry of the obligor, and the obligor’s liquidity and other financial indicators along with certain qualitative factors. These statistical models are updated regularly for changes in economic and business conditions. Included in the analysis of consumer and commercial loan portfolios are reserves which are maintained to cover uncertainties that affect the Corporation’s estimate of probable losses including domestic and global economic uncertainty and large single-name defaults.
default.


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For impaired loans, which include nonperforming commercial loans as well as consumer and commercial loans and leases modified in a troubled debt restructuring (TDR), management measures impairment primarily based on the present value of payments expected to be received, discounted at the loans’ original effective contractual interest rates. Credit card loans are discounted at the portfolio average contractual annual percentage rate, excluding promotionally priced loans, in effect prior to restructuring. Impaired loans and TDRs may also be measured based on observable market prices, or for loans that are solely dependentmore than 180 days past due and collateral-dependent TDRs, the Corporation bases the allowance on the collateral for repayment, the estimated fair value of the underlying collateral as of the reporting date less costs to sell. If the recorded investment in impaired loans exceeds this amount, a specific allowance is established as a component of the allowance for loan and lease losses unless these are secured consumer loans that are solely dependent on the collateral for repayment, in which case the amount that exceeds the fair value of the collateral is charged off.
Generally, the Corporation initially estimates theThe fair value of the collateral securing these consumer real estate-secured loans is generally determined using an automated valuation model (AVM). An AVM is a tool that estimates the value of a property by reference to market data including sales of comparable properties and price trends specific to the Metropolitan Statistical Area in which the property being valued is located. In the event that an AVM value is not available, the Corporation utilizes publicized indices or if these methods provide less reliable valuations, the Corporation uses appraisals or broker price opinions to estimate the fair value of the collateral. While there is inherent imprecision in these valuations, the Corporation believes that they are representative of thethis portfolio in the aggregate.
For loans that are more than 180 days past due and collateral-dependent TDRs, with the exception of the Corporation’s fully insured portfolio, the outstanding balance of loans that is in excess of the estimated property value after
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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 (e.g., borrowers making full payments, 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.
In addition to the allowance for loan and lease losses, the Corporation also estimates probable lossesECL 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 loan commitments. Unfunded lending commitments are subject to individual reviewsexposure using the same models and methodologies as the funded exposure and are analyzed and segregated by risk according to the Corporation’s internal risk rating scale. These risk classifications, in conjunction with an analysis of historical loss experience, utilization assumptions, current economic conditions, performance trends within the portfolio and any other pertinent information, result in the estimation of the reservereported as reserves for unfunded lending commitments.
The allowance for credit losses related to the loan and lease portfolio is reported separately on the Consolidated Balance Sheet whereas the reserve for unfunded lending commitments is reported on the Consolidated Balance Sheet in accrued expenses and other liabilities. The provision for credit losses related to the loan and lease portfolio and unfunded lending commitments is reported in the Consolidated Statement of Income.
Nonperforming Loans and Leases, Charge-offs and Delinquencies
Nonperforming loans and leases generally include loans and leases that have been placed on nonaccrual status. Loans accounted for under the fair value option PCI loans and LHFS are not reported as nonperforming.
In accordance with the Corporation’s policies, consumer real estate-secured loans, including residential mortgages and home equity loans, are generally placed on nonaccrual status and classified as nonperforming at 90 days past due unless repayment of the loan is insured by the Federal Housing Administration (FHA)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, or 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 no later thanin the end of the month in which the account becomes 180 days past due or 60 days after receipt of notification of death or bankruptcy. These loans are not placed on nonaccrual status prior to charge-off and, therefore, are not reportedsame manner as nonperformingconsumer 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.
PCI loans are recorded at fair value at the acquisition date. Although the PCI loans may be contractually delinquent, the Corporation does not classify these loans as nonperforming as the loans were written down to fair value at the acquisition date and the accretable yield is recognized in interest income over the remaining life of the loan. In addition, reported net charge-offs exclude write-offs on PCI loans as the fair value already considers the estimated credit losses.


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Troubled Debt Restructurings
Consumer and commercial loans and leases whose contractual terms have been restructured in a manner that grants a concession to a borrower experiencing financial difficulties are classified as TDRs. Concessions could include a reduction in the interest rate to a rate that is below market on the loan, payment extensions, forgiveness of principal, forbearance or other actions designed to maximize collections. Loans that are carried at fair value LHFS and PCI loansLHFS 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
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 that 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 are intendedthe Corporation intends to be soldsell in the foreseeable future, including residential mortgages, loan syndications, and to a lesser degree, commercial real estate, consumer finance and other loans, are reported as LHFS and are carried at the lower of aggregate cost or fair value. The Corporation accounts for certain LHFS, including residential mortgage LHFS, under the fair value option. Loan origination costs related to LHFS that the Corporation accounts for under the fair value option are recognized in noninterest expense when incurred. Loan origination costs for LHFS carried at the lower of cost or fair value are capitalized as part of the carrying value of the loans and, recognized as a reduction of noninterest income upon the sale of such loans.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.
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 federal 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 0. 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 commencement, lease liabilities are recognized based on the present value of the remaining lease payments and discounted using the Corporation’s incremental borrowing rate. Right-of-use assets initially equal the lease liability, adjusted for any lease payments made prior to lease commencement and for any lease incentives.
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 comparesassesses the fair value of each reporting unit withagainst its carrying value, including goodwill, as measured by allocated equity. For purposes of goodwill impairment testing, the Corporation utilizes allocated equity as a proxy for the carrying value of its reporting units. Allocated equity in the reporting units is comprised of allocated capital plus capital for the portion of goodwill and intangibles specifically assigned to the reporting unit.
In performing its goodwill impairment testing, the Corporation first assesses qualitative factors to determine whether it is more likely than not that the fair value of a reporting unit is less than its carrying value. Qualitative factors include, among other things, macroeconomic conditions, industry and market considerations, financial performance of the respective reporting unit and other relevant entity- and reporting-unit specific considerations.
If the Corporation concludes it is more likely than not that the fair value of a reporting unit is less than its carrying value, a quantitative assessment is performed. 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 iswould not be considered not impaired; however, ifimpaired. If the carrying value of the reporting unit exceeds its fair value, an additional step musta goodwill impairment loss would be performed to measure potential impairment.
This step involves calculating an implied fair value of goodwillrecognized for the amount by which is the excess of the fair value of the reporting unit, as determined in the first step, over the aggregateunit’s allocated equity exceeds its fair values of the assets, liabilities and identifiable intangibles as if the reporting unit was being acquired in a business combination. If the implied fair value of goodwill exceeds the goodwill assigned to the reporting unit, there is no impairment. If the goodwill assigned to a reporting unit exceeds the implied fair value of goodwill, an impairment charge is recorded for the excess.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
reversals of goodwill impairment losses are not permitted under applicable accounting guidance.
For intangible assets subject to amortization, an impairment loss is recognized if the carrying value of the intangible asset is not recoverable and exceeds fair value. The carrying value of the intangible asset is considered not recoverable if it exceeds the sum of the undiscounted cash flows expected to result from the use of the asset. Intangible assets deemed to have indefinite useful lives are not subject to amortization. An impairment loss is recognized if the carrying value of the intangible asset with an indefinite life exceeds its fair value.
Variable Interest Entities
A VIE is an entity that lacks equity investors or whose equity investors do not have a controlling financial interest in the entity through their equity investments. The Corporation consolidates a VIE if it has both the power to direct the activities of the VIE that most significantly impact the VIE’s economic performance and an obligation to absorb losses or the right to receive benefits that could potentially be significant to the VIE. On a quarterly basis, the Corporation reassesses its involvement with the VIE and evaluates the impact of changes in governing documents and its financial interests in the VIE. The consolidation status of the VIEs with which the Corporation is involved may change as a result of such reassessments.
The Corporation primarily uses VIEs for its securitization activities, in which the Corporation transfers whole loans or debt securities into a trust or other vehicle. When the Corporation is the servicer of whole loans held in a securitization trust, including non-agency residential mortgages, home equity loans, credit cards, and other loans, the Corporation has the power to direct the most significant activities of the trust. The Corporation generally does

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not have the power to direct the most significant activities of a residential mortgage agency trust except in certain circumstances in which the Corporation holds substantially all of the issued securities and has the unilateral right to liquidate the trust. The power to direct the most significant activities of a commercial mortgage securitization trust is typically held by the special servicer or by the party holding specific subordinate securities which embody certain controlling rights. The Corporation consolidates a whole-loan securitization trust if it has the power to direct the most significant activities and also holds securities issued by the trust or has other contractual arrangements, other than standard representations and warranties, that could potentially be significant to the trust.
The Corporation may also transfer trading account securities and AFS securities into municipal bond or resecuritization trusts. The Corporation consolidates a municipal bond or resecuritization trust if it has control over the ongoing activities of the trust such as the remarketing of the trust’s liabilities or, if there are no ongoing activities, sole discretion over the design of the trust, including the identification of securities to be transferred in and the structure of securities to be issued, and also retains securities or has liquidity or other commitments that could potentially be significant to the trust. The Corporation does not consolidate a municipal bond or resecuritization trust if one or a limited number of third-party investors share responsibility for the design of the trust or have control over the significant activities of the trust through liquidation or other substantive rights.
Other VIEs used by the Corporation include collateralized debt obligations (CDOs), investment vehicles created on behalf of customers and other investment vehicles. The Corporation does not routinely serve as collateral manager for CDOs and, therefore, does not typically have the power to direct the
107 Bank of America


activities that most significantly impact the economic performance of a CDO. However, following an event of default, if the Corporation is a majority holder of senior securities issued by a CDO and acquires the power to manage its assets, the Corporation consolidates the CDO.
The Corporation consolidates a customer or other investment vehicle if it has control over the initial design of the vehicle or manages the assets in the vehicle and also absorbs potentially significant gains or losses through an investment in the vehicle, derivative contracts or other arrangements. The Corporation does not consolidate an investment vehicle if a single investor controlled the initial design of the vehicle or manages the assets in the vehicles or if the Corporation does not have a variable interest that could potentially be significant to the vehicle.
Retained interests in securitized assets are initially recorded at fair value. In addition, the Corporation may invest in debt securities issued by unconsolidated VIEs. Fair values of these debt securities, which are classified as trading account assets, debt securities carried at fair value or HTM securities, are based primarily on quoted market prices in active or inactive markets. Generally, quoted market prices for retained residual interests are not available; therefore, the Corporation estimates fair values based on the present value of the associated expected future cash flows.
Fair Value
The Corporation measures the fair values of its assets and liabilities, where applicable, in accordance with accounting guidance that requires an entity to base fair value on exit price. Under this guidance, an entity is required to maximize the use of observable inputs and minimize the use of unobservable inputs in measuring fair value. A hierarchy is established which categorizesUnder 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 1Unadjusted 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 2Observable 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 3Unobservable inputs that are supported by little or no market activity and that are significant to the overall fair value of the assets or liabilities. Level 3 assets and liabilities include financial instruments for which the determination of fair value requires significant management judgment or estimation. The fair value for such assets and liabilities is generally determined using pricing models, discounted cash flow methodologies or similar techniques that incorporate the assumptions a market participant would use in pricing the asset or liability. This category generally includes retained residual interests in securitizations, consumer MSRs, certain ABS, highly structured, complex or long-dated derivative contracts, certain loans and LHFS, IRLCs and certain CDOs where independent pricing information cannot be obtained for a significant portion of the underlying assets.
Level 1Unadjusted 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 2Observable 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 3Unobservable inputs that are supported by little or no market activity and that are significant to the overall
fair value of the assets or liabilities. Level 3 assets and liabilities include financial instruments for which the determination of fair value requires significant management judgment or estimation. The fair value for such assets and liabilities is generally determined using pricing models, discounted cash flow methodologies or similar techniques that incorporate the assumptions a market participant would use in pricing the asset or liability. This category generally includes retained residual interests in securitizations, consumer MSRs, certain ABS, highly structured, complex or long-dated derivative contracts, certain loans and LHFS, IRLCs and certain CDOs where independent pricing information cannot be obtained for a significant portion of the underlying assets.
Income Taxes
There are two components of income tax expense: current and deferred. Current income tax expense reflects taxes to be paid or refunded for the current period. Deferred income tax expense results from changes in deferred tax assets and liabilities between periods. These gross deferred tax assets and liabilities represent decreases or increases in taxes expected to be paid in the future because of future reversals of temporary differences in the bases of assets and liabilities as measured by tax laws and their bases as reported in the financial statements. Deferred tax assets are also recognized for tax attributes such as net operating loss carryforwards and tax credit carryforwards. Valuation allowances are recorded to reduce deferred tax assets to the amounts management concludes are more-likely-than-notmore likely than not to be realized.
Income tax benefits are recognized and measured based upon a two-step model: first, a tax position must be more-likely-than-notmore 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-notmore likely than not to be sustained upon settlement. The difference between the benefit

111Bank of America 2017



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
Revenue is recorded when earned, which is generally over the period services are provided and no contingencies exist. The following summarizes the Corporation’s revenue recognition accounting policies as they relate tofor certain noninterest income line items in the Consolidated Statement of Income.activities.
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. Interchange fees are recognized upon settlement of the credit and debit card payment transactions and are generally determined on a percentage basis for credit cards and fixed rates for debit cards based on the corresponding payment network’s rates. Substantially all card fees are recognized at the transaction date, except for certain time-based fees such as interchange, cash advance, annual late, over-limitfees, which are recognized over 12 months. Fees charged to cardholders and other miscellaneous fees. Uncollected feesmerchants that are included in customer card receivables balances with an amount recordedestimated to be uncollectible are reserved in the allowance for loan and lease losseslosses. 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 uncollectiblebased on past redemption behavior, card receivables. Uncollected feesproduct type, account
Bank of America 108


transaction activity and other historical card performance. The liability is reduced as the points are written off when aredeemed. The Corporation also makes payments to credit card receivable reaches 180 days past due.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, overdraftsfunds/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 bankingservices, such as payroll, sweep account and other cash management services. UncollectedLending-related fees are included in outstandinggenerally represent transactional fees earned from certain loan balances with an amount recorded for estimated uncollectible service fees receivable. Uncollected fees are written off when a fee receivable reaches 60 days past due.commitments, financial guarantees and SBLCs.
Investment and Brokerage Services
Investment and brokerage services revenue consists primarilyconsist of asset management fees and brokerage income.fees. Asset management fees consist primarilyare 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 and trust services and are generally based on the dollar amounta fixed price per unit or as a percentage of the assets being managed.total transaction amount. Brokerage income generally includesfees 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 onwhen the sale ofCorporation fills customer orders to buy or sell various financial products.products or when it acknowledges, affirms, settles and clears transactions and/or submits trade information to the appropriate clearing broker. Certain customers pay brokerage, clearing and/or exchange fees imposed by relevant regulatory bodies or exchanges in order to execute or clear trades. These fees are recorded net and are not reflected in the transaction price, as the Corporation is an agent for those services.
Investment Banking Income
Investment banking income includes underwriting income and financial advisory services income. Underwriting consists primarily of advisoryfees 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 which are recognized. The Corporation incurs certain out-of-pocket expenses, such as legal costs, in performing these services. These expenses are
recovered through the revenue the Corporation earns from the customer and are included in operating expenses. Syndication fees represent fees earned as the agent or lead lender responsible for structuring, arranging and administering a loan syndication.
Financial advisory services consist of fees earned for assisting clients with transactions related to mergers and acquisitions and financial restructurings. Revenue varies depending on the size of the transaction and scope of services performed and is generally contingent on successful completion of the transaction. Revenue is typically recognized netonce 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 direct expenses. Non-reimbursed expenses are recordedopen performance obligations at December 31, 2020, as noninterest expense.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 (see below for more information).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.
Credit Card and Deposit Arrangements
Endorsing Organization AgreementsPaycheck Protection Program
The Corporation contractsis 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 other organizations to obtain their endorsement ofcash-flow assistance through loans fully guaranteed by the Corporation’s loan and deposit products. This endorsement may provide to the Corporation exclusive rights to market to the organization’s members or to customers on behalf of the Corporation. These organizations endorse the Corporation’s loan and deposit products and provide the Corporation with their mailing lists and marketing activities. These agreements generally have terms that range five or more years. The Corporation typically pays royalties in exchange for the endorsement. Compensation costs related to the credit card agreements are recorded as contra-revenue in card income.
Cardholder Reward Agreements
The Corporation offers reward programs that allow its cardholders to earn points that can be redeemed for a broad range of rewards including cash, travel and gift cards. The Corporation establishes a rewards liability based upon the points earned that are expected to be redeemed and the average cost per point redeemed. The points to be redeemed are estimated based on past redemption behavior, card product type, account transaction activity and other historical card performance. The liability is reduced as the points are redeemed. The estimated cost of the rewards programs is recorded as contra-revenue in card income.Small



109 Bank of America


Business Administration (SBA). If the borrower meets certain criteria and uses the proceeds 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)202020192018
Net interest income
Interest income
Loans and leases$34,029 $43,086 $40,811 
Debt securities9,790 11,806 11,724 
Federal funds sold and securities borrowed or purchased under agreements to resell903 4,843 3,176 
Trading account assets4,128 5,196 4,811 
Other interest income2,735 6,305 6,247 
Total interest income51,585 71,236 66,769 
Interest expense
Deposits1,943 7,188 4,495 
Short-term borrowings987 7,208 5,839 
Trading account liabilities974 1,249 1,358 
Long-term debt4,321 6,700 6,915 
Total interest expense8,225 22,345 18,607 
Net interest income$43,360 $48,891 $48,162 
Noninterest income
Fees and commissions
Card income
Interchange fees (1)
$3,954 $3,834 $3,866 
Other card income1,702 1,963 1,958 
Total card income5,656 5,797 5,824 
Service charges
Deposit-related fees5,991 6,588 6,667 
Lending-related fees1,150 1,086 1,100 
Total service charges7,141 7,674 7,767 
Investment and brokerage services
Asset management fees10,708 10,241 10,189 
Brokerage fees3,866 3,661 3,971 
Total investment and brokerage services14,574 13,902 14,160 
Investment banking fees
Underwriting income4,698 2,998 2,722 
Syndication fees861 1,184 1,347 
Financial advisory services1,621 1,460 1,258 
Total investment banking fees7,180 5,642 5,327 
Total fees and commissions34,551 33,015 33,078 
Market making and similar activities8,355 9,034 9,008 
Other income (loss)(738)304 772 
Total noninterest income$42,168 $42,353 $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.
Bank of America 2017112110



NOTE Derivatives
Derivative Balances
Derivatives are entered into on behalf of customers, for trading or to support risk management activities. Derivatives used in risk management activities include derivatives that may or may not be designated in qualifying hedge accounting relationships. Derivatives that are not designated in qualifying hedge accounting relationships are referred to as other risk management derivatives. For more information on the
Corporation’s derivatives and hedging
activities, see Note 1 – Summary of Significant Accounting Principles. Principles. The following tables present derivative instruments included on the Consolidated Balance Sheet in derivative assets and liabilities at December 31, 20172020 and 2016.2019. 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 the cash collateral received or paid.
December 31, 2020
Gross Derivative AssetsGross Derivative Liabilities
(Dollars in billions)
Contract/
Notional (1)
Trading and Other Risk Management DerivativesQualifying
Accounting
Hedges
TotalTrading and Other Risk Management DerivativesQualifying
Accounting
Hedges
Total
Interest rate contracts       
Swaps$13,242.8 $199.9 $10.9 $210.8 $209.3 $1.3 $210.6 
Futures and forwards3,222.2 3.5 0.1 3.6 3.6 0 3.6 
Written options1,530.5 0 0 0 40.5 0 40.5 
Purchased options1,545.8 45.3 0 45.3 0 0 0 
Foreign exchange contracts 
Swaps1,475.8 37.1 0.3 37.4 39.7 0.6 40.3 
Spot, futures and forwards3,710.7 53.4 0 53.4 54.5 0.5 55.0 
Written options289.6 0 0 0 4.8 0 4.8 
Purchased options279.3 5.0 0 5.0 0 0 0 
Equity contracts 
Swaps320.2 13.3 0 13.3 14.5 0 14.5 
Futures and forwards106.2 0.3 0 0.3 1.4 0 1.4 
Written options599.1 0 0 0 48.8 0 48.8 
Purchased options541.2 52.6 0 52.6 0 0 0 
Commodity contracts  
Swaps36.4 1.9 0 1.9 4.4 0 4.4 
Futures and forwards63.6 2.0 0 2.0 1.0 0 1.0 
Written options24.6 0 0 0 1.4 0 1.4 
Purchased options24.7 1.5 0 1.5 0 0 0 
Credit derivatives (2)
   
Purchased credit derivatives:   
Credit default swaps322.7 2.3 0 2.3 4.4 0 4.4 
Total return swaps/options63.6 0.2 0 0.2 1.0 0 1.0 
Written credit derivatives:  
Credit default swaps301.5 4.4 0 4.4 1.9 0 1.9 
Total return swaps/options68.6 0.6 0 0.6 0.4 0 0.4 
Gross derivative assets/liabilities$423.3 $11.3 $434.6 $431.6 $2.4 $434.0 
Less: Legally enforceable master netting agreements  (344.9)  (344.9)
Less: Cash collateral received/paid   (42.5)  (43.6)
Total derivative assets/liabilities   $47.2   $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.
              
   December 31, 2017
   Gross Derivative Assets Gross Derivative Liabilities
(Dollars in billions)
Contract/
Notional (1)
 Trading and Other Risk Management Derivatives 
Qualifying
Accounting
Hedges
 Total Trading and Other Risk Management Derivatives 
Qualifying
Accounting
Hedges
 Total
Interest rate contracts 
  
  
  
  
  
  
Swaps (2)
$15,416.4
 $175.1
 $2.9
 $178.0
 $172.5
 $1.7
 $174.2
Futures and forwards (2)
4,332.4
 0.5
 
 0.5
 0.5
 
 0.5
Written options1,170.5
 
 
 
 35.5
 
 35.5
Purchased options1,184.5
 37.6
 
 37.6
 
 
 
Foreign exchange contracts     
  
  
  
  
Swaps2,011.1
 35.6
 2.2
 37.8
 36.1
 2.7
 38.8
Spot, futures and forwards3,543.3
 39.1
 0.7
 39.8
 39.1
 0.8
 39.9
Written options291.8
 
 
 
 5.1
 
 5.1
Purchased options271.9
 4.6
 
 4.6
 
 
 
Equity contracts   
  
  
  
  
  
Swaps265.6
 4.8
 
 4.8
 4.4
 
 4.4
Futures and forwards106.9
 1.5
 
 1.5
 0.9
 
 0.9
Written options480.8
 
 
 
 23.9
 
 23.9
Purchased options428.2
 24.7
 
 24.7
 
 
 
Commodity contracts 
  
  
  
  
  
  
Swaps46.1
 1.8
 
 1.8
 4.6
 
 4.6
Futures and forwards47.1
 3.5
 
 3.5
 0.6
 
 0.6
Written options21.7
 
 
 
 1.4
 
 1.4
Purchased options22.9
 1.4
 
 1.4
 
 
 
Credit derivatives (3)
 
  
  
  
  
  
  
Purchased credit derivatives: 
  
  
    
  
  
Credit default swaps (2)
470.9
 4.1
 
 4.1
 11.1
 
 11.1
Total return swaps/options54.1
 0.1
 
 0.1
 1.3
 
 1.3
Written credit derivatives:

 

  
 

 

  
 

Credit default swaps (2)
448.2
 10.6
 
 10.6
 3.6
 
 3.6
Total return swaps/options55.2
 0.8
 
 0.8
 0.2
 
 0.2
Gross derivative assets/liabilities  $345.8
 $5.8
 $351.6
 $340.8
 $5.2
 $346.0
Less: Legally enforceable master netting agreements (2)
 
  
  
 (279.2)  
  
 (279.2)
Less: Cash collateral received/paid (2)
 
  
  
 (34.6)  
  
 (32.5)
Total derivative assets/liabilities 
  
  
 $37.8
  
  
 $34.3
(1)
Represents the total contract/notional amount of derivative assets and liabilities outstanding.
(2)
Derivative assets and liabilities reflect the effects of contractual amendments by two central clearing counterparties to legally re-characterize daily cash variation margin from collateral, which secures an outstanding exposure, to settlement, which discharges an outstanding exposure. One of these central clearing counterparties amended its governing documents, which became effective in January 2017. In addition, the Corporation elected to transfer its existing positions to the settlement platform for the other central clearing counterparty in September 2017.
(3)
The net derivative asset and notional amount of written credit derivatives for which the Corporation held purchased credit derivatives with identical underlying referenced names were $6.4 billion and $435.1 billion at December 31, 2017.


113111Bank of America 2017



              
   December 31, 2016
   Gross Derivative Assets Gross Derivative Liabilities
(Dollars in billions)
Contract/
Notional (1)
 Trading and Other Risk Management Derivatives 
Qualifying
Accounting
Hedges
 Total Trading and Other Risk Management Derivatives 
Qualifying
Accounting
Hedges
 Total
Interest rate contracts 
  
  
  
  
  
  
Swaps$16,977.7
 $385.0
 $5.9
 $390.9
 $386.9
 $2.0
 $388.9
Futures and forwards5,609.5
 2.2
 
 2.2
 2.1
 
 2.1
Written options1,146.2
 
 
 
 52.2
 
 52.2
Purchased options1,178.7
 53.3
 
 53.3
 
 
 
Foreign exchange contracts   
  
  
  
  
  
Swaps1,828.6
 54.6
 4.2
 58.8
 58.8
 6.2
 65.0
Spot, futures and forwards3,410.7
 58.8
 1.7
 60.5
 56.6
 0.8
 57.4
Written options356.6
 
 
 
 9.4
 
 9.4
Purchased options342.4
 8.9
 
 8.9
 
 
 
Equity contracts 
  
  
  
  
  
  
Swaps189.7
 3.4
 
 3.4
 4.0
 
 4.0
Futures and forwards68.7
 0.9
 
 0.9
 0.9
 
 0.9
Written options431.5
 
 
 
 21.4
 
 21.4
Purchased options385.5
 23.9
 
 23.9
 
 
 
Commodity contracts 
  
  
  
  
  
  
Swaps48.2
 2.5
 
 2.5
 5.1
 
 5.1
Futures and forwards49.1
 3.6
 
 3.6
 0.5
 
 0.5
Written options29.3
 
 
 
 1.9
 
 1.9
Purchased options28.9
 2.0
 
 2.0
 
 
 
Credit derivatives (2)
 
  
  
  
  
  
  
Purchased credit derivatives: 
  
  
  
  
  
  
Credit default swaps604.0
 8.1
 
 8.1
 10.3
 
 10.3
Total return swaps/options21.2
 0.4
 
 0.4
 1.5
 
 1.5
Written credit derivatives: 
  
  
  
    
  
Credit default swaps614.4
 10.7
 
 10.7
 7.5
 
 7.5
Total return swaps/options25.4
 1.0
 
 1.0
 0.2
 
 0.2
Gross derivative assets/liabilities 
 $619.3
 $11.8
 $631.1
 $619.3
 $9.0
 $628.3
Less: Legally enforceable master netting agreements 
  
  
 (545.3)  
  
 (545.3)
Less: Cash collateral received/paid 
  
  
 (43.3)  
  
 (43.5)
Total derivative assets/liabilities 
  
  
 $42.5
  
  
 $39.5
(1)


December 31, 2019
Gross Derivative AssetsGross Derivative Liabilities
(Dollars in billions)
Contract/
Notional (1)
Trading and Other Risk Management DerivativesQualifying
Accounting
Hedges
TotalTrading and Other Risk Management DerivativesQualifying
Accounting
Hedges
Total
Interest rate contracts       
Swaps$15,074.4 $162.0 $9.7 $171.7 $168.5 $0.4 $168.9 
Futures and forwards3,279.8 1.0 1.0 1.0 1.0 
Written options1,767.7 32.5 32.5 
Purchased options1,673.6 37.4 37.4 
Foreign exchange contracts      
Swaps1,657.7 30.3 0.7 31.0 31.7 0.9 32.6 
Spot, futures and forwards3,792.7 35.9 0.1 36.0 38.7 0.3 39.0 
Written options274.3 3.8 3.8 
Purchased options261.6 4.0 4.0 
Equity contracts       
Swaps315.0 6.5 6.5 8.1 8.1 
Futures and forwards125.1 0.3 0.3 1.1 1.1 
Written options731.1 34.6 34.6 
Purchased options668.6 42.4 42.4 
Commodity contracts       
Swaps42.0 2.1 2.1 4.4 4.4 
Futures and forwards61.3 1.7 1.7 0.4 0.4 
Written options33.2 1.4 1.4 
Purchased options37.9 1.4 1.4 
Credit derivatives (2)
       
Purchased credit derivatives:       
Credit default swaps321.6 2.7 2.7 5.6 5.6 
Total return swaps/options86.6 0.4 0.4 1.3 1.3 
Written credit derivatives:      
Credit default swaps300.2 5.4 5.4 2.0 2.0 
Total return swaps/options86.2 0.8 0.8 0.4 0.4 
Gross derivative assets/liabilities $334.3 $10.5 $344.8 $335.5 $1.6 $337.1 
Less: Legally enforceable master netting agreements   (270.4)  (270.4)
Less: Cash collateral received/paid   (33.9)  (28.5)
Total derivative assets/liabilities   $40.5   $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.
Represents the total contract/notional amount of derivative assets and liabilities outstanding.
(2)
The net derivative asset and notional amount of written credit derivatives for which the Corporation held purchased credit derivatives with identical underlying referenced names were $2.2 billion and $548.9 billion at December 31, 2016.
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, 20172020 and 20162019 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 includesinclude 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, and Short-term Borrowings and Restricted Cash.


Bank of America 2017114112



       
Offsetting of Derivatives (1)
       
Offsetting of Derivatives (1)
       
Derivative
Assets
 Derivative Liabilities 
Derivative
Assets
 Derivative LiabilitiesDerivative
Assets
Derivative LiabilitiesDerivative
Assets
Derivative Liabilities
(Dollars in billions)December 31, 2017 December 31, 2016(Dollars in billions)December 31, 2020December 31, 2019
Interest rate contracts 
  
  
  
Interest rate contracts    
Over-the-counter$211.7
 $206.0
 $267.3
 $258.2
Over-the-counter$247.7 $243.5 $203.1 $196.6 
Over-the-counter cleared (2)
1.9
 1.8
 177.2
 182.8
Exchange-tradedExchange-traded0 0 0.1 0.1 
Over-the-counter clearedOver-the-counter cleared10.2 9.1 6.0 5.3 
Foreign exchange contracts       Foreign exchange contracts
Over-the-counter78.7
 80.8
 124.3
 126.7
Over-the-counter92.2 96.5 69.2 73.1 
Over-the-counter cleared0.9
 0.7
 0.3
 0.3
Over-the-counter cleared1.4 1.3 0.5 0.5 
Equity contracts       Equity contracts
Over-the-counter18.3
 16.2
 15.6
 13.7
Over-the-counter31.3 28.3 21.3 17.8 
Exchange-traded9.1
 8.5
 11.4
 10.8
Exchange-traded32.3 31.0 26.4 22.8 
Commodity contracts       Commodity contracts
Over-the-counter2.9
 4.4
 3.7
 4.9
Over-the-counter3.5 5.0 2.8 4.2 
Exchange-traded0.7
 0.8
 1.1
 1.0
Exchange-traded0.7 0.7 0.8 0.8 
Over-the-counter clearedOver-the-counter cleared0 0 0.1 
Credit derivatives       Credit derivatives
Over-the-counter9.1
 9.6
 15.3
 14.7
Over-the-counter5.2 5.6 6.4 6.6 
Over-the-counter cleared (2)
6.1
 6.0
 4.3
 4.3
Over-the-counter clearedOver-the-counter cleared2.2 1.9 2.5 2.2 
Total gross derivative assets/liabilities, before netting       Total gross derivative assets/liabilities, before netting
Over-the-counter320.7
 317.0
 426.2
 418.2
Over-the-counter379.9 378.9 302.8 298.3 
Exchange-traded9.8
 9.3
 12.5
 11.8
Exchange-traded33.0 31.7 27.3 23.7 
Over-the-counter cleared (2)
8.9
 8.5
 181.8
 187.4
Over-the-counter clearedOver-the-counter cleared13.8 12.3 9.0 8.1 
Less: Legally enforceable master netting agreements and cash collateral received/paid       Less: Legally enforceable master netting agreements and cash collateral received/paid
Over-the-counter(296.9) (294.6) (398.2) (392.6)Over-the-counter(345.7)(347.2)(274.7)(269.3)
Exchange-traded(8.6) (8.6) (8.9) (8.9)Exchange-traded(29.5)(29.5)(21.5)(21.5)
Over-the-counter cleared (2)
(8.3) (8.5) (181.5) (187.3)
Over-the-counter clearedOver-the-counter cleared(12.2)(11.8)(8.1)(8.1)
Derivative assets/liabilities, after netting25.6
 23.1
 31.9
 28.6
Derivative assets/liabilities, after netting39.3 34.4 34.8 31.2 
Other gross derivative assets/liabilities (3)
12.2
 11.2
 10.6
 10.9
Other gross derivative assets/liabilities (2)
Other gross derivative assets/liabilities (2)
7.9 11.1 5.7 7.0 
Total derivative assets/liabilities37.8
 34.3
 42.5
 39.5
Total derivative assets/liabilities47.2 45.5 40.5 38.2 
Less: Financial instruments collateral (4)
(11.2) (10.4) (13.5) (10.5)
Less: Financial instruments collateral (3)
Less: Financial instruments collateral (3)
(16.1)(16.6)(14.6)(16.1)
Total net derivative assets/liabilities$26.6
 $23.9
 $29.0
 $29.0
Total net derivative assets/liabilities$31.1 $28.9 $25.9 $22.1 
(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.
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, and exchange-traded derivatives include listed options transacted on an exchange.
(2)
Derivative assets and liabilities reflect the effects of contractual amendments by two central clearing counterparties to legally re-characterize daily cash variation margin from collateral, which secures an outstanding exposure, to settlement, which discharges an outstanding exposure. One of these central clearing counterparties amended its governing documents, which became effective in January 2017. In addition, the Corporation elected to transfer its existing positions to the settlement platform for the other central clearing counterparty in September 2017.
(3)
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.
(4)
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’sCorporation's ALM and risk management activities.
TheCorporation 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. For more information on MSRs, see Note 20 – Fair Value Measurements.
The Corporation uses foreign exchange contracts to manage the foreign exchange risk associated with certain foreign currency-denominated assets and liabilities, as well as the Corporation’s investments in non-U.S. subsidiaries. Foreign exchange contracts, which include spot and forward contracts, represent agreements to exchange the currency of one country for the currency of another country at an agreed-upon price on an agreed-upon settlement date. Exposure to loss on these contracts will increase or decrease over their respective lives as currency exchange and interest rates fluctuate.


115Bank of America 2017



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 commodity and foreign exchange derivative contracts to protect against changes in the fair value of its assets and liabilities due to fluctuations in interest rates commodity prices and exchange rates (fair value hedges). The Corporation also uses these types of contracts and equity derivatives to protect against changes in the cash flows of its assets and liabilities,
113 Bank of America


and other forecasted transactions (cash flow hedges). The Corporation hedges its net investment in consolidated non-U.S. operations determined to
have functional currencies other than
the U.S. dollar using forward exchange contracts and cross-currency basis swaps, and by issuing foreign currency-denominated debt (net investment hedges).
Fair Value Hedges
The following table summarizes information related to fair value hedges for 2017, 20162020, 2019 and 2015, including hedges2018.
Gains and Losses on Derivatives Designated as Fair Value Hedges
DerivativeHedged Item
(Dollars in millions)202020192018202020192018
Interest rate risk on long-term debt (1)
$7,091 $6,113 $(1,538)$(7,220)$(6,110)$1,429 
Interest rate and foreign currency risk on long-term debt (2)
783 119 (1,187)(783)(101)1,079 
Interest rate risk on available-for-sale securities (3)
(44)(102)(52)49 98 50 
Total$7,830 $6,130 $(2,777)$(7,954)$(6,113)$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 rate riskexpense, $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)
Carrying Value
Cumulative
Fair Value Adjustments (1)
Carrying Value
Cumulative
Fair Value Adjustments (1)
(Dollars in millions)December 31, 2020December 31, 2019
Long-term debt (2)
$(150,556)$(8,910)$(162,389)$(8,685)
Available-for-sale debt securities (2, 3, 4)
116,252 114 1,654 64 
Trading account assets (5)
427 15 
(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 that were acquired as partand AFS debt securities from discontinued hedging relationships resulted in an (increase) decrease in the related liability of a business combination$(3.7) billion and redesignated at that time. At redesignation,$1.3 billion and an increase (decrease) in the fair valuerelated asset of $(69) million and $8 million, which are being amortized over the remaining contractual life of the derivativesde-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 positive. As the derivatives mature, the fair value will approach zero. As a result, ineffectiveness will occur and the fair value changes$34.6 billion, of which $7.0 billion was designated in the derivatives and the long-term debt being hedged may be directionally the same in certain scenarios. Based on a regression analysis, the derivatives continuelast-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 be highly effective at offsetting changes in the fair value of the long-term debt attributable to interest rate risk.precious metals inventory.
               
Derivatives Designated as Fair Value Hedges              
                  
Gains (Losses)Derivative Hedged Item Hedge Ineffectiveness
(Dollars in millions)2017 2016 2015 2017 2016 2015 2017 2016 2015
Interest rate risk on long-term debt (1)
$(1,537) $(1,488) $(718) $1,045
 $646
 $(77) $(492) $(842) $(795)
Interest rate and foreign currency risk on long-term debt (1)
1,811
 (941) (1,898) (1,767) 944
 1,812
 44
 3
 (86)
Interest rate risk on available-for-sale securities (2)
(67) 227
 105
 35
 (286) (127) (32) (59) (22)
Total$207
 $(2,202) $(2,511) $(687) $1,304
 $1,608
 $(480) $(898) $(903)
(1)
Amounts are recorded in interest expense on long-term debt and in other income.
(2)
Amounts are recorded in interest income on debt securities.
Cash Flow and Net Investment Hedges
The following table below summarizes certain information related to cash flow hedges and net investment hedges for 2017, 2016,2020, 2019 and 2015.2018. Of the $831$426 million after-tax net lossgain ($1.3 billion pre-tax)566 million pretax) on derivatives in accumulated OCI at December 31, 2017, $1302020, gains of $190 million after-tax ($208254 million pre-tax) ispretax) related to both open and terminated hedges are expected to be
reclassified into earnings in the next 12 months. These net lossesgains reclassified into earnings are expected to primarily reduceincrease net interest income
related to the respective hedged items. Amounts related to price risk on restricted stock awards reclassified from accumulated OCI are recorded in personnel expense. For terminated cash flow hedges, the time period over which the majority of the forecasted transactions are hedged is approximately seven3 years, with a maximum length of time for certain forecasted transactions of 1916 years.
Gains and Losses on Derivatives Designated as Cash Flow and Net Investment Hedges
Gains (Losses) Recognized in
Accumulated OCI on Derivatives
Gains (Losses) in Income
Reclassified from Accumulated OCI
(Dollars in millions, amounts pretax)202020192018202020192018
Cash flow hedges
Interest rate risk on variable-rate assets (1)
$763 $671 $(159)$(7)$(104)$(165)
Price risk on forecasted MBS purchases (1)
241 
Price risk on certain compensation plans (2)
85 34 12 (2)27 
Total$1,089 $705 $(155)$14 $(106)$(138)
Net investment hedges
Foreign exchange risk (3)
$(834)$22 $989 $4 $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.
            
Derivatives Designated as Cash Flow and Net Investment Hedges   
            
 
Gains (Losses) Recognized in
Accumulated OCI on Derivatives
 Gains (Losses) in Income
Reclassified from Accumulated OCI
(Dollars in millions, amounts pre-tax)2017 2016 2015 2017 2016 2015
Cash flow hedges           
Interest rate risk on variable-rate portfolios$(109) $(340) $95
 $(327) $(553) $(974)
Price risk on certain restricted stock awards (1)
59
 41
 (40) 148
 (32) 91
Total (2)
$(50) $(299) $55
 $(179) $(585) $(883)
Net investment hedges 
  
  
  
  
  
Foreign exchange risk (3)
$(1,588) $1,636
 $3,010
 $1,782
 $3
 $153
(1)
Gains (losses) recognized in accumulated OCI are primarily related to the change in the Corporation’s stock price for the period.
(2)
In 2017, 2016 and 2015, amounts representing hedge ineffectiveness were not significant.
(3)
In 2017, substantially all of the gains in income reclassified from accumulated OCI were comprised of the gain recognized on derivatives used to hedge the currency risk of the Corporation’s net investment in its non-U.S. consumer credit card business, which was sold in 2017. For more information, see Note 14 – Accumulated Other Comprehensive Income (Loss). In 2017, 2016 and 2015, amounts excluded from effectiveness testing in total were $120 million, $325 million and $298 million.


Bank of America 2017116114



Other Risk Management Derivatives
Other risk management derivatives are used by the Corporation to reduce certain risk exposures. These derivatives are not qualifying accounting hedges because either they did not qualify for or were not designated as accounting hedges.exposures by economically hedging various assets and liabilities. The following table below presents gains (losses) on these derivatives for 2017, 20162020, 2019 and 2015.2018. These gains (losses) are largely offset by the income or expense that is recorded on the hedged item.
Gains and Losses on Other Risk Management Derivatives
(Dollars in millions)202020192018
Interest rate risk on mortgage activities (1, 2)
$446 $315 $(107)
Credit risk on loans (2)
(68)(58)
Interest rate and foreign currency risk on ALM activities (3)
(2,971)1,112 3,278 
Price risk on certain compensation plans (4)
700 943 (495)
      
Other Risk Management Derivatives
      
Gains (Losses)     
(Dollars in millions)2017 2016 2015
Interest rate risk on mortgage banking income (1)
$8
 $461
 $254
Credit risk on loans (2)
(6) (107) (22)
Interest rate and foreign currency risk on ALM activities (3)
(36) (754) (222)
Price risk on certain restricted stock awards (4)
301
 9
 (267)
(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.
(1)
(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.
Net gains (losses) on these derivatives are recorded in mortgage banking income as they are used to mitigate the interest rate risk related to MSRs, IRLCs and mortgage LHFS, all of which are measured at fair value with changes in fair value recorded in mortgage banking income. The fair value of IRLCs is derived from the fair value of related mortgage loans which is based on observable market data and includes the expected net future cash flows related to servicing of the loans. The net gains on IRLCs related to the origination of mortgage loans that are held-for-sale, which are not included in the table but are considered derivative instruments, were $220 million, $533 million and $714 million for 2017, 2016 and 2015, respectively.
(2)
Primarily related to derivatives that are economic hedges of credit risk on loans. Net gains (losses) on these derivatives are recorded in other income.
(3)
Primarily related to hedges of debt securities carried at fair value and hedges of foreign currency-denominated debt. Gains (losses) on these derivatives and the related hedged items are recorded in other income.
(4)
Gains (losses) on these derivatives are recorded in personnel 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. ThroughAt both December 31, 20172020 and 2016,2019, the Corporation had transferred $6.0 billion and $6.6$5.2 billion of non-U.S. government-guaranteed MBSmortgage-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 $6.0$5.2 billion and $6.6 billion at theas of both transfer dates. At December 31, 20172020 and 2016,2019, the fair value of the transferred securities was $6.1$5.5 billion and $6.3$5.3 billion. Derivative assets of $46 million and $43 million and liabilities of $3 million and $10 million were recorded at December 31, 2017 and 2016, and are included in credit derivatives in the derivative instruments table on page 113.
Sales and Trading Revenue
The Corporation enters into trading derivatives to facilitate client transactions and to manage risk exposures arising from trading account assets and liabilities. It is the Corporation’s policy to include these derivative instruments in its trading activities, which include derivatives and non-derivative cash instruments. The resulting risk from these derivatives is managed on a portfolio basis as part of the Corporation’s Global Markets business segment. The related sales and trading revenue generated within Global Markets is recorded in various income statement line items, including trading account profitsmarket making and similar activities and net interest income as well as other revenue categories.
Sales and trading revenue includes changes in the fair value and realized gains and losses on the sales of trading and other assets, net interest income, and fees primarily from commissions on equity securities. Revenue is generated by the difference in the client price for an instrument and the price at which the trading desk can execute the trade in the dealer market. For equity securities, commissions related to purchases and sales are recorded in the “Other” column in the Sales and Trading Revenue table. Changes in the fair value of these securities are included in trading account profits.market making and similar activities. For debt securities, revenue, with the exception of interest associated with the debt securities, is typically included in trading account profits.
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 trading account profitsmarket making and similar activities as part of the initial mark to fair value. For derivatives, the majority of revenue is included in trading account profits.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.

117Bank of America 2017



The following table, below, which includes both derivatives and non-derivative cash instruments, identifies the amounts in the respective income statement line items attributable to the Corporation’s sales and trading revenue in Global Markets, categorized by primary risk, for 2017, 20162020, 2019 and 2015. The difference between total trading account profits in the following
table and in the Consolidated Statement of Income represents trading activities in business segments other than Global Markets.2018. This table includes DVAdebit 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 following table below is not presented on an FTE basis.
Sales and Trading Revenue
Market making and similar activitiesNet Interest
Income
Other (1)
Total
(Dollars in millions)2020
Interest rate risk$2,211 $2,400 $231 $4,842 
Foreign exchange risk1,482 (20)3 1,465 
Equity risk3,656 (77)1,801 5,380 
Credit risk812 1,638 328 2,778 
Other risk308 4 44 356 
Total sales and trading revenue$8,469 $3,945 $2,407 $14,821 
2019
Interest rate risk$1,000 $1,817 $113 $2,930 
Foreign exchange risk1,288 62 57 1,407 
Equity risk3,563 (634)1,569 4,498 
Credit risk1,091 1,807 519 3,417 
Other risk120 70 53 243 
Total sales and trading revenue$7,062 $3,122 $2,311 $12,495 
2018
Interest rate risk$810 $1,651 $245 $2,706 
Foreign exchange risk1,504 31 22 1,557 
Equity risk3,870 (657)1,643 4,856 
Credit risk1,034 1,886 600 3,520 
Other risk40 197 49 286 
Total sales and trading revenue$7,258 $3,108 $2,559 $12,925 
        
Sales and Trading Revenue       
        
 Trading Account Profits Net Interest Income 
Other (1)
 Total
(Dollars in millions)2017
Interest rate risk$1,145
 $980
 $417
 $2,542
Foreign exchange risk1,417
 (1) (162) 1,254
Equity risk2,689
 (525) 1,904
 4,068
Credit risk1,251
 2,537
 577
 4,365
Other risk204
 33
 75
 312
Total sales and trading revenue$6,706
 $3,024
 $2,811
 $12,541
        
 2016
Interest rate risk$1,613
 $1,410
 $304
 $3,327
Foreign exchange risk1,360
 (10) (154) 1,196
Equity risk1,917
 20
 2,074
 4,011
Credit risk1,250
 2,569
 424
 4,243
Other risk407
 (20) 40
 427
Total sales and trading revenue$6,547
 $3,969
 $2,688
 $13,204
        
 2015
Interest rate risk$1,290
 $1,333
 $(259) $2,364
Foreign exchange risk1,322
 (10) (117) 1,195
Equity risk2,115
 56
 2,152
 4,323
Credit risk920
 2,333
 445
 3,698
Other risk459
 (81) 62
 440
Total sales and trading revenue$6,106
 $3,631
 $2,283
 $12,020
(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.
(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 $2.0 billion, $2.1 billion, and $2.2 billion for 2017, 2016, and 2015, respectively.
Credit Derivatives
The Corporation enters into credit derivatives primarily to facilitate client transactions and to manage credit risk exposures. Credit derivatives derive value based on an underlying third-party referenced obligation or a portfolio of referenced obligations and generally require the Corporation, as the seller of credit protection, to make payments to a buyer upon the occurrence of a pre-definedpredefined 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
115 Bank of America


moratorium. For credit derivatives based on a portfolio of referenced credits or credit indices, the Corporation may not be required to make payment until a specified amount of loss has occurred and/or may only be required to make payment up to a specified amount.
Credit derivative instruments where the Corporation is the seller of credit protection and their expiration at December 31, 2017 and 2016 are summarized in the following table.

Bank of America 2017118


          
Credit Derivative Instruments         
          
 
Less than
One Year
 
One to
Three Years
 
Three to
Five Years
 
Over Five
Years
 Total
 December 31, 2017
(Dollars in millions)Carrying Value
Credit default swaps: 
  
  
  
  
Investment grade$4
 $3
 $61
 $245
 $313
Non-investment grade203
 453
 484
 2,133
 3,273
Total207
 456
 545
 2,378
 3,586
Total return swaps/options: 
  
  
  
  
Investment grade30
 
 
 
 30
Non-investment grade150
 
 
 3
 153
Total180
 
 
 3
 183
Total credit derivatives$387
 $456
 $545
 $2,381
 $3,769
Credit-related notes: 
  
  
  
  
Investment grade$
 $
 $7
 $689
 $696
Non-investment grade12
 4
 34
 1,548
 1,598
Total credit-related notes$12
 $4
 $41
 $2,237
 $2,294
 Maximum Payout/Notional
Credit default swaps: 
  
  
  
  
Investment grade$61,388
 $115,480
 $107,081
 $21,579
 $305,528
Non-investment grade39,312
 49,843
 39,098
 14,420
 142,673
Total100,700
 165,323
 146,179
 35,999
 448,201
Total return swaps/options: 
  
  
  
  
Investment grade37,394
 2,581
 
 143
 40,118
Non-investment grade13,751
 514
 143
 697
 15,105
Total51,145
 3,095
 143
 840
 55,223
Total credit derivatives$151,845
 $168,418
 $146,322
 $36,839
 $503,424
          
 December 31, 2016
 Carrying Value
Credit default swaps:         
Investment grade$10
 $64
 $535
 $783
 $1,392
Non-investment grade771
 1,053
 908
 3,339
 6,071
Total781
 1,117
 1,443
 4,122
 7,463
Total return swaps/options: 
  
  
  
  
Investment grade16
 
 
 
 16
Non-investment grade127
 10
 2
 1
 140
Total143
 10
 2
 1
 156
Total credit derivatives$924
 $1,127
 $1,445
 $4,123
 $7,619
Credit-related notes: 
  
  
  
  
Investment grade$
 $12
 $542
 $1,423
 $1,977
Non-investment grade70
 22
 60
 1,318
 1,470
Total credit-related notes$70
 $34
 $602
 $2,741
 $3,447
 Maximum Payout/Notional
Credit default swaps:         
Investment grade$121,083
 $143,200
 $116,540
 $21,905
 $402,728
Non-investment grade84,755
 67,160
 41,001
 18,711
 211,627
Total205,838
 210,360
 157,541
 40,616
 614,355
Total return swaps/options: 
  
  
  
  
Investment grade12,792
 
 
 
 12,792
Non-investment grade6,638
 5,127
 589
 208
 12,562
Total19,430
 5,127
 589
 208
 25,354
Total credit derivatives$225,268
 $215,487
 $158,130
 $40,824
 $639,709
Credit derivatives are classified as investment and non-investment grade based on the credit quality of the underlying referenced obligation. The Corporation considers ratings of BBB-
or higher as investment grade. Non-investment grade includes non-rated credit derivative instruments. The Corporation discloses internal categorizations of investment grade and non-investment grade consistent with how risk is managed for these instruments.
Credit derivative instruments where the Corporation is the seller of credit protection and their expiration at December 31, 2020 and 2019 are summarized in the following table.
Credit Derivative Instruments
Less than
One Year
One to
Three Years
Three to
Five Years
Over Five
Years
Total
December 31, 2020
(Dollars in millions)Carrying Value
Credit default swaps:     
Investment grade$0 $1 $35 $94 $130 
Non-investment grade26 233 364 1,163 1,786 
Total26 234 399 1,257 1,916 
Total return swaps/options:     
Investment grade21 4 0 0 25 
Non-investment grade345 0 0 0 345 
Total366 4 0 0 370 
Total credit derivatives$392 $238 $399 $1,257 $2,286 
Credit-related notes:     
Investment grade$0 $0 $0 $572 $572 
Non-investment grade64 2 10 947 1,023 
Total credit-related notes$64 $2 $10 $1,519 $1,595 
 Maximum Payout/Notional
Credit default swaps:     
Investment grade$33,474 $75,731 $87,218 $16,822 $213,245 
Non-investment grade13,664 28,770 35,978 9,852 88,264 
Total47,138 104,501 123,196 26,674 301,509 
Total return swaps/options:     
Investment grade30,961 1,061 77 0 32,099 
Non-investment grade36,128 364 27 5 36,524 
Total67,089 1,425 104 5 68,623 
Total credit derivatives$114,227 $105,926 $123,300 $26,679 $370,132 
December 31, 2019
Carrying Value
Credit default swaps:
Investment grade$$$60 $164 $229 
Non-investment grade70 292 561 808 1,731 
Total70 297 621 972 1,960 
Total return swaps/options:     
Investment grade35 35 
Non-investment grade344 344 
Total379 379 
Total credit derivatives$449 $297 $621 $972 $2,339 
Credit-related notes:     
Investment grade$$$$639 $643 
Non-investment grade1,125 1,134 
Total credit-related notes$$$$1,764 $1,777 
 Maximum Payout/Notional
Credit default swaps:
Investment grade$55,827 $67,838 $71,320 $17,708 $212,693 
Non-investment grade19,049 26,521 29,618 12,337 87,525 
Total74,876 94,359 100,938 30,045 300,218 
Total return swaps/options:     
Investment grade56,488 62 76 56,626 
Non-investment grade28,707 657 104 60 29,528 
Total85,195 657 166 136 86,154 
Total credit derivatives$160,071 $95,016 $101,104 $30,181 $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.

119Bank of America 2017



The Corporation is not obligated to make any payments to the entities under the terms of the securities owned.
Bank of America 116


Credit-related Contingent Features and Collateral
TheCorporation 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 114,112, the Corporation enters into legally enforceable master netting agreements whichthat reduce risk by permitting closeout and netting of transactions with the same counterparty upon the occurrence of certain events.
A majorityCertain 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, 20172020 and 2016,2019, the Corporation held cash and securities collateral of $77.2$96.5 billion and $85.5$84.3 billion and posted cash and securities collateral of $59.2$88.6 billion and $71.1$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, 2017,2020, 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 approximately $3.2$2.6 billion,, including $2.1$1.2 billion for Bank of America, National Association (Bank of America, N.A. or BANA)(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, 20172020 and 2016,2019, 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, 20172020 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)One
incremental notch
Second
incremental notch
Bank of America Corporation$300 $735 
Bank of America, N.A. and subsidiaries (1)
61 570 
   
Additional Collateral Required to be Posted Upon Downgrade at December 31, 2017
   
(Dollars in millions)
One
incremental notch
Second
incremental notch
Bank of America Corporation$779
$487
Bank of America, N.A. and subsidiaries (1)
391
230
(1)Included in Bank of America Corporation collateral requirements in this table.
(1)
Included in Bank of America Corporation collateral requirements in this table.
The following table below 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, 20172020 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, 2017
Derivative Liabilities Subject to Unilateral Termination Upon Downgrade at December 31, 2020Derivative Liabilities Subject to Unilateral Termination Upon Downgrade at December 31, 2020
 
(Dollars in millions)
One
incremental notch
Second
incremental notch
(Dollars in millions)One
incremental notch
Second
incremental notch
Derivative liabilities$428
$1,163
Derivative liabilities$45 $1,035 
Collateral posted339
800
Collateral posted23 544 



Bank of America 2017120


Valuation Adjustments on Derivatives
TheCorporation records credit risk valuation adjustments on derivatives in order to properly reflect the credit quality of the counterparties and its own credit quality. The Corporation calculates valuation adjustments on derivatives based on a modeled expected exposure that incorporates current market risk factors. The exposure also takes into consideration credit mitigants such as enforceable master netting agreements and collateral. CDS spread data is used to estimate the default probabilities and severities that are applied to the exposures. Where no observable credit default data is available for counterparties, the Corporation uses proxies and other market data to estimate default probabilities and severity.
Valuation adjustments on derivatives are affected by changes in market spreads, non-credit related market factors such as interest rate and currency changes that affect the expected exposure, and other factors like changes in collateral arrangements and partial payments. Credit spreads and non-credit factors can move independently. For example, for an interest rate swap, changes in interest rates may increase the expected exposure, which would increase the counterparty credit valuation adjustment (CVA). Independently, counterparty credit spreads may tighten, which would result in an offsetting decrease to CVA.
The Corporation enters into risk management activities to offset market driven exposures. The Corporation often hedges the counterparty spread risk in CVA with CDS. The Corporation hedges other market risks in both CVA and DVA primarily with currency and interest rate swaps. In certain instances, the net-of-hedge amounts in the table below move in the same direction as the gross amount or may move in the opposite direction. This movement is a consequence of the complex interaction of the risks being hedged, resulting in limitations in the ability to perfectly hedge all of the market exposures at all times.
The table below presents CVA,credit valuation adjustment (CVA), DVA and FVA gains (losses) on derivatives (excluding the effect of any related hedge activities), which are recorded in trading account profits, on a grossmarket making and net of hedge basissimilar activities, for 2017, 20162020, 2019 and 2015.2018. 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)202020192018
Derivative assets (CVA)$(118)$72 $77 
Derivative assets/liabilities (FVA)(24)(2)(15)
Derivative liabilities (DVA)24 (147)(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.
         
Valuation Adjustments on Derivatives (1)
   
         
Gains (Losses)GrossNet GrossNet GrossNet
(Dollars in millions)2017 2016 2015
Derivative assets (CVA)$330
$98
 $374
$214
 $255
$227
Derivative assets/liabilities (FVA)160
178
 186
102
 16
16
Derivative liabilities (DVA)(324)(281) 24
(141) (18)(153)
(1)
At December 31, 2017, 2016 and 2015, cumulative CVA reduced the derivative assets balance by $677 million, $1.0 billion and $1.4 billion, cumulative FVA reduced the net derivatives balance by $136 million, $296 million and $481 million, and cumulative DVA reduced the derivative liabilities balance by $450 million, $774 million and $750 million, respectively.


121117Bank of America 2017




NOTE 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 and AFS marketable equity securities at December 31, 20172020 and 2016.2019.
Debt Securities
Amortized
Cost
Gross
Unrealized
Gains
Gross
Unrealized
Losses
Fair
Value
(Dollars in millions)December 31, 2020
Available-for-sale debt securities
Mortgage-backed securities:
Agency$59,518 $2,370 $(39)$61,849 
Agency-collateralized mortgage obligations5,112 161 (13)5,260 
Commercial15,470 1,025 (4)16,491 
Non-agency residential (1)
899 127 (17)1,009 
Total mortgage-backed securities80,999 3,683 (73)84,609 
U.S. Treasury and agency securities114,157 2,236 (13)116,380 
Non-U.S. securities14,009 15 (7)14,017 
Other taxable securities, substantially all asset-backed securities2,656 61 (6)2,711 
Total taxable securities211,821 5,995 (99)217,717 
Tax-exempt securities16,417 389 (32)16,774 
Total available-for-sale debt securities (3)
228,238 6,384 (131)234,491 
Other debt securities carried at fair value (2)
11,720 429 (39)12,110 
Total debt securities carried at fair value239,958 6,813 (170)246,601 
Held-to-maturity debt securities, substantially all U.S. agency mortgage-backed securities (3)
438,279 10,095 (194)448,180 
Total debt securities (3,4)
$678,237 $16,908 $(364)$694,781 
December 31, 2019
Available-for-sale debt securities
Mortgage-backed securities:
Agency$121,698 $1,013 $(183)$122,528 
Agency-collateralized mortgage obligations4,587 78 (24)4,641 
Commercial14,797 249 (25)15,021 
Non-agency residential (1)
948 138 (9)1,077 
Total mortgage-backed securities142,030 1,478 (241)143,267 
U.S. Treasury and agency securities67,700 1,023 (195)68,528 
Non-U.S. securities11,987 (2)11,991 
Other taxable securities, substantially all asset-backed securities3,874 67 3,941 
Total taxable securities225,591 2,574 (438)227,727 
Tax-exempt securities17,716 202 (6)17,912 
Total available-for-sale debt securities243,307 2,776 (444)245,639 
Other debt securities carried at fair value (2)
10,596 255 (23)10,828 
Total debt securities carried at fair value253,903 3,031 (467)256,467 
Held-to-maturity debt securities, substantially all U.S. agency mortgage-backed securities215,730 4,433 (342)219,821 
Total debt securities (3, 4)
$469,633 $7,464 $(809)$476,288 
        
Debt Securities and Available-for-Sale Marketable Equity Securities    
  
 
Amortized
Cost
 
Gross
Unrealized
Gains
 
Gross
Unrealized
Losses
 
Fair
Value
(Dollars in millions)December 31, 2017
Available-for-sale debt securities       
Mortgage-backed securities:       
Agency$194,119
 $506
 $(1,696) $192,929
Agency-collateralized mortgage obligations6,846
 39
 (81) 6,804
Commercial13,864
 28
 (208) 13,684
Non-agency residential (1)
2,410
 267
 (8) 2,669
Total mortgage-backed securities217,239
 840
 (1,993) 216,086
U.S. Treasury and agency securities54,523
 18
 (1,018) 53,523
Non-U.S. securities6,669
 9
 (1) 6,677
Other taxable securities, substantially all asset-backed securities5,699
 73
 (2) 5,770
Total taxable securities284,130
 940
 (3,014) 282,056
Tax-exempt securities20,541
 138
 (104) 20,575
Total available-for-sale debt securities304,671
 1,078
 (3,118) 302,631
Other debt securities carried at fair value12,273
 252
 (39) 12,486
Total debt securities carried at fair value316,944
 1,330
 (3,157) 315,117
Held-to-maturity debt securities, substantially all U.S. agency mortgage-backed securities125,013
 111
 (1,825) 123,299
Total debt securities (2)
$441,957
 $1,441
 $(4,982) $438,416
Available-for-sale marketable equity securities (3)
$27
 $
 $(2) $25
        
 December 31, 2016
Available-for-sale debt securities       
Mortgage-backed securities: 
  
  
  
Agency$190,809
 $640
 $(1,963) $189,486
Agency-collateralized mortgage obligations8,296
 85
 (51) 8,330
Commercial12,594
 21
 (293) 12,322
Non-agency residential (1)
1,863
 181
 (31) 2,013
Total mortgage-backed securities213,562
 927
 (2,338) 212,151
U.S. Treasury and agency securities48,800
 204
 (752) 48,252
Non-U.S. securities6,372
 13
 (3) 6,382
Other taxable securities, substantially all asset-backed securities10,573
 64
 (23) 10,614
Total taxable securities279,307
 1,208
 (3,116) 277,399
Tax-exempt securities17,272
 72
 (184) 17,160
Total available-for-sale debt securities296,579
 1,280
 (3,300) 294,559
Less: Available-for-sale securities of business held for sale (4)
(619) 
 
 (619)
Other debt securities carried at fair value19,748
 121
 (149) 19,720
Total debt securities carried at fair value315,708
 1,401
 (3,449) 313,660
Held-to-maturity debt securities, substantially all U.S. agency mortgage-backed securities117,071
 248
 (2,034) 115,285
Total debt securities (2)
$432,779
 $1,649
 $(5,483) $428,945
Available-for-sale marketable equity securities (3)
$325
 $51
 $(1) $375
(1)At December 31, 2020 and 2019, the underlying collateral type included approximately 37 percent and 49 percent prime, 2 percent and 6 percent Alt-A and 61 percent and 45 percent subprime.
(1)
(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.
(3)Includes securities pledged as collateral of $65.5 billion and $67.0 billion at December 31, 2020 and 2019.
(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, 2017 and 2016, the underlying collateral type included approximately 62 percent and 60 percent prime, 13 percent and 19 percent Alt-A, and 25 percent and 21 percent subprime.
(2)
The Corporation had debt securities from FNMA and FHLMC that each exceeded 10 percent of shareholders’ equity, with an amortized cost of $163.6 billion and $50.3 billion, and a fair value of $162.1 billion and $50.0 billion at December 31, 2017, and an amortized cost of $156.4 billion and $48.7 billion, and a fair value of $154.4 billion and $48.3 billion at December 31, 2016.
(3)
Classified in other assets on the Consolidated Balance Sheet.
(4)
Represents AFS debt securities of business held for sale. In 2017, the Corporation sold its non-U.S. consumer credit card business.
At December 31, 2017,2020, the accumulated net unrealized lossgain on AFS debt securities, excluding the amount related to debt securities previously transferred to held to maturity, included in accumulated OCI was $1.2$4.7 billion, net of the related income tax benefitexpense of $872 million. At December 31, 2017 and 2016, the$1.6 billion. The Corporation had nonperforming AFS debt securities of $99$20 million and $121 million.
$9 million at December 31, 2020 and 2019.
The following table presentsEffective January 1, 2020, the componentsCorporation adopted the new accounting standard for credit losses that requires evaluation of otherAFS and HTM debt securities carriedfor 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 whereof $769 million and $891 million and other equity securities, as valued under the changesmeasurement 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 reportedincluded in time deposits placed and other income. In 2017, the Corporation recorded unrealized mark-to-market net gains of $243 million and realized net losses of $49 million compared to unrealized mark-to-market net gains of $51 million and realized net losses of $128 million in 2016. These amounts exclude hedge results.short-term investments.


Bank of America 2017122118


    
Other Debt Securities Carried at Fair Value
  
 December 31
(Dollars in millions)2017 2016
Mortgage-backed securities:   
Agency-collateralized mortgage obligations$5
 $5
Non-agency residential2,764
 3,139
Total mortgage-backed securities2,769
 3,144
Non-U.S. securities (1)
9,488
 16,336
Other taxable securities, substantially all asset-backed securities229
 240
Total$12,486
 $19,720

(1)
These securities are primarily used to satisfy certain international regulatory liquidity requirements.
The gross realized gains and losses on sales of AFS debt securities for 2017, 20162020, 2019 and 20152018 are presented in the table below.
      
Gains and Losses on Sales of AFS Debt Securities
      
(Dollars in millions)2017 2016 2015
Gross gains$352
 $520
 $1,174
Gross losses(97) (30) (36)
Net gains on sales of AFS debt securities$255
 $490
 $1,138
Income tax expense attributable to realized net gains on sales of AFS debt securities$97
 $186
 $432
Gains and Losses on Sales of AFS Debt Securities
(Dollars in millions)202020192018
Gross gains$423 $336 $169 
Gross losses(12)(119)(15)
Net gains on sales of AFS debt securities$411 $217 $154 
Income tax expense attributable to realized net gains on sales of AFS debt securities$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, 20172020 and 2016.2019.
            
Temporarily Impaired and Other-than-temporarily Impaired AFS Debt Securities      
  
 Less than Twelve Months Twelve Months or Longer Total
 
Fair
Value
 Gross Unrealized Losses 
Fair
Value
 Gross Unrealized Losses 
Fair
Value
 Gross Unrealized Losses
(Dollars in millions)December 31, 2017
Temporarily impaired AFS debt securities           
Mortgage-backed securities:           
Agency$73,535
 $(352) $72,612
 $(1,344) $146,147
 $(1,696)
Agency-collateralized mortgage obligations2,743
 (29) 1,684
 (52) 4,427
 (81)
Commercial5,575
 (50) 4,586
 (158) 10,161
 (208)
Non-agency residential335
 (7) 
 
 335
 (7)
Total mortgage-backed securities82,188
 (438) 78,882
 (1,554) 161,070
 (1,992)
U.S. Treasury and agency securities27,537
 (251) 24,035
 (767) 51,572
 (1,018)
Non-U.S. securities772
 (1) 
 
 772
 (1)
Other taxable securities, substantially all asset-backed securities
 
 92
 (2) 92
 (2)
Total taxable securities110,497
 (690) 103,009
 (2,323) 213,506
 (3,013)
Tax-exempt securities1,090
 (2) 7,100
 (102) 8,190
 (104)
Total temporarily impaired AFS debt securities111,587
 (692) 110,109
 (2,425) 221,696
 (3,117)
Other-than-temporarily impaired AFS debt securities (1)
           
Non-agency residential mortgage-backed securities58
 (1) 
 
 58
 (1)
Total temporarily impaired and other-than-temporarily impaired
AFS debt securities
$111,645
 $(693) $110,109
 $(2,425) $221,754
 $(3,118)
 ��          
 December 31, 2016
Temporarily impaired AFS debt securities           
Mortgage-backed securities:           
Agency$135,210
 $(1,846) $3,770
 $(117) $138,980
 $(1,963)
Agency-collateralized mortgage obligations3,229
 (25) 1,028
 (26) 4,257
 (51)
Commercial9,018
 (293) 
 
 9,018
 (293)
Non-agency residential212
 (1) 204
 (13) 416
 (14)
Total mortgage-backed securities147,669
 (2,165) 5,002
 (156) 152,671
 (2,321)
U.S. Treasury and agency securities28,462
 (752) 
 
 28,462
 (752)
Non-U.S. securities52
 (1) 142
 (2) 194
 (3)
Other taxable securities, substantially all asset-backed securities762
 (5) 1,438
 (18) 2,200
 (23)
Total taxable securities176,945
 (2,923) 6,582
 (176) 183,527
 (3,099)
Tax-exempt securities4,782
 (148) 1,873
 (36) 6,655
 (184)
Total temporarily impaired AFS debt securities181,727
 (3,071) 8,455
 (212) 190,182
 (3,283)
Other-than-temporarily impaired AFS debt securities (1)
           
Non-agency residential mortgage-backed securities94
 (1) 401
 (16) 495
 (17)
Total temporarily impaired and other-than-temporarily impaired
AFS debt securities
$181,821
 $(3,072) $8,856
 $(228) $190,677
 $(3,300)
(1)
Includes OTTI AFS debt securities on which an OTTI loss, primarily related to changes in interest rates, remains in accumulated OCI.

Total AFS Debt Securities in a Continuous Unrealized Loss Position
Less than Twelve MonthsTwelve Months or LongerTotal
Fair
Value
Gross Unrealized LossesFair
Value
Gross Unrealized LossesFair
Value
Gross Unrealized Losses
(Dollars in millions)December 31, 2020
Continuously unrealized loss-positioned AFS debt securities
Mortgage-backed securities:   
Agency$2,841 $(39)$2 $0 $2,843 $(39)
Agency-collateralized mortgage obligations187 (2)364 (11)551 (13)
Commercial566 (4)9 0 575 (4)
Non-agency residential342 (9)56 (8)398 (17)
Total mortgage-backed securities3,936 (54)431 (19)4,367 (73)
U.S. Treasury and agency securities8,282 (9)498 (4)8,780 (13)
Non-U.S. securities1,861 (6)135 (1)1,996 (7)
Other taxable securities, substantially all asset-backed securities576 (2)396 (4)972 (6)
Total taxable securities14,655 (71)1,460 (28)16,115 (99)
Tax-exempt securities4,108 (29)617 (3)4,725 (32)
Total AFS debt securities in a continuous
unrealized loss position
$18,763 $(100)$2,077 $(31)$20,840 $(131)
December 31, 2019
Continuously unrealized loss-positioned AFS debt securities
Mortgage-backed securities:
Agency$17,641 $(41)$17,238 $(142)$34,879 $(183)
Agency-collateralized mortgage obligations255 (1)925 (23)1,180 (24)
Commercial2,180 (22)442 (3)2,622 (25)
Non-agency residential122 (6)22 (3)144 (9)
Total mortgage-backed securities20,198 (70)18,627 (171)38,825 (241)
U.S. Treasury and agency securities12,836 (71)18,866 (124)31,702 (195)
Non-U.S. securities851 837 (2)1,688 (2)
Other taxable securities, substantially all asset-backed securities938 222 1,160 
Total taxable securities34,823 (141)38,552 (297)73,375 (438)
Tax-exempt securities4,286 (5)190 (1)4,476 (6)
Total AFS debt securities in a continuous
unrealized loss position
$39,109 $(146)$38,742 $(298)$77,851 $(444)
123Bank of America 2017




The Corporation had $41 million, $19 million and $81 million of credit-related OTTI losses on AFS debt securities that were recognized in other income in 2017, 2016 and 2015, respectfully. The amount of noncredit-related OTTI losses, which is recognized in OCI, was insignificant for all periods presented.
The cumulative credit loss component of OTTI losses that have been recognized in income related to AFS debt securities that the Corporation does not intend to sell was $274 million, $253 million and $266 million at December 31, 2017, 2016 and 2015, respectfully.
The Corporation estimates the portion of a loss on a security that is attributable to credit using a discounted cash flow model and estimates the expected cash flows of the underlying collateral using internal credit, interest rate and prepayment risk models that incorporate management’s best estimate of current key assumptions such as default rates, loss severity and prepayment rates. Assumptions used for the underlying loans that support the MBS can vary widely from loan to loan and are influenced by such factors as loan interest rate, geographic location of the borrower, borrower characteristics and collateral type. Based on these assumptions, the Corporation then determines how the underlying collateral cash flows will be distributed to each MBS issued from the applicable special purpose entity. Expected principal and interest cash flows on an impaired AFS debt security are discounted using the effective yield of each individual impaired AFS debt security.
Significant assumptions used in estimating the expected cash flows for measuring credit losses on non-agency residential mortgage-backed securities (RMBS) were as follows at December 31, 2017.
      
Significant Assumptions
    
   
Range (1)
 Weighted-
average
 
10th
Percentile (2)
 
90th
Percentile (2)
Prepayment speed12.4% 3.0% 21.3%
Loss severity20.2
 9.1
 36.7
Life default rate20.9
 1.2
 76.6
(1)
Represents the range of inputs/assumptions based upon the underlying collateral.
(2)
The value of a variable below which the indicated percentile of observations will fall.
Annual constant prepayment speed and loss severity rates are projected considering collateral characteristics such as LTV, creditworthiness of borrowers as measured using Fair Isaac Corporation (FICO) scores, and geographic concentrations. The weighted-average severity by collateral type was 17.5 percent for prime, 18.1 percent for Alt-A and 29.0 percent for subprime at December 31, 2017. Default rates are projected by considering collateral characteristics including, but not limited to, LTV, FICO and geographic concentration. Weighted-average life default rates by collateral type were 16.9 percent for prime, 21.4 percent for Alt-A and 21.6 percent for subprime at December 31, 2017.

119Bank of America 2017124



The remaining contractual maturity distribution and yields of the Corporation’s debt securities carried at fair value and HTM debt securities at December 31, 20172020 are summarized in the table below. Actual duration and yields may differ as prepayments on the loans underlying the mortgages or other ABS are passed through to the Corporation.
Maturities of Debt Securities Carried at Fair Value and Held-to-maturity Debt Securities
Due in One
Year or Less
Due after One Year
through Five Years
Due after Five Years
through Ten Years
Due after
Ten Years
Total
(Dollars in millions)Amount
Yield (1)
Amount
Yield (1)
Amount
Yield (1)
Amount
Yield (1)
Amount
Yield (1)
Amortized cost of debt securities carried at fair value          
Mortgage-backed securities:          
Agency$%$5.69 %$56 4.44 %$59,455 3.36 %$59,518 3.36 %
Agency-collateralized mortgage obligations24 2.57 5,088 2.94 5,112 2.94 
Commercial26 3.04 6,669 2.52 7,711 2.32 1,077 2.64 15,483 2.43 
Non-agency residential1,620 6.77 1,621 6.77 
Total mortgage-backed securities26 3.04 6,676 2.52 7,792 2.34 67,240 3.40 81,734 3.23 
U.S. Treasury and agency securities10,020 1.26 29,533 1.85 74,665 0.74 32 2.55 114,250 1.07 
Non-U.S. securities22,862 0.31 926 1.81 581 1.09 532 1.79 24,901 0.42 
Other taxable securities, substantially all asset-backed securities699 1.15 1,336 2.46 366 2.26 255 1.60 2,656 2.00 
Total taxable securities33,607 0.61 38,471 1.99 83,404 0.89 68,059 3.38 223,541 1.80 
Tax-exempt securities872 0.87 8,430 1.27 4,397 1.66 2,718 1.41 16,417 1.38 
Total amortized cost of debt securities carried at fair value$34,479 0.62 $46,901 1.86 $87,801 0.93 $70,777 3.30 $239,958 1.77 
Amortized cost of HTM debt securities (2)
$15 3.78 $66 2.73 $17,133 1.86 $421,065 2.40 $438,279 2.38 
Debt securities carried at fair value          
Mortgage-backed securities:          
Agency$ $ $61  $61,781  $61,849  
Agency-collateralized mortgage obligations  24  5,236  5,260  
Commercial26  7,077  8,242  1,160  16,505  
Non-agency residential   1,776  1,783  
Total mortgage-backed securities26 7,084 8,334 69,953 85,397 
U.S. Treasury and agency securities10,056 30,873 75,511 33 116,473 
Non-U.S. securities23,187  940  582  534  25,243  
Other taxable securities, substantially all asset-backed securities702  1,369  379  264  2,714  
Total taxable securities33,971  40,266  84,806  70,784  229,827  
Tax-exempt securities874  8,554  4,566  2,780  16,774  
Total debt securities carried at fair value$34,845  $48,820  $89,372  $73,564  $246,601  
Fair value of HTM debt securities (2)
$14 $69 $17,139 $430,958 $448,180 
(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.
                    
Maturities of Debt Securities Carried at Fair Value and Held-to-maturity Debt Securities
                    
 
Due in One
Year or Less
 
Due after One Year
through Five Years
 
Due after Five Years
through Ten Years
 
Due after
Ten Years
 Total
 Amount 
Yield (1)
 Amount 
Yield (1)
 Amount 
Yield (1)
 Amount 
Yield (1)
 Amount 
Yield (1)
(Dollars in millions)December 31, 2017
Amortized cost of debt securities carried at fair value 
  
  
  
  
  
  
  
  
  
Mortgage-backed securities: 
  
  
  
  
  
  
  
  
  
Agency$5
 4.20% $28
 3.69% $555
 2.57% $193,531
 3.22% $194,119
 3.22%
Agency-collateralized mortgage obligations
 
 
 
 33
 2.52
 6,817
 3.18
 6,850
 3.18
Commercial54
 7.45
 974
 1.98
 11,866
 2.43
 970
 2.78
 13,864
 2.44
Non-agency residential
 
 
 
 24
 0.01
 4,955
 9.32
 4,979
 9.28
Total mortgage-backed securities59
 7.18
 1,002
 2.03
 12,478
 2.43
 206,273
 3.36
 219,812
 3.31
U.S. Treasury and agency securities490
 0.39
 23,395
 1.42
 30,615
 2.03
 23
 2.52
 54,523
 1.75
Non-U.S. securities13,832
 1.02
 2,111
 0.97
 48
 0.72
 167
 6.60
 16,158
 1.07
Other taxable securities, substantially all asset-backed securities1,979
 2.53
 2,029
 3.02
 1,151
 3.22
 751
 4.74
 5,910
 3.11
Total taxable securities16,360
 1.21
 28,537
 1.52
 44,292
 2.17
 207,214
 3.37
 296,403
 2.89
Tax-exempt securities1,327
 1.81
 6,927
 1.88
 9,132
 1.79
 3,155
 1.84
 20,541
 1.83
Total amortized cost of debt securities carried at fair value$17,687
 1.25
 $35,464
 1.59
 $53,424
 2.11
 $210,369
 3.35
 $316,944
 2.82
Amortized cost of HTM debt securities (2)
$1
 5.82
 $71
 3.06
 $1,144
 2.65
 $123,797
 3.03
 $125,013
 3.03
                    
Debt securities carried at fair value 
  
  
  
  
  
  
  
  
  
Mortgage-backed securities: 
  
  
  
  
  
  
  
  
  
Agency$5
  
 $28
  
 $555
  
 $192,341
  
 $192,929
  
Agency-collateralized mortgage obligations
  
 
  
 32
  
 6,777
  
 6,809
  
Commercial54
  
 969
  
 11,703
  
 958
  
 13,684
  
Non-agency residential
  
 
  
 33
  
 5,400
  
 5,433
  
Total mortgage-backed securities59
   997
   12,323
   205,476
   218,855
  
U.S. Treasury and agency securities491
   22,898
   30,111
   23
   53,523
  
Non-U.S. securities13,830
  
 2,115
  
 48
  
 172
  
 16,165
  
Other taxable securities, substantially all asset-backed securities1,981
  
 2,006
  
 1,184
  
 828
  
 5,999
  
Total taxable securities16,361
  
 28,016
  
 43,666
  
 206,499
  
 294,542
  
Tax-exempt securities1,326
  
 6,934
  
 9,162
  
 3,153
  
 20,575
  
Total debt securities carried at fair value$17,687
  
 $34,950
  
 $52,828
  
 $209,652
  
 $315,117
  
Fair value of HTM debt securities (2)
$1
   $71
   $1,117
   $122,110
   $123,299
  
(1)
The 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.


125Bank of America 2017120




NOTE 45Outstanding 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, 20172020 and 2016.2019.
In 2017,
30-59 Days Past Due (1)
60-89 Days Past Due (1)
90 Days or
More
Past Due (1)
Total Past
Due 30 Days
or More
Total Current or Less Than 30 Days Past Due (1)
Loans Accounted for Under the Fair Value OptionTotal
Outstandings
(Dollars in millions)December 31, 2020
Consumer real estate      
Core portfolio
Residential mortgage$1,157 $175 $786 $2,118 $213,155 $215,273 
Home equity126 61 269 456 29,872 30,328 
Non-core portfolio
Residential mortgage273 122 913 1,308 6,974 8,282 
Home equity28 17 76 121 3,862 3,983 
Credit card and other consumer
Credit card445 341 903 1,689 77,019 78,708 
Direct/Indirect consumer (2)
209 67 37 313 91,050 91,363 
Other consumer0 0 0 0 124 124 
Total consumer2,238 783 2,984 6,005 422,056 428,061 
Consumer loans accounted for under the fair value option (3)
     $735 735 
Total consumer loans and leases2,238 783 2,984 6,005 422,056 735 428,796 
Commercial
U.S. commercial561 214 512 1,287 287,441 288,728 
Non-U.S. commercial61 44 11 116 90,344 90,460 
Commercial real estate (4)
128 113 226 467 59,897 60,364 
Commercial lease financing86 20 57 163 16,935 17,098 
U.S. small business commercial (5)
84 56 123 263 36,206 36,469 
Total commercial920 447 929 2,296 490,823 493,119 
Commercial loans accounted for under the fair value option (3)
     5,946 5,946 
Total commercial loans and leases920 447 929 2,296 490,823 5,946 499,065 
Total loans and leases (6)
$3,158 $1,230 $3,913 $8,301 $912,879 $6,681 $927,861 
Percentage of outstandings0.34 %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 sold its non-U.S. consumer credit card business. This business, which at December 31, 2016 included
$9.2 billion of non-U.S. credit card loansCorporation's interest accrual policies and the related allowancedelinquency status for loan and lease losses of $243 million, was presented in assets of business held for sale onmodifications related to the Consolidated Balance Sheet. In this Note, all applicable amounts for December 31, 2016 include these balances, unless otherwise noted. For more information,pandemic, see Note 1 – Summary of Significant Accounting Principles.
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.
                
 
30-59 Days Past Due (1)
 
60-89 Days Past Due (1)
 
90 Days or
More
Past Due (2)
 
Total Past
Due 30 Days
or More
 
Total Current or Less Than 30 Days Past Due (3)
 
Purchased
Credit-impaired
(4)
 Loans Accounted for Under the Fair Value Option 
Total
Outstandings
(Dollars in millions)December 31, 2017
Consumer real estate 
    
  
  
  
  
  
Core portfolio               
Residential mortgage$1,242
 $321
 $1,040
 $2,603
 $174,015
     $176,618
Home equity215
 108
 473
 796
 43,449
     44,245
Non-core portfolio               
Residential mortgage (5)
1,028
 468
 3,535
 5,031
 14,161
 $8,001
   27,193
Home equity224
 121
 572
 917
 9,866
 2,716
   13,499
Credit card and other consumer               
U.S. credit card542
 405
 900
 1,847
 94,438
     96,285
Direct/Indirect consumer (6)
320
 102
 43
 465
 93,365
     93,830
Other consumer (7)
10
 2
 1
 13
 2,665
     2,678
Total consumer3,581
 1,527
 6,564
 11,672
 431,959
 10,717
   454,348
Consumer loans accounted for under the fair value option (8)
 
  
  
  
  
  
 $928
 928
Total consumer loans and leases3,581
 1,527
 6,564
 11,672
 431,959
 10,717
 928
 455,276
Commercial               
U.S. commercial547
 244
 425
 1,216
 283,620
     284,836
Non-U.S. commercial52
 1
 3
 56
 97,736
     97,792
Commercial real estate (9)
48
 10
 29
 87
 58,211
     58,298
Commercial lease financing110
 68
 26
 204
 21,912
     22,116
U.S. small business commercial95
 45
 88
 228
 13,421
     13,649
Total commercial852
 368
 571
 1,791
 474,900
     476,691
Commercial loans accounted for under the fair value option (8)
 
  
  
  
  
  
 4,782
 4,782
Total commercial loans and leases852
 368
 571
 1,791
 474,900
   4,782
 481,473
Total loans and leases (10)
$4,433
 $1,895
 $7,135
 $13,463
 $906,859
 $10,717
 $5,710
 $936,749
Percentage of outstandings0.48% 0.20% 0.76% 1.44% 96.81% 1.14% 0.61% 100.00%
(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.
(1)
Consumer real estate loans 30-59 days past due includes fully-insured loans of $850 million and nonperforming loans of $253 million. Consumer real estate loans 60-89 days past due includes fully-insured loans of $386 million and nonperforming loans of $195 million.
(2)
Consumer real estate includes fully-insured loans of $3.2 billion.
(3)
Consumer real estate includes $2.3 billion and direct/indirect consumer includes $43 million of nonperforming loans.
(4)
PCI loan amounts are shown gross of the valuation allowance.
(5)
Total outstandings includes pay option loans of $1.4 billion. The Corporation no longer originates this product.
(6)
Total outstandings includes auto and specialty lending loans of $49.9 billion, unsecured consumer lending loans of $469 million, U.S. securities-based lending loans of $39.8 billion, non-U.S. consumer loans of $3.0 billion and other consumer loans of $684 million.
(7)
Total outstandings includes consumer leases of $2.5 billion and consumer overdrafts of $163 million.
(8)
Consumer loans accounted for under the fair value option includes residential mortgage loans of $567 million and home equity loans of $361 million. Commercial loans accounted for under the fair value option includes U.S. commercial loans of $2.6 billion and non-U.S. commercial loans of $2.2 billion. For more information, see Note 20 – Fair Value Measurements and Note 21 – Fair Value Option.
(9)
Total outstandings includes U.S. commercial real estate loans of $54.8 billion and non-U.S. commercial real estate loans of $3.5 billion.
(10)
The Corporation pledged $160.3 billion of loans to secure potential borrowing capacity with the Federal Reserve Bank and Federal Home Loan Bank (FHLB). This amount is not included in the parenthetical disclosure of loans and leases pledged as collateral on the Consolidated Balance Sheet as there were no related outstanding borrowings.

(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)Includes PPP loans.
(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 potential borrowing capacity with the Federal Reserve Bank and Federal Home Loan Bank.
121Bank of America 2017126



               
30-59 Days
Past Due
(1)
 
60-89 Days Past Due (1)
 
90 Days or
More
Past Due
(2)
 Total Past
Due 30 Days
or More
 
Total
Current or
Less Than
30 Days
Past Due (3)
 
Purchased
Credit-impaired
(4)
 
Loans
Accounted
for Under
the Fair
Value Option
 Total Outstandings
30-59 Days
Past Due
(1)
60-89 Days Past Due (1)
90 Days or
More
Past Due
(1)
Total Past
Due 30 Days
or More
Total
Current or
Less Than
30 Days
Past Due (1)
Loans
Accounted
for Under
the Fair
Value Option
Total Outstandings
(Dollars in millions)December 31, 2016(Dollars in millions)December 31, 2019
Consumer real estate 
    
  
  
  
  
  
Consumer real estate      
Core portfolio               Core portfolio
Residential mortgage$1,340
 $425
 $1,213
 $2,978
 $153,519
 

  
 $156,497
Residential mortgage$1,378 $261 $565 $2,204 $223,566  $225,770 
Home equity239
 105
 451
 795
 48,578
 

  
 49,373
Home equity135 70 198 403 34,823  35,226 
Non-core portfolio   
  
  
  
  
  
  
Non-core portfolio       
Residential mortgage (5)
1,338
 674
 5,343
 7,355
 17,818
 $10,127
  
 35,300
Residential mortgageResidential mortgage458 209 1,263 1,930 8,469  10,399 
Home equity260
 136
 832
 1,228
 12,231
 3,611
  
 17,070
Home equity34 16 72 122 4,860  4,982 
Credit card and other consumer   
  
  
  
  
  
  
Credit card and other consumer       
U.S. credit card472
 341
 782
 1,595
 90,683
    
 92,278
Non-U.S. credit card37
 27
 66
 130
 9,084
    
 9,214
Direct/Indirect consumer (6)
272
 79
 34
 385
 93,704
    
 94,089
Other consumer (7)
26
 8
 6
 40
 2,459
    
 2,499
Credit cardCredit card564 429 1,042 2,035 95,573  97,608 
Direct/Indirect consumer (2)
Direct/Indirect consumer (2)
297 85 35 417 90,581  90,998 
Other consumer Other consumer 192  192 
Total consumer3,984
 1,795
 8,727
 14,506
 428,076
 13,738
  
456,320
Total consumer2,866 1,070 3,175 7,111 458,064 465,175 
Consumer loans accounted for under the fair value option (8)
            $1,051

1,051
Consumer loans accounted for under the fair value option (3)
Consumer loans accounted for under the fair value option (3)
$594 594 
Total consumer loans and leases3,984
 1,795
 8,727
 14,506
 428,076
 13,738
 1,051
 457,371
Total consumer loans and leases2,866 1,070 3,175 7,111 458,064 594 465,769 
Commercial   
  
  
  
  
  
  
Commercial       
U.S. commercial952
 263
 400
 1,615
 268,757
    
 270,372
U.S. commercial788 279 371 1,438 305,610  307,048 
Non-U.S. commercial348
 4
 5
 357
 89,040
    
 89,397
Non-U.S. commercial35 23 66 104,900  104,966 
Commercial real estate (9)(4)
20
 10
 56
 86
 57,269
    
 57,355
144 19 119 282 62,407  62,689 
Commercial lease financing167
 21
 27
 215
 22,160
    
 22,375
Commercial lease financing100 56 39 195 19,685  19,880 
U.S. small business commercial96
 49
 84
 229
 12,764
    
 12,993
U.S. small business commercial119 56 107 282 15,051  15,333 
Total commercial1,583
 347
 572
 2,502
 449,990
    
 452,492
Total commercial1,186 433 644 2,263 507,653  509,916 
Commercial loans accounted for under the fair value option (8)(3)
            6,034
 6,034
7,741 7,741 
Total commercial loans and leases1,583
 347
 572
 2,502
 449,990
   6,034
 458,526
Total commercial loans and leases1,186 433 644 2,263 507,653 7,741 517,657 
Total consumer and commercial loans and leases (10)
$5,567
 $2,142
 $9,299
 $17,008
 $878,066
 $13,738
 $7,085
 $915,897
Less: Loans of business held for sale (10)
              (9,214)
Total loans and leases (11)
              $906,683
Percentage of outstandings (10)
0.61% 0.23% 1.02% 1.86% 95.87% 1.50% 0.77% 100.00%
Total loans and leases (5)
Total loans and leases (5)
$4,052 $1,503 $3,819 $9,374 $965,717 $8,335 $983,426 
Percentage of outstandingsPercentage of outstandings0.41 %0.15 %0.39 %0.95 %98.20 %0.85 %100.00 %
(1)
(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.
Consumer real estate loans 30-59 days past due includes fully-insured loans of $1.1 billion and nonperforming loans of $266 million. Consumer real estate loans 60-89 days past due includes fully-insured loans of $547 million and nonperforming loans of $216 million.
(2)
Consumer real estate includes fully-insured loans of $4.8 billion.
(3)
Consumer real estate includes $2.5 billion and direct/indirect consumer includes $27 million of nonperforming loans.
(4)
PCI loan amounts are shown gross of the valuation allowance.
(5)
Total outstandings includes pay option loans of $1.8 billion. The Corporation no longer originates this product.
(6)
Total outstandings includes auto and specialty lending loans of $48.9 billion, unsecured consumer lending loans of $585 million, U.S. securities-based lending loans of $40.1 billion, non-U.S. consumer loans of $3.0 billion, student loans of $497 million and other consumer loans of $1.1 billion.
(7)
Total outstandings includes consumer finance loans of $465 million, consumer leases of $1.9 billion and consumer overdrafts of $157 million.
(8)
Consumer loans accounted for under the fair value option includes residential mortgage loans of $710 million and home equity loans of $341 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 $3.1 billion. For more information, see Note 20 – Fair Value Measurements and Note 21 – Fair Value Option.
(9)
Total outstandings includes U.S. commercial real estate loans of $54.3 billion and non-U.S. commercial real estate loans of $3.1 billion.
(10)
Includes non-U.S. credit card loans, which were included in assets of business held for sale on the Consolidated Balance Sheet.
(11)
The Corporation pledged $143.1 billion of loans to secure potential borrowing capacity with the Federal Reserve Bank and FHLB. This amount is not included in the parenthetical disclosure of loans and leases pledged as collateral on the Consolidated Balance Sheet as there were no related outstanding borrowings.
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, FICOFair 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 run-offrunoff portfolios.
The Corporation has entered into long-term credit protection agreements with FNMA and FHLMC on loans totaling $6.3$9.0 billion and $6.4$7.5 billion at December 31, 20172020 and 2016,2019, 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.
Nonperforming Loans and Leases
The Corporation classifies junior-lien home equity loans as nonperforming when the first-lien loan becomes 90 days past due even if the junior-lien loan is performing. At December 31, 2017 and 2016, $330 million and $428 million of such junior-lien home equity loans were included in nonperforming loans.
The Corporation classifies consumer real estate loans that have been discharged in Chapter 7 bankruptcy and not reaffirmed by the borrower as TDRs, irrespective of payment history or delinquency status, even if the repayment terms for the loan have not been otherwise modified. The Corporation continues to have a lien on the underlying collateral. At December 31, 2017,Commercial nonperforming loans discharged in Chapter 7 bankruptcy with no change in repayment terms were $358 million of which $209 million were current on their contractual payments, while $124 million were 90 days or more past due. Of the contractually current nonperforming loans, 66 percent were discharged in Chapter 7

127Bank of America 2017



bankruptcy over 12 months ago, and 57 percent were discharged 24 months or more ago.
During 2017, the Corporation sold nonperforming and other delinquent consumer real estate loans with a carrying value of $1.3 billion, including $803 million of PCI loans, comparedincreased to $2.2 billion including $549at December 31, 2020 from $1.5 billion at December 31, 2019 with broad-based increases across multiple industries. 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 PCIcertain loans in 2016. The Corporation recorded net recoveries of $105 million related to these sales during 2017that were previously classified as purchased credit-impaired loans and net charge-offs of $30 million during 2016. Gains related to these sales of $57 million and $75 million were recorded in other income in the Consolidated Statement of Income during 2017 and 2016. In 2017 and 2016, the Corporation
accounted for under a pool basis.
transferred consumer nonperforming loans with a net carrying value of $198 million and $55 million to held-for-sale.
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, 20172020 and 2016.2019. 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 more information on the Corporation's interest accrual policies, delinquency status for loan modifications related to the pandemic and the criteria for classification as nonperforming, see Note 1 – Summary of Significant Accounting Principles.
Bank of America 122


Credit Quality
Nonperforming Loans
and Leases
Accruing Past Due
90 Days or More (1)
December 31
(Dollars in millions)2020201920202019
Residential mortgage (2)
$2,005 $1,470 $762 $1,088 
With no related allowance (3)
1,378 n/a0 
Home equity (2)
649 536 0 
With no related allowance (3)
347 n/a0 
Credit Cardn/an/a903 1,042 
Direct/indirect consumer71 47 33 33 
Total consumer2,725 2,053 1,698 2,163 
U.S. commercial1,243 1,094 228 106 
Non-U.S. commercial418 43 10 
Commercial real estate404 280 6 19 
Commercial lease financing87 32 25 20 
U.S. small business commercial75 50 115 97 
Total commercial2,227 1,499 384 250 
Total nonperforming loans$4,952 $3,552 $2,082 $2,413 
Percentage of outstanding loans and leases0.54 %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.
        
Credit Quality  
        
 
Nonperforming Loans
and Leases
 
Accruing Past Due
90 Days or More
 December 31
2017
(Dollars in millions)2017 2016 2017 2016
Consumer real estate 
  
  
  
Core portfolio       
Residential mortgage (1)
$1,087
 $1,274
 $417
 $486
Home equity1,079
 969
 
 
Non-core portfolio 
  
  
  
Residential mortgage (1)
1,389
 1,782
 2,813
 4,307
Home equity1,565
 1,949
 
 
Credit card and other consumer 
  
    
U.S. credit cardn/a
 n/a
 900
 782
Non-U.S. credit cardn/a
 n/a
 
 66
Direct/Indirect consumer46
 28
 40
 34
Other consumer
 2
 
 4
Total consumer5,166
 6,004
 4,170
 5,679
Commercial 
  
  
  
U.S. commercial814
 1,256
 144
 106
Non-U.S. commercial299
 279
 3
 5
Commercial real estate112
 72
 4
 7
Commercial lease financing24
 36
 19
 19
U.S. small business commercial55
 60
 75
 71
Total commercial1,304
 1,703
 245
 208
Total loans and leases$6,470
 $7,707
 $4,415
 $5,887
(1)
Residential mortgage loans in the core and non-core portfolios accruing past due 90 days or more are fully-insured loans. At December 31, 2017 and 2016, residential mortgage includes $2.2 billion and $3.0 billion of loans on which interest has been curtailed by the FHA, and therefore are no longer accruing interest, although principal is still insured, and $1.0 billion and $1.8 billion of loans on which interest is still accruing.
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
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 prepayments, using 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.
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 these loans 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 trends specific to the Metropolitan Statistical Area in which the property being valued is located. In the event that an AVM value is not available, the Corporation utilizes publicized indices or if these methods provide less reliable valuations, the Corporation uses appraisals or broker price opinions to estimate the fair value of the collateral. While there is inherent imprecision in these valuations, the Corporation believes that they are representative of this portfolio in the aggregate.
For loans that are more than 180 days past due and collateral-dependent TDRs, with the exception of the Corporation’s fully insured portfolio, the outstanding balance of loans that is in excess of the estimated property value after
Bank of America 104


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 (e.g., borrowers making full payments, 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.
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 reported as reserves for unfunded lending commitments.
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
105 Bank of America


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 portfolio segmentscommercial 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
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 that 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.
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 federal 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 0. 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.

Bank of America 106


Lessee Arrangements
Substantially all of the Corporation’s lessee arrangements are operating leases. Under these arrangements, the Corporation records right-of-use assets and lease liabilities at lease commencement. Right-of-use assets are reported in other assets on the Consolidated Balance Sheet, and the related lease liabilities are reported in accrued expenses and other liabilities. All leases are recorded on the Consolidated Balance Sheet except leases with an initial term less than 12 months for which the Corporation made the short-term lease election. Lease expense is recognized on a straight-line basis over the lease term and is recorded in occupancy and equipment expense in the Consolidated Statement of Income.
The Corporation made an accounting policy election not to separate lease and non-lease components of a contract that is or contains a lease for its real estate and equipment leases. As such, lease payments represent payments on both lease and non-lease components. At lease commencement, lease liabilities are recognized based on primarythe present value of the remaining lease payments and discounted using the Corporation’s incremental borrowing rate. Right-of-use assets initially equal the lease liability, adjusted for any lease payments made prior to lease commencement and for any lease incentives.
Goodwill and Intangible Assets
Goodwill is the purchase premium after adjusting for the fair value of net assets acquired. Goodwill is not amortized but is reviewed for potential impairment on an annual basis, or when events or circumstances indicate a potential impairment, at the reporting unit level. A reporting unit is a business segment or one level below a business segment.
The Corporation assesses the fair value of each reporting unit against its carrying value, including goodwill, as measured by allocated equity. For purposes of goodwill impairment testing, the Corporation utilizes allocated equity as a proxy for the carrying value of its reporting units. Allocated equity in the reporting units is comprised of allocated capital plus capital for the portion of goodwill and intangibles specifically assigned to the reporting unit.
In performing its goodwill impairment testing, the Corporation first assesses qualitative factors to determine whether it is more likely than not that the fair value of a reporting unit is less than its carrying value. Qualitative factors include, among other things, macroeconomic conditions, industry and market considerations, financial performance of the respective reporting unit and other relevant entity- and reporting-unit specific considerations.
If the Corporation concludes it is more likely than not that the fair value of a reporting unit is less than its carrying value, a quantitative assessment is performed. 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
reversals of goodwill impairment losses are not permitted under applicable accounting guidance.
For intangible assets subject to amortization, an impairment loss is recognized if the carrying value of the intangible asset is not recoverable and exceeds fair value. The carrying value of the intangible asset is considered not recoverable if it exceeds the sum of the undiscounted cash flows expected to result from the use of the asset. Intangible assets deemed to have indefinite useful lives are not subject to amortization. An impairment loss is recognized if the carrying value of the intangible asset with an indefinite life exceeds its fair value.
Variable Interest Entities
A VIE is an entity that lacks equity investors or whose equity investors do not have a controlling financial interest in the entity through their equity investments. The Corporation consolidates a VIE if it has both the power to direct the activities of the VIE that most significantly impact the VIE’s economic performance and an obligation to absorb losses or the right to receive benefits that could potentially be significant to the VIE. On a quarterly basis, the Corporation reassesses its involvement with the VIE and evaluates the impact of changes in governing documents and its financial interests in the VIE. The consolidation status of the VIEs with which the Corporation is involved may change as a result of such reassessments.
The Corporation primarily uses VIEs for its securitization activities, in which the Corporation transfers whole loans or debt securities into a trust or other vehicle. When the Corporation is the servicer of whole loans held in a securitization trust, including non-agency residential mortgages, home equity loans, credit quality indicators.cards, and other loans, the Corporation has the power to direct the most significant activities of the trust. The Corporation generally does not have the power to direct the most significant activities of a residential mortgage agency trust except in certain circumstances in which the Corporation holds substantially all of the issued securities and has the unilateral right to liquidate the trust. The power to direct the most significant activities of a commercial mortgage securitization trust is typically held by the special servicer or by the party holding specific subordinate securities which embody certain controlling rights. The Corporation consolidates a whole-loan securitization trust if it has the power to direct the most significant activities and also holds securities issued by the trust or has other contractual arrangements, other than standard representations and warranties, that could potentially be significant to the trust.
The Corporation may also transfer trading account securities and AFS securities into municipal bond or resecuritization trusts. The Corporation consolidates a municipal bond or resecuritization trust if it has control over the ongoing activities of the trust such as the remarketing of the trust’s liabilities or, if there are no ongoing activities, sole discretion over the design of the trust, including the identification of securities to be transferred in and the structure of securities to be issued, and also retains securities or has liquidity or other commitments that could potentially be significant to the trust. The Corporation does not consolidate a municipal bond or resecuritization trust if one or a limited number of third-party investors share responsibility for the design of the trust or have control over the significant activities of the trust through liquidation or other substantive rights.
Other VIEs used by the Corporation include collateralized debt obligations (CDOs), investment vehicles created on behalf of customers and other investment vehicles. The Corporation does not routinely serve as collateral manager for CDOs and, therefore, does not typically have the power to direct the
107 Bank of America


activities that most significantly impact the economic performance of a CDO. However, following an event of default, if the Corporation is a majority holder of senior securities issued by a CDO and acquires the power to manage its assets, the Corporation consolidates the CDO.
The Corporation consolidates a customer or other investment vehicle if it has control over the initial design of the vehicle or manages the assets in the vehicle and also absorbs potentially significant gains or losses through an investment in the vehicle, derivative contracts or other arrangements. The Corporation does not consolidate an investment vehicle if a single investor controlled the initial design of the vehicle or manages the assets in the vehicles or if the Corporation does not have a variable interest that could potentially be significant to the vehicle.
Retained interests in securitized assets are initially recorded at fair value. In addition, the Corporation may invest in debt securities issued by unconsolidated VIEs. Fair values of these debt securities, which are classified as trading account assets, debt securities carried at fair value or HTM securities, are based primarily on quoted market prices in active or inactive markets. Generally, quoted market prices for retained residual interests are not available; therefore, the Corporation estimates fair values based on the present value of the associated expected future cash flows.
Fair Value
The Corporation measures the fair values of its assets and liabilities, where applicable, in accordance with accounting guidance that requires an entity to base fair value on exit price. Under this guidance, an entity is required to maximize the use of observable inputs and minimize the use of unobservable inputs in measuring fair value. Under applicable accounting standards, fair value measurements are categorized into one of three levels 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 1Unadjusted 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 2Observable 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 3Unobservable inputs that are supported by little or no market activity and that are significant to the overall
fair value of the assets or liabilities. Level 3 assets and liabilities include financial instruments for which the determination of fair value requires significant management judgment or estimation. The fair value for such assets and liabilities is generally determined using pricing models, discounted cash flow methodologies or similar techniques that incorporate the assumptions a market participant would use in pricing the asset or liability. This category generally includes retained residual interests in securitizations, consumer MSRs, certain ABS, highly structured, complex or long-dated derivative contracts, certain loans and LHFS, IRLCs and certain CDOs where independent pricing information cannot be obtained for a significant portion of the underlying assets.
Income Taxes
There are two components of income tax expense: current and deferred. Current income tax expense reflects taxes to be paid or refunded for the current period. Deferred income tax expense results from changes in deferred tax assets and liabilities between periods. These gross deferred tax assets and liabilities represent decreases or increases in taxes expected to be paid in the future because of future reversals of temporary differences in the bases of assets and liabilities as measured by tax laws and their bases as reported in the financial statements. Deferred tax assets are also recognized for tax attributes such as net operating loss carryforwards and tax credit carryforwards. Valuation allowances are recorded to reduce deferred tax assets to the amounts management concludes are more likely than not to be realized.
Income tax benefits are recognized and measured based upon a two-step model: first, a tax position must be more likely than not to be sustained based solely on its technical merits in order to be recognized, and second, the benefit is measured as the largest dollar amount of that position that is more likely than not to be sustained upon settlement. The difference between the benefit recognized and the tax benefit claimed on a tax return is referred to as an unrecognized tax benefit. The Corporation records income tax-related interest and penalties, if applicable, within income tax expense.
Revenue Recognition
The following summarizes the Corporation’s revenue recognition accounting policies for certain noninterest income activities.
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. Interchange fees are recognized upon settlement of the credit and debit card payment transactions and are generally determined on a percentage basis for credit cards and fixed rates for debit cards based on 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
Bank of America 108


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 trade information to the appropriate clearing broker. Certain customers pay brokerage, clearing and/or exchange fees imposed by relevant regulatory bodies or exchanges in order to execute or clear trades. These fees are recorded net and are not reflected in the transaction price, as the Corporation is an agent for those services.
Investment Banking Income
Investment banking income includes underwriting income and financial advisory services income. Underwriting consists of fees earned for the placement of a customer’s debt or equity securities. The revenue is generally earned based on a percentage of the fixed number of shares or principal placed. Once the number of shares or notes is determined and the service is completed, the underwriting fees are recognized. The Corporation incurs certain out-of-pocket expenses, such as legal costs, in performing these services. These expenses are
recovered through the revenue the Corporation earns from the customer and are included in operating expenses. Syndication fees represent fees earned as the agent or lead lender responsible for structuring, arranging and administering a loan syndication.
Financial advisory services consist of fees earned for assisting clients with transactions related to mergers and acquisitions and financial restructurings. Revenue varies depending on the size of the transaction and scope of services performed and is generally contingent on successful completion of the transaction. Revenue is typically recognized once the transaction is completed and all services have been rendered. Additionally, the Corporation may earn a fixed fee in merger and acquisition transactions to provide a fairness opinion, with the fees recognized when the opinion is delivered to the client.
Other Revenue Measurement and Recognition Policies
The Corporation did not disclose the value of any open performance obligations at December 31, 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 assistance through loans fully guaranteed by the Small
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Business Administration (SBA). If the borrower meets certain criteria and uses the proceeds 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)202020192018
Net interest income
Interest income
Loans and leases$34,029 $43,086 $40,811 
Debt securities9,790 11,806 11,724 
Federal funds sold and securities borrowed or purchased under agreements to resell903 4,843 3,176 
Trading account assets4,128 5,196 4,811 
Other interest income2,735 6,305 6,247 
Total interest income51,585 71,236 66,769 
Interest expense
Deposits1,943 7,188 4,495 
Short-term borrowings987 7,208 5,839 
Trading account liabilities974 1,249 1,358 
Long-term debt4,321 6,700 6,915 
Total interest expense8,225 22,345 18,607 
Net interest income$43,360 $48,891 $48,162 
Noninterest income
Fees and commissions
Card income
Interchange fees (1)
$3,954 $3,834 $3,866 
Other card income1,702 1,963 1,958 
Total card income5,656 5,797 5,824 
Service charges
Deposit-related fees5,991 6,588 6,667 
Lending-related fees1,150 1,086 1,100 
Total service charges7,141 7,674 7,767 
Investment and brokerage services
Asset management fees10,708 10,241 10,189 
Brokerage fees3,866 3,661 3,971 
Total investment and brokerage services14,574 13,902 14,160 
Investment banking fees
Underwriting income4,698 2,998 2,722 
Syndication fees861 1,184 1,347 
Financial advisory services1,621 1,460 1,258 
Total investment banking fees7,180 5,642 5,327 
Total fees and commissions34,551 33,015 33,078 
Market making and similar activities8,355 9,034 9,008 
Other income (loss)(738)304 772 
Total noninterest income$42,168 $42,353 $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
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. Derivatives that are not designated in qualifying hedge accounting relationships are referred to as other risk management derivatives. For more information on the
Corporation’s derivatives and hedging activities, see Note 1 – Summary of Significant Accounting Principles. The following tables present derivative instruments included on the Consolidated Balance Sheet in derivative assets and liabilities at December 31, 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.
December 31, 2020
Gross Derivative AssetsGross Derivative Liabilities
(Dollars in billions)
Contract/
Notional (1)
Trading and Other Risk Management DerivativesQualifying
Accounting
Hedges
TotalTrading and Other Risk Management DerivativesQualifying
Accounting
Hedges
Total
Interest rate contracts       
Swaps$13,242.8 $199.9 $10.9 $210.8 $209.3 $1.3 $210.6 
Futures and forwards3,222.2 3.5 0.1 3.6 3.6 0 3.6 
Written options1,530.5 0 0 0 40.5 0 40.5 
Purchased options1,545.8 45.3 0 45.3 0 0 0 
Foreign exchange contracts 
Swaps1,475.8 37.1 0.3 37.4 39.7 0.6 40.3 
Spot, futures and forwards3,710.7 53.4 0 53.4 54.5 0.5 55.0 
Written options289.6 0 0 0 4.8 0 4.8 
Purchased options279.3 5.0 0 5.0 0 0 0 
Equity contracts 
Swaps320.2 13.3 0 13.3 14.5 0 14.5 
Futures and forwards106.2 0.3 0 0.3 1.4 0 1.4 
Written options599.1 0 0 0 48.8 0 48.8 
Purchased options541.2 52.6 0 52.6 0 0 0 
Commodity contracts  
Swaps36.4 1.9 0 1.9 4.4 0 4.4 
Futures and forwards63.6 2.0 0 2.0 1.0 0 1.0 
Written options24.6 0 0 0 1.4 0 1.4 
Purchased options24.7 1.5 0 1.5 0 0 0 
Credit derivatives (2)
   
Purchased credit derivatives:   
Credit default swaps322.7 2.3 0 2.3 4.4 0 4.4 
Total return swaps/options63.6 0.2 0 0.2 1.0 0 1.0 
Written credit derivatives:  
Credit default swaps301.5 4.4 0 4.4 1.9 0 1.9 
Total return swaps/options68.6 0.6 0 0.6 0.4 0 0.4 
Gross derivative assets/liabilities$423.3 $11.3 $434.6 $431.6 $2.4 $434.0 
Less: Legally enforceable master netting agreements  (344.9)  (344.9)
Less: Cash collateral received/paid   (42.5)  (43.6)
Total derivative assets/liabilities   $47.2   $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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December 31, 2019
Gross Derivative AssetsGross Derivative Liabilities
(Dollars in billions)
Contract/
Notional (1)
Trading and Other Risk Management DerivativesQualifying
Accounting
Hedges
TotalTrading and Other Risk Management DerivativesQualifying
Accounting
Hedges
Total
Interest rate contracts       
Swaps$15,074.4 $162.0 $9.7 $171.7 $168.5 $0.4 $168.9 
Futures and forwards3,279.8 1.0 1.0 1.0 1.0 
Written options1,767.7 32.5 32.5 
Purchased options1,673.6 37.4 37.4 
Foreign exchange contracts      
Swaps1,657.7 30.3 0.7 31.0 31.7 0.9 32.6 
Spot, futures and forwards3,792.7 35.9 0.1 36.0 38.7 0.3 39.0 
Written options274.3 3.8 3.8 
Purchased options261.6 4.0 4.0 
Equity contracts       
Swaps315.0 6.5 6.5 8.1 8.1 
Futures and forwards125.1 0.3 0.3 1.1 1.1 
Written options731.1 34.6 34.6 
Purchased options668.6 42.4 42.4 
Commodity contracts       
Swaps42.0 2.1 2.1 4.4 4.4 
Futures and forwards61.3 1.7 1.7 0.4 0.4 
Written options33.2 1.4 1.4 
Purchased options37.9 1.4 1.4 
Credit derivatives (2)
       
Purchased credit derivatives:       
Credit default swaps321.6 2.7 2.7 5.6 5.6 
Total return swaps/options86.6 0.4 0.4 1.3 1.3 
Written credit derivatives:      
Credit default swaps300.2 5.4 5.4 2.0 2.0 
Total return swaps/options86.2 0.8 0.8 0.4 0.4 
Gross derivative assets/liabilities $334.3 $10.5 $344.8 $335.5 $1.6 $337.1 
Less: Legally enforceable master netting agreements   (270.4)  (270.4)
Less: Cash collateral received/paid   (33.9)  (28.5)
Total derivative assets/liabilities   $40.5   $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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Offsetting of Derivatives (1)
Derivative
Assets
Derivative LiabilitiesDerivative
Assets
Derivative Liabilities
(Dollars in billions)December 31, 2020December 31, 2019
Interest rate contracts    
Over-the-counter$247.7 $243.5 $203.1 $196.6 
Exchange-traded0 0 0.1 0.1 
Over-the-counter cleared10.2 9.1 6.0 5.3 
Foreign exchange contracts
Over-the-counter92.2 96.5 69.2 73.1 
Over-the-counter cleared1.4 1.3 0.5 0.5 
Equity contracts
Over-the-counter31.3 28.3 21.3 17.8 
Exchange-traded32.3 31.0 26.4 22.8 
Commodity contracts
Over-the-counter3.5 5.0 2.8 4.2 
Exchange-traded0.7 0.7 0.8 0.8 
Over-the-counter cleared0 0 0.1 
Credit derivatives
Over-the-counter5.2 5.6 6.4 6.6 
Over-the-counter cleared2.2 1.9 2.5 2.2 
Total gross derivative assets/liabilities, before netting
Over-the-counter379.9 378.9 302.8 298.3 
Exchange-traded33.0 31.7 27.3 23.7 
Over-the-counter cleared13.8 12.3 9.0 8.1 
Less: Legally enforceable master netting agreements and cash collateral received/paid
Over-the-counter(345.7)(347.2)(274.7)(269.3)
Exchange-traded(29.5)(29.5)(21.5)(21.5)
Over-the-counter cleared(12.2)(11.8)(8.1)(8.1)
Derivative assets/liabilities, after netting39.3 34.4 34.8 31.2 
Other gross derivative assets/liabilities (2)
7.9 11.1 5.7 7.0 
Total derivative assets/liabilities47.2 45.5 40.5 38.2 
Less: Financial instruments collateral (3)
(16.1)(16.6)(14.6)(16.1)
Total net derivative assets/liabilities$31.1 $28.9 $25.9 $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.
TheCorporation 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,
113 Bank of America


and other forecasted transactions (cash flow hedges). The Corporation hedges its net investment in consolidated non-U.S. operations determined to have functional currencies other than
the U.S. dollar using forward exchange contracts and cross-currency basis swaps, and by issuing foreign currency-denominated debt (net investment hedges).
Fair Value Hedges
The following table summarizes information related to fair value hedges for 2020, 2019 and 2018.
Gains and Losses on Derivatives Designated as Fair Value Hedges
DerivativeHedged Item
(Dollars in millions)202020192018202020192018
Interest rate risk on long-term debt (1)
$7,091 $6,113 $(1,538)$(7,220)$(6,110)$1,429 
Interest rate and foreign currency risk on long-term debt (2)
783 119 (1,187)(783)(101)1,079 
Interest rate risk on available-for-sale securities (3)
(44)(102)(52)49 98 50 
Total$7,830 $6,130 $(2,777)$(7,954)$(6,113)$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)
Carrying Value
Cumulative
Fair Value Adjustments (1)
Carrying Value
Cumulative
Fair Value Adjustments (1)
(Dollars in millions)December 31, 2020December 31, 2019
Long-term debt (2)
$(150,556)$(8,910)$(162,389)$(8,685)
Available-for-sale debt securities (2, 3, 4)
116,252 114 1,654 64 
Trading account assets (5)
427 15 
(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
Gains (Losses) Recognized in
Accumulated OCI on Derivatives
Gains (Losses) in Income
Reclassified from Accumulated OCI
(Dollars in millions, amounts pretax)202020192018202020192018
Cash flow hedges
Interest rate risk on variable-rate assets (1)
$763 $671 $(159)$(7)$(104)$(165)
Price risk on forecasted MBS purchases (1)
241 
Price risk on certain compensation plans (2)
85 34 12 (2)27 
Total$1,089 $705 $(155)$14 $(106)$(138)
Net investment hedges
Foreign exchange risk (3)
$(834)$22 $989 $4 $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.
Bank of America 114


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)202020192018
Interest rate risk on mortgage activities (1, 2)
$446 $315 $(107)
Credit risk on loans (2)
(68)(58)
Interest rate and foreign currency risk on ALM activities (3)
(2,971)1,112 3,278 
Price risk on certain compensation plans (4)
700 943 (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 segments,basis as part of the Corporation’s Global Markets business segment. The related sales and trading revenue generated within Global Markets is recorded in various income statement line items, including market making and similar activities and net interest income as well as other revenue categories.
Sales and trading revenue includes changes in the fair value and realized gains and losses on the sales of trading and other assets, net interest income, and fees primarily from commissions on equity securities. Revenue is generated by the difference in the client price for an instrument and the price at which the trading desk can execute the trade in the dealer market. For equity securities, commissions related to purchases and sales are recorded in the “Other” column in the Sales and Trading Revenue table. Changes in the fair value of these securities are included in market making and similar activities. For debt securities, revenue, with the exception of interest associated with the debt securities, is typically included in
market making and similar activities. Unlike commissions for equity securities, the initial revenue related to broker-dealer services for debt securities is typically included in the pricing of the instrument rather than being charged through separate fee arrangements. Therefore, this revenue is recorded in market making and similar activities as part of the initial mark to fair value. For derivatives, the majority of revenue is included in market making and similar activities. In transactions where the Corporation acts as agent, which include exchange-traded futures and options, fees are recorded in other income.
The following table, which includes both derivatives and non-derivative cash instruments, identifies the amounts in the respective income statement line items attributable to the Corporation’s sales and trading revenue in Global Markets, categorized by primary risk, for 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 activitiesNet Interest
Income
Other (1)
Total
(Dollars in millions)2020
Interest rate risk$2,211 $2,400 $231 $4,842 
Foreign exchange risk1,482 (20)3 1,465 
Equity risk3,656 (77)1,801 5,380 
Credit risk812 1,638 328 2,778 
Other risk308 4 44 356 
Total sales and trading revenue$8,469 $3,945 $2,407 $14,821 
2019
Interest rate risk$1,000 $1,817 $113 $2,930 
Foreign exchange risk1,288 62 57 1,407 
Equity risk3,563 (634)1,569 4,498 
Credit risk1,091 1,807 519 3,417 
Other risk120 70 53 243 
Total sales and trading revenue$7,062 $3,122 $2,311 $12,495 
2018
Interest rate risk$810 $1,651 $245 $2,706 
Foreign exchange risk1,504 31 22 1,557 
Equity risk3,870 (657)1,643 4,856 
Credit risk1,034 1,886 600 3,520 
Other risk40 197 49 286 
Total sales and trading 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.
Credit Derivatives
The Corporation enters into credit derivatives primarily to facilitate client transactions and to manage credit risk exposures. Credit derivatives derive value based on an underlying third-party referenced obligation or a portfolio of referenced obligations and generally require the Corporation, as the seller of credit protection, to make payments to a buyer upon the occurrence of a predefined credit event. Such credit events generally include bankruptcy of the referenced credit entity and failure to pay under the obligation, as well as acceleration of indebtedness and payment repudiation or
115 Bank of America


moratorium. For credit derivatives based on a portfolio of referenced credits or credit indices, the Corporation may not be required to make payment until a specified amount of loss has occurred and/or may only be required to make payment up to a specified amount.
Credit derivatives are classified as investment and non-investment grade based on the credit quality of the underlying referenced obligation. The Corporation considers ratings of BBB-
or higher as investment grade. Non-investment grade includes non-rated credit derivative instruments. The Corporation discloses internal categorizations of investment grade and non-investment grade consistent with how risk is managed for these instruments.
Credit derivative instruments where the Corporation is the seller of credit protection and their expiration at December 31, 2020 and 2019 are summarized in the following table.
Credit Derivative Instruments
Less than
One Year
One to
Three Years
Three to
Five Years
Over Five
Years
Total
December 31, 2020
(Dollars in millions)Carrying Value
Credit default swaps:     
Investment grade$0 $1 $35 $94 $130 
Non-investment grade26 233 364 1,163 1,786 
Total26 234 399 1,257 1,916 
Total return swaps/options:     
Investment grade21 4 0 0 25 
Non-investment grade345 0 0 0 345 
Total366 4 0 0 370 
Total credit derivatives$392 $238 $399 $1,257 $2,286 
Credit-related notes:     
Investment grade$0 $0 $0 $572 $572 
Non-investment grade64 2 10 947 1,023 
Total credit-related notes$64 $2 $10 $1,519 $1,595 
 Maximum Payout/Notional
Credit default swaps:     
Investment grade$33,474 $75,731 $87,218 $16,822 $213,245 
Non-investment grade13,664 28,770 35,978 9,852 88,264 
Total47,138 104,501 123,196 26,674 301,509 
Total return swaps/options:     
Investment grade30,961 1,061 77 0 32,099 
Non-investment grade36,128 364 27 5 36,524 
Total67,089 1,425 104 5 68,623 
Total credit derivatives$114,227 $105,926 $123,300 $26,679 $370,132 
December 31, 2019
Carrying Value
Credit default swaps:
Investment grade$$$60 $164 $229 
Non-investment grade70 292 561 808 1,731 
Total70 297 621 972 1,960 
Total return swaps/options:     
Investment grade35 35 
Non-investment grade344 344 
Total379 379 
Total credit derivatives$449 $297 $621 $972 $2,339 
Credit-related notes:     
Investment grade$$$$639 $643 
Non-investment grade1,125 1,134 
Total credit-related notes$$$$1,764 $1,777 
 Maximum Payout/Notional
Credit default swaps:
Investment grade$55,827 $67,838 $71,320 $17,708 $212,693 
Non-investment grade19,049 26,521 29,618 12,337 87,525 
Total74,876 94,359 100,938 30,045 300,218 
Total return swaps/options:     
Investment grade56,488 62 76 56,626 
Non-investment grade28,707 657 104 60 29,528 
Total85,195 657 166 136 86,154 
Total credit derivatives$160,071 $95,016 $101,104 $30,181 $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.
Bank of America 116


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 112, 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)One
incremental notch
Second
incremental notch
Bank of America Corporation$300 $735 
Bank of America, N.A. and subsidiaries (1)
61 570 
(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)One
incremental notch
Second
incremental notch
Derivative liabilities$45 $1,035 
Collateral posted23 544 
Valuation Adjustments on Derivatives
TheCorporation records credit risk valuation adjustments on derivatives in order to properly reflect the credit quality of the counterparties and its own credit quality. The Corporation calculates valuation adjustments on derivatives based on a modeled expected exposure that incorporates current market risk factors. The exposure also takes into consideration credit mitigants such as enforceable master netting agreements and collateral. CDS spread data is used to estimate the default probabilities and severities that are applied to the exposures. Where no observable credit default data is available for counterparties, the Corporation uses proxies and other market data to estimate default probabilities and severity.
The table below presents credit valuation adjustment (CVA), DVA and FVA gains (losses) on derivatives (excluding the effect of any related hedge activities), which are recorded in market making and similar activities, for 2020, 2019 and 2018. CVA gains reduce the cumulative CVA thereby increasing the derivative assets balance. DVA gains increase the cumulative DVA thereby decreasing the derivative liabilities balance. CVA and DVA losses have the opposite impact. FVA gains related to derivative assets reduce the cumulative FVA thereby increasing the derivative assets balance. FVA gains related to derivative liabilities increase the cumulative FVA thereby decreasing the derivative liabilities balance. FVA losses have the opposite impact.
Valuation Adjustments Gains (Losses) on Derivatives (1)
(Dollars in millions)202020192018
Derivative assets (CVA)$(118)$72 $77 
Derivative assets/liabilities (FVA)(24)(2)(15)
Derivative liabilities (DVA)24 (147)(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.
117 Bank of America


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
Amortized
Cost
Gross
Unrealized
Gains
Gross
Unrealized
Losses
Fair
Value
(Dollars in millions)December 31, 2020
Available-for-sale debt securities
Mortgage-backed securities:
Agency$59,518 $2,370 $(39)$61,849 
Agency-collateralized mortgage obligations5,112 161 (13)5,260 
Commercial15,470 1,025 (4)16,491 
Non-agency residential (1)
899 127 (17)1,009 
Total mortgage-backed securities80,999 3,683 (73)84,609 
U.S. Treasury and agency securities114,157 2,236 (13)116,380 
Non-U.S. securities14,009 15 (7)14,017 
Other taxable securities, substantially all asset-backed securities2,656 61 (6)2,711 
Total taxable securities211,821 5,995 (99)217,717 
Tax-exempt securities16,417 389 (32)16,774 
Total available-for-sale debt securities (3)
228,238 6,384 (131)234,491 
Other debt securities carried at fair value (2)
11,720 429 (39)12,110 
Total debt securities carried at fair value239,958 6,813 (170)246,601 
Held-to-maturity debt securities, substantially all U.S. agency mortgage-backed securities (3)
438,279 10,095 (194)448,180 
Total debt securities (3,4)
$678,237 $16,908 $(364)$694,781 
December 31, 2019
Available-for-sale debt securities
Mortgage-backed securities:
Agency$121,698 $1,013 $(183)$122,528 
Agency-collateralized mortgage obligations4,587 78 (24)4,641 
Commercial14,797 249 (25)15,021 
Non-agency residential (1)
948 138 (9)1,077 
Total mortgage-backed securities142,030 1,478 (241)143,267 
U.S. Treasury and agency securities67,700 1,023 (195)68,528 
Non-U.S. securities11,987 (2)11,991 
Other taxable securities, substantially all asset-backed securities3,874 67 3,941 
Total taxable securities225,591 2,574 (438)227,727 
Tax-exempt securities17,716 202 (6)17,912 
Total available-for-sale debt securities243,307 2,776 (444)245,639 
Other debt securities carried at fair value (2)
10,596 255 (23)10,828 
Total debt securities carried at fair value253,903 3,031 (467)256,467 
Held-to-maturity debt securities, substantially all U.S. agency mortgage-backed securities215,730 4,433 (342)219,821 
Total debt securities (3, 4)
$469,633 $7,464 $(809)$476,288 
(1)At December 31, 2020 and 2019, the underlying collateral type included approximately 37 percent and 49 percent prime, 2 percent and 6 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.
(3)Includes securities pledged as collateral of $65.5 billion and $67.0 billion at December 31, 2020 and 2019.
(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. WithinAt December 31, 2020, the Consumer Real Estate portfolio segment,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 primaryremaining $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 quality indicators are refreshed LTVloss assumption.
At December 31, 2020 and refreshed FICO score. Refreshed LTV measures2019, 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 loan asCorporation also held money market investments at a percentage of thefair 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$1.6 billion 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,$1.0 billion, which are asset quality categories defined by regulatory authorities. These assets have an elevated level of riskincluded in time deposits placed 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.short-term investments.


Bank of America 2017128118



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)202020192018
Gross gains$423 $336 $169 
Gross losses(12)(119)(15)
Net gains on sales of AFS debt securities$411 $217 $154 
Income tax expense attributable to realized net gains on sales of AFS debt securities$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
Less than Twelve MonthsTwelve Months or LongerTotal
Fair
Value
Gross Unrealized LossesFair
Value
Gross Unrealized LossesFair
Value
Gross Unrealized Losses
(Dollars in millions)December 31, 2020
Continuously unrealized loss-positioned AFS debt securities
Mortgage-backed securities:   
Agency$2,841 $(39)$2 $0 $2,843 $(39)
Agency-collateralized mortgage obligations187 (2)364 (11)551 (13)
Commercial566 (4)9 0 575 (4)
Non-agency residential342 (9)56 (8)398 (17)
Total mortgage-backed securities3,936 (54)431 (19)4,367 (73)
U.S. Treasury and agency securities8,282 (9)498 (4)8,780 (13)
Non-U.S. securities1,861 (6)135 (1)1,996 (7)
Other taxable securities, substantially all asset-backed securities576 (2)396 (4)972 (6)
Total taxable securities14,655 (71)1,460 (28)16,115 (99)
Tax-exempt securities4,108 (29)617 (3)4,725 (32)
Total AFS debt securities in a continuous
unrealized loss position
$18,763 $(100)$2,077 $(31)$20,840 $(131)
December 31, 2019
Continuously unrealized loss-positioned AFS debt securities
Mortgage-backed securities:
Agency$17,641 $(41)$17,238 $(142)$34,879 $(183)
Agency-collateralized mortgage obligations255 (1)925 (23)1,180 (24)
Commercial2,180 (22)442 (3)2,622 (25)
Non-agency residential122 (6)22 (3)144 (9)
Total mortgage-backed securities20,198 (70)18,627 (171)38,825 (241)
U.S. Treasury and agency securities12,836 (71)18,866 (124)31,702 (195)
Non-U.S. securities851 837 (2)1,688 (2)
Other taxable securities, substantially all asset-backed securities938 222 1,160 
Total taxable securities34,823 (141)38,552 (297)73,375 (438)
Tax-exempt securities4,286 (5)190 (1)4,476 (6)
Total AFS debt securities in a continuous
unrealized loss position
$39,109 $(146)$38,742 $(298)$77,851 $(444)

119 Bank of America


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
Due in One
Year or Less
Due after One Year
through Five Years
Due after Five Years
through Ten Years
Due after
Ten Years
Total
(Dollars in millions)Amount
Yield (1)
Amount
Yield (1)
Amount
Yield (1)
Amount
Yield (1)
Amount
Yield (1)
Amortized cost of debt securities carried at fair value          
Mortgage-backed securities:          
Agency$%$5.69 %$56 4.44 %$59,455 3.36 %$59,518 3.36 %
Agency-collateralized mortgage obligations24 2.57 5,088 2.94 5,112 2.94 
Commercial26 3.04 6,669 2.52 7,711 2.32 1,077 2.64 15,483 2.43 
Non-agency residential1,620 6.77 1,621 6.77 
Total mortgage-backed securities26 3.04 6,676 2.52 7,792 2.34 67,240 3.40 81,734 3.23 
U.S. Treasury and agency securities10,020 1.26 29,533 1.85 74,665 0.74 32 2.55 114,250 1.07 
Non-U.S. securities22,862 0.31 926 1.81 581 1.09 532 1.79 24,901 0.42 
Other taxable securities, substantially all asset-backed securities699 1.15 1,336 2.46 366 2.26 255 1.60 2,656 2.00 
Total taxable securities33,607 0.61 38,471 1.99 83,404 0.89 68,059 3.38 223,541 1.80 
Tax-exempt securities872 0.87 8,430 1.27 4,397 1.66 2,718 1.41 16,417 1.38 
Total amortized cost of debt securities carried at fair value$34,479 0.62 $46,901 1.86 $87,801 0.93 $70,777 3.30 $239,958 1.77 
Amortized cost of HTM debt securities (2)
$15 3.78 $66 2.73 $17,133 1.86 $421,065 2.40 $438,279 2.38 
Debt securities carried at fair value          
Mortgage-backed securities:          
Agency$ $ $61  $61,781  $61,849  
Agency-collateralized mortgage obligations  24  5,236  5,260  
Commercial26  7,077  8,242  1,160  16,505  
Non-agency residential   1,776  1,783  
Total mortgage-backed securities26 7,084 8,334 69,953 85,397 
U.S. Treasury and agency securities10,056 30,873 75,511 33 116,473 
Non-U.S. securities23,187  940  582  534  25,243  
Other taxable securities, substantially all asset-backed securities702  1,369  379  264  2,714  
Total taxable securities33,971  40,266  84,806  70,784  229,827  
Tax-exempt securities874  8,554  4,566  2,780  16,774  
Total debt securities carried at fair value$34,845  $48,820  $89,372  $73,564  $246,601  
Fair value of HTM debt securities (2)
$14 $69 $17,139 $430,958 $448,180 
(1)The weighted-average yield is computed based on a constant effective interest rate over the contractual life of each security. The average yield considers the contractual coupon and the amortization of premiums and accretion of discounts, excluding the effect of related hedging derivatives.
(2)Substantially all U.S. agency MBS.
Bank of America 120


NOTE 5Outstanding Loans and Leases and Allowance for Credit Losses
The following tables present certain credit quality indicatorstotal outstanding loans and leases and an aging analysis for the Corporation’s Consumer Real Estate, Credit Card and Other Consumer, and Commercial portfolio segments, by class of financing receivables, at December 31, 20172020 and 2016.2019.
30-59 Days Past Due (1)
60-89 Days Past Due (1)
90 Days or
More
Past Due (1)
Total Past
Due 30 Days
or More
Total Current or Less Than 30 Days Past Due (1)
Loans Accounted for Under the Fair Value OptionTotal
Outstandings
(Dollars in millions)December 31, 2020
Consumer real estate      
Core portfolio
Residential mortgage$1,157 $175 $786 $2,118 $213,155 $215,273 
Home equity126 61 269 456 29,872 30,328 
Non-core portfolio
Residential mortgage273 122 913 1,308 6,974 8,282 
Home equity28 17 76 121 3,862 3,983 
Credit card and other consumer
Credit card445 341 903 1,689 77,019 78,708 
Direct/Indirect consumer (2)
209 67 37 313 91,050 91,363 
Other consumer0 0 0 0 124 124 
Total consumer2,238 783 2,984 6,005 422,056 428,061 
Consumer loans accounted for under the fair value option (3)
     $735 735 
Total consumer loans and leases2,238 783 2,984 6,005 422,056 735 428,796 
Commercial
U.S. commercial561 214 512 1,287 287,441 288,728 
Non-U.S. commercial61 44 11 116 90,344 90,460 
Commercial real estate (4)
128 113 226 467 59,897 60,364 
Commercial lease financing86 20 57 163 16,935 17,098 
U.S. small business commercial (5)
84 56 123 263 36,206 36,469 
Total commercial920 447 929 2,296 490,823 493,119 
Commercial loans accounted for under the fair value option (3)
     5,946 5,946 
Total commercial loans and leases920 447 929 2,296 490,823 5,946 499,065 
Total loans and leases (6)
$3,158 $1,230 $3,913 $8,301 $912,879 $6,681 $927,861 
Percentage of outstandings0.34 %0.13 %0.42 %0.89 %98.39 %0.72 %100.00 %
            
Consumer Real Estate – Credit Quality Indicators (1)
            
 
Core Residential
Mortgage (2)
 
Non-core Residential
Mortgage
(2)
 
Residential Mortgage PCI (3)
 
Core Home Equity (2)
 
Non-core Home Equity (2)
 
Home
Equity PCI
(Dollars in millions)December 31, 2017
Refreshed LTV (4)
 
  
  
  
    
Less than or equal to 90 percent$153,669
 $12,135
 $6,872
 $43,048
 $7,944
 $1,781
Greater than 90 percent but less than or equal to 100 percent3,082
 850
 559
 549
 1,053
 412
Greater than 100 percent1,322
 1,011
 570
 648
 1,786
 523
Fully-insured loans (5)
18,545
 5,196
 
 
 
 
Total consumer real estate$176,618
 $19,192
 $8,001
 $44,245
 $10,783
 $2,716
Refreshed FICO score           
Less than 620$2,234
 $2,390
 $1,941
 $1,169
 $2,098
 $452
Greater than or equal to 620 and less than 6804,531
 2,086
 1,657
 2,371
 2,393
 466
Greater than or equal to 680 and less than 74022,934
 3,519
 2,396
 8,115
 2,723
 786
Greater than or equal to 740128,374
 6,001
 2,007
 32,590
 3,569
 1,012
Fully-insured loans (5)
18,545
 5,196
 
 
 
 
Total consumer real estate$176,618
 $19,192
 $8,001
 $44,245
 $10,783
 $2,716
(1)
Excludes $928 million of loans accounted for under the fair value option.
(2)
Excludes PCI loans.
(3)
Includes $1.2 billion of pay option loans. The Corporation no longer originates this product.
(4)
Refreshed LTV percentages for PCI loans are calculated using the carrying value net of the related valuation allowance.
(5)
Credit quality indicators are not reported for fully-insured loans as principal repayment is insured.
(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.
      
Credit Card and Other Consumer – Credit Quality Indicators
      
 
U.S. Credit
Card
 
Direct/Indirect
Consumer
 
Other
Consumer
(Dollars in millions)December 31, 2017
Refreshed FICO score 
  
  
Less than 620$4,730
 $1,630
 $49
Greater than or equal to 620 and less than 68012,422
 2,000
 143
Greater than or equal to 680 and less than 74035,656
 11,906
 398
Greater than or equal to 74043,477
 34,838
 1,921
Other internal credit metrics (1, 2)

 43,456
 167
Total credit card and other consumer$96,285
 $93,830
 $2,678
(1)
Other internal credit metrics may include delinquency status, geography or other factors.
(2)
Direct/indirect consumer includes $42.8 billion of securities-based(2)Total outstandings primarily includes auto and specialty lending which is overcollateralized and therefore has minimal credit risk.
          
Commercial – Credit Quality Indicators (1)
    
          
 
U.S.
Commercial
 
Non-U.S.
Commercial
 
Commercial
Real Estate
 
Commercial
Lease
Financing
 
U.S. Small
Business
Commercial (2)
(Dollars in millions)December 31, 2017
Risk ratings 
  
  
  
  
Pass rated$275,904
 $96,199
 $57,732
 $21,535
 $322
Reservable criticized8,932
 1,593
 566
 581
 50
Refreshed FICO score (3)
         
Less than 620 
       223
Greater than or equal to 620 and less than 680        625
Greater than or equal to 680 and less than 740        1,875
Greater than or equal to 740        3,713
Other internal credit metrics (3, 4)
        6,841
Total commercial$284,836
 $97,792
 $58,298
 $22,116
 $13,649
(1)
Excludes $4.8 billion of loans accounted for under the fair value option.
(2)
U.S. small business commercial includes $709 million of criticized business card and small business loans which are evaluated using refreshed FICO scores or internal credit metrics, including delinquency status, rather than risk ratings. At December 31, 2017, 98 percent of the balances where internal credit metrics are used was current or less than 30 days past due.
(3)
Refreshed FICO score and other internal credit metrics are applicable only to the U.S. small business commercial portfolio.
(4)
Other internal credit metrics may include delinquency status, application scores, geography or other factors.

129Bank of America 2017



            
Consumer Real Estate – Credit Quality Indicators (1)
            
 
Core Residential
Mortgage (2)
 
Non-core Residential
Mortgage
(2)
 
Residential Mortgage PCI (3)
 
Core Home Equity (2)
 
Non-core Home Equity (2)
 
Home
Equity PCI
(Dollars in millions)December 31, 2016
Refreshed LTV (4)
 
  
  
  
    
Less than or equal to 90 percent$129,737
 $14,280
 $7,811
 $47,171
 $8,480
 $1,942
Greater than 90 percent but less than or equal to 100 percent3,634
 1,446
 1,021
 1,006
 1,668
 630
Greater than 100 percent1,872
 1,972
 1,295
 1,196
 3,311
 1,039
Fully-insured loans (5)
21,254
 7,475
 
 
 
 
Total consumer real estate$156,497
 $25,173
 $10,127
 $49,373
 $13,459
 $3,611
Refreshed FICO score 
  
  
  
  
  
Less than 620$2,479
 $3,198
 $2,741
 $1,254
 $2,692
 $559
Greater than or equal to 620 and less than 6805,094
 2,807
 2,241
 2,853
 3,094
 636
Greater than or equal to 680 and less than 74022,629
 4,512
 2,916
 10,069
 3,176
 1,069
Greater than or equal to 740105,041
 7,181
 2,229
 35,197
 4,497
 1,347
Fully-insured loans (5)
21,254
 7,475
 
 
 
 
Total consumer real estate$156,497
 $25,173
 $10,127
 $49,373
 $13,459
 $3,611
(1)
Excludes $1.1 billion of loans accounted for under the fair value option.
(2)
Excludes PCI loans.
(3)
Includes $1.6 billion of pay option loans. The Corporation no longer originates this product.
(4)
Refreshed LTV percentages for PCI loans are calculated using the carrying value net of the related valuation allowance.
(5)
Credit quality indicators are not reported for fully-insured loans as principal repayment is insured.
        
Credit Card and Other Consumer – Credit Quality Indicators
        
 
U.S. Credit
Card
 
Non-U.S.
Credit Card
 
Direct/Indirect
Consumer
 
Other
Consumer (1)
(Dollars in millions)December 31, 2016
Refreshed FICO score 
  
  
  
Less than 620$4,431
 $
 $1,478
 $187
Greater than or equal to 620 and less than 68012,364
 
 2,070
 222
Greater than or equal to 680 and less than 74034,828
 
 12,491
 404
Greater than or equal to 74040,655
 
 33,420
 1,525
Other internal credit metrics (2, 3, 4)

 9,214
 44,630
 161
Total credit card and other consumer$92,278
 $9,214
 $94,089
 $2,499
(1)
At December 31, 2016, 19 percent of the other consumer portfolio was associated with portfolios from certain consumer finance businesses that the Corporation previously exited.
(2)
Other internal credit metrics may include delinquency status, geography or other factors.
(3)
Direct/indirect consumer includes $43.1 billion of securities-based lending which is overcollateralized and therefore has minimal credit risk and $499 million of loans the Corporation no longer originates, primarily student loans.
(4)
Non-U.S. credit card represents the U.K. credit card portfolio which was evaluated using internal credit metrics, including delinquency status. At December 31, 2016, 98 percent of this portfolio was current or less than 30 days past due, one percent was 30-89 days past due and one percent was 90 days or more past due.
          
Commercial – Credit Quality Indicators (1)
    
          
 
U.S.
Commercial
 
Non-U.S.
Commercial
 
Commercial
Real Estate
 
Commercial
Lease
Financing
 
U.S. Small
Business
Commercial (2)
(Dollars in millions)December 31, 2016
Risk ratings 
  
  
  
  
Pass rated$261,214
 $85,689
 $56,957
 $21,565
 $453
Reservable criticized9,158
 3,708
 398
 810
 71
Refreshed FICO score (3)
         
Less than 620        200
Greater than or equal to 620 and less than 680        591
Greater than or equal to 680 and less than 740        1,741
Greater than or equal to 740        3,264
Other internal credit metrics (3, 4)
        6,673
Total commercial$270,372
 $89,397
 $57,355
 $22,375
 $12,993
(1)
Excludes $6.0 billion of loans accounted for under the fair value option.
(2)
U.S. small business commercial includes $755 million of criticized business card and small business loans which are evaluated using refreshed FICO scores or internal credit metrics, including delinquency status, rather than risk ratings. At December 31, 2016, 98 percent of the balances where internal credit metrics are used was current or less than 30 days past due.
(3)
Refreshed FICO score and other internal credit metrics are applicable only to the U.S. small business commercial portfolio.
(4)
Other internal credit metrics may include delinquency status, application scores, geography or other factors.

Bank of America 2017130


Impaired Loans and Troubled Debt Restructurings
A loan is considered impaired when, based on current information, it is probable that the Corporation will be unable to collect all amounts due from the borrower in accordance with the contractual terms of the loan. Impaired loans include nonperforming commercial loans and all consumerleases of $46.4 billion, U.S. securities-based lending loans of $41.1 billion and commercial TDRs. Impaired loans exclude nonperformingnon-U.S. consumer loans and nonperforming commercial leases unless they are classified as TDRs. Loansof $3.0 billion.
(3)Consumer loans accounted for under the fair value option are also excluded. PCIincludes residential mortgage loans are excludedof $298 million and reported separately on page 137.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)Includes PPP loans.
(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 potential borrowing capacity with the Federal Reserve Bank and Federal Home Loan Bank.
121 Bank of America


30-59 Days
Past Due
(1)
60-89 Days Past Due (1)
90 Days or
More
Past Due
(1)
Total Past
Due 30 Days
or More
Total
Current or
Less Than
30 Days
Past Due (1)
Loans
Accounted
for Under
the Fair
Value Option
Total Outstandings
(Dollars in millions)December 31, 2019
Consumer real estate      
Core portfolio
Residential mortgage$1,378 $261 $565 $2,204 $223,566  $225,770 
Home equity135 70 198 403 34,823  35,226 
Non-core portfolio       
Residential mortgage458 209 1,263 1,930 8,469  10,399 
Home equity34 16 72 122 4,860  4,982 
Credit card and other consumer       
Credit card564 429 1,042 2,035 95,573  97,608 
Direct/Indirect consumer (2)
297 85 35 417 90,581  90,998 
Other consumer 192  192 
Total consumer2,866 1,070 3,175 7,111 458,064 465,175 
Consumer loans accounted for under the fair value option (3)
$594 594 
Total consumer loans and leases2,866 1,070 3,175 7,111 458,064 594 465,769 
Commercial       
U.S. commercial788 279 371 1,438 305,610  307,048 
Non-U.S. commercial35 23 66 104,900  104,966 
Commercial real estate (4)
144 19 119 282 62,407  62,689 
Commercial lease financing100 56 39 195 19,685  19,880 
U.S. small business commercial119 56 107 282 15,051  15,333 
Total commercial1,186 433 644 2,263 507,653  509,916 
Commercial loans accounted for under the fair value option (3)
7,741 7,741 
Total commercial loans and leases1,186 433 644 2,263 507,653 7,741 517,657 
Total loans and leases (5)
$4,052 $1,503 $3,819 $9,374 $965,717 $8,335 $983,426 
Percentage of outstandings0.41 %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.
Nonperforming Loans and Leases
Commercial nonperforming loans increased to $2.2 billion at December 31, 2020 from $1.5 billion at December 31, 2019 with broad-based increases across multiple industries. 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 for loan modifications related to the pandemic and the criteria for classification as nonperforming, see Note 1 – Summary of Significant Accounting Principles.
Bank of America 122


Credit Quality
Nonperforming Loans
and Leases
Accruing Past Due
90 Days or More (1)
December 31
(Dollars in millions)2020201920202019
Residential mortgage (2)
$2,005 $1,470 $762 $1,088 
With no related allowance (3)
1,378 n/a0 
Home equity (2)
649 536 0 
With no related allowance (3)
347 n/a0 
Credit Cardn/an/a903 1,042 
Direct/indirect consumer71 47 33 33 
Total consumer2,725 2,053 1,698 2,163 
U.S. commercial1,243 1,094 228 106 
Non-U.S. commercial418 43 10 
Commercial real estate404 280 6 19 
Commercial lease financing87 32 25 20 
U.S. small business commercial75 50 115 97 
Total commercial2,227 1,499 384 250 
Total nonperforming loans$4,952 $3,552 $2,082 $2,413 
Percentage of outstanding loans and leases0.54 %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.
Consumer Real Estate
ImpairedTo 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 prepayments, using 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.
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 these loans 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 trends specific to the Metropolitan Statistical Area in which the property being valued is located. In the event that an AVM value is not available, the Corporation utilizes publicized indices or if these methods provide less reliable valuations, the Corporation uses appraisals or broker price opinions to estimate the fair value of the collateral. While there is inherent imprecision in these valuations, the Corporation believes that they are representative of this portfolio in the aggregate.
For loans that are more than 180 days past due and collateral-dependent TDRs, with the exception of the Corporation’s fully insured portfolio, the outstanding balance of loans that is in excess of the estimated property value after
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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 (e.g., borrowers making full payments, 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.
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 reported as reserves for unfunded lending commitments.
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
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 that 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.
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 federal 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 0. 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 commencement, lease liabilities are recognized based on the present value of the remaining lease payments and discounted using the Corporation’s incremental borrowing rate. Right-of-use assets initially equal the lease liability, adjusted for any lease payments made prior to lease commencement and for any lease incentives.
Goodwill and Intangible Assets
Goodwill is the purchase premium after adjusting for the fair value of net assets acquired. Goodwill is not amortized but is reviewed for potential impairment on an annual basis, or when events or circumstances indicate a potential impairment, at the reporting unit level. A reporting unit is a business segment or one level below a business segment.
The Corporation assesses the fair value of each reporting unit against its carrying value, including goodwill, as measured by allocated equity. For purposes of goodwill impairment testing, the Corporation utilizes allocated equity as a proxy for the carrying value of its reporting units. Allocated equity in the reporting units is comprised of allocated capital plus capital for the portion of goodwill and intangibles specifically assigned to the reporting unit.
In performing its goodwill impairment testing, the Corporation first assesses qualitative factors to determine whether it is more likely than not that the fair value of a reporting unit is less than its carrying value. Qualitative factors include, among other things, macroeconomic conditions, industry and market considerations, financial performance of the respective reporting unit and other relevant entity- and reporting-unit specific considerations.
If the Corporation concludes it is more likely than not that the fair value of a reporting unit is less than its carrying value, a quantitative assessment is performed. 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
reversals of goodwill impairment losses are not permitted under applicable accounting guidance.
For intangible assets subject to amortization, an impairment loss is recognized if the carrying value of the intangible asset is not recoverable and exceeds fair value. The carrying value of the intangible asset is considered not recoverable if it exceeds the sum of the undiscounted cash flows expected to result from the use of the asset. Intangible assets deemed to have indefinite useful lives are not subject to amortization. An impairment loss is recognized if the carrying value of the intangible asset with an indefinite life exceeds its fair value.
Variable Interest Entities
A VIE is an entity that lacks equity investors or whose equity investors do not have a controlling financial interest in the entity through their equity investments. The Corporation consolidates a VIE if it has both the power to direct the activities of the VIE that most significantly impact the VIE’s economic performance and an obligation to absorb losses or the right to receive benefits that could potentially be significant to the VIE. On a quarterly basis, the Corporation reassesses its involvement with the VIE and evaluates the impact of changes in governing documents and its financial interests in the VIE. The consolidation status of the VIEs with which the Corporation is involved may change as a result of such reassessments.
The Corporation primarily uses VIEs for its securitization activities, in which the Corporation transfers whole loans or debt securities into a trust or other vehicle. When the Corporation is the servicer of whole loans held in a securitization trust, including non-agency residential mortgages, home equity loans, credit cards, and other loans, the Corporation has the power to direct the most significant activities of the trust. The Corporation generally does not have the power to direct the most significant activities of a residential mortgage agency trust except in certain circumstances in which the Corporation holds substantially all of the issued securities and has the unilateral right to liquidate the trust. The power to direct the most significant activities of a commercial mortgage securitization trust is typically held by the special servicer or by the party holding specific subordinate securities which embody certain controlling rights. The Corporation consolidates a whole-loan securitization trust if it has the power to direct the most significant activities and also holds securities issued by the trust or has other contractual arrangements, other than standard representations and warranties, that could potentially be significant to the trust.
The Corporation may also transfer trading account securities and AFS securities into municipal bond or resecuritization trusts. The Corporation consolidates a municipal bond or resecuritization trust if it has control over the ongoing activities of the trust such as the remarketing of the trust’s liabilities or, if there are no ongoing activities, sole discretion over the design of the trust, including the identification of securities to be transferred in and the structure of securities to be issued, and also retains securities or has liquidity or other commitments that could potentially be significant to the trust. The Corporation does not consolidate a municipal bond or resecuritization trust if one or a limited number of third-party investors share responsibility for the design of the trust or have control over the significant activities of the trust through liquidation or other substantive rights.
Other VIEs used by the Corporation include collateralized debt obligations (CDOs), investment vehicles created on behalf of customers and other investment vehicles. The Corporation does not routinely serve as collateral manager for CDOs and, therefore, does not typically have the power to direct the
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activities that most significantly impact the economic performance of a CDO. However, following an event of default, if the Corporation is a majority holder of senior securities issued by a CDO and acquires the power to manage its assets, the Corporation consolidates the CDO.
The Corporation consolidates a customer or other investment vehicle if it has control over the initial design of the vehicle or manages the assets in the vehicle and also absorbs potentially significant gains or losses through an investment in the vehicle, derivative contracts or other arrangements. The Corporation does not consolidate an investment vehicle if a single investor controlled the initial design of the vehicle or manages the assets in the vehicles or if the Corporation does not have a variable interest that could potentially be significant to the vehicle.
Retained interests in securitized assets are initially recorded at fair value. In addition, the Corporation may invest in debt securities issued by unconsolidated VIEs. Fair values of these debt securities, which are classified as trading account assets, debt securities carried at fair value or HTM securities, are based primarily on quoted market prices in active or inactive markets. Generally, quoted market prices for retained residual interests are not available; therefore, the Corporation estimates fair values based on the present value of the associated expected future cash flows.
Fair Value
The Corporation measures the fair values of its assets and liabilities, where applicable, in accordance with accounting guidance that requires an entity to base fair value on exit price. Under this guidance, an entity is required to maximize the use of observable inputs and minimize the use of unobservable inputs in measuring fair value. Under applicable accounting standards, fair value measurements are categorized into one of three levels 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 1Unadjusted 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 2Observable 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 3Unobservable inputs that are supported by little or no market activity and that are significant to the overall
fair value of the assets or liabilities. Level 3 assets and liabilities include financial instruments for which the determination of fair value requires significant management judgment or estimation. The fair value for such assets and liabilities is generally determined using pricing models, discounted cash flow methodologies or similar techniques that incorporate the assumptions a market participant would use in pricing the asset or liability. This category generally includes retained residual interests in securitizations, consumer MSRs, certain ABS, highly structured, complex or long-dated derivative contracts, certain loans and LHFS, IRLCs and certain CDOs where independent pricing information cannot be obtained for a significant portion of the underlying assets.
Income Taxes
There are two components of income tax expense: current and deferred. Current income tax expense reflects taxes to be paid or refunded for the current period. Deferred income tax expense results from changes in deferred tax assets and liabilities between periods. These gross deferred tax assets and liabilities represent decreases or increases in taxes expected to be paid in the future because of future reversals of temporary differences in the bases of assets and liabilities as measured by tax laws and their bases as reported in the financial statements. Deferred tax assets are also recognized for tax attributes such as net operating loss carryforwards and tax credit carryforwards. Valuation allowances are recorded to reduce deferred tax assets to the amounts management concludes are more likely than not to be realized.
Income tax benefits are recognized and measured based upon a two-step model: first, a tax position must be more likely than not to be sustained based solely on its technical merits in order to be recognized, and second, the benefit is measured as the largest dollar amount of that position that is more likely than not to be sustained upon settlement. The difference between the benefit recognized and the tax benefit claimed on a tax return is referred to as an unrecognized tax benefit. The Corporation records income tax-related interest and penalties, if applicable, within income tax expense.
Revenue Recognition
The following summarizes the Corporation’s revenue recognition accounting policies for certain noninterest income activities.
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. Interchange fees are recognized upon settlement of the credit and debit card payment transactions and are generally determined on a percentage basis for credit cards and fixed rates for debit cards based on 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
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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 trade information to the appropriate clearing broker. Certain customers pay brokerage, clearing and/or exchange fees imposed by relevant regulatory bodies or exchanges in order to execute or clear trades. These fees are recorded net and are not reflected in the transaction price, as the Corporation is an agent for those services.
Investment Banking Income
Investment banking income includes underwriting income and financial advisory services income. Underwriting consists of fees earned for the placement of a customer’s debt or equity securities. The revenue is generally earned based on a percentage of the fixed number of shares or principal placed. Once the number of shares or notes is determined and the service is completed, the underwriting fees are recognized. The Corporation incurs certain out-of-pocket expenses, such as legal costs, in performing these services. These expenses are
recovered through the revenue the Corporation earns from the customer and are included in operating expenses. Syndication fees represent fees earned as the agent or lead lender responsible for structuring, arranging and administering a loan syndication.
Financial advisory services consist of fees earned for assisting clients with transactions related to mergers and acquisitions and financial restructurings. Revenue varies depending on the size of the transaction and scope of services performed and is generally contingent on successful completion of the transaction. Revenue is typically recognized once the transaction is completed and all services have been rendered. Additionally, the Corporation may earn a fixed fee in merger and acquisition transactions to provide a fairness opinion, with the fees recognized when the opinion is delivered to the client.
Other Revenue Measurement and Recognition Policies
The Corporation did not disclose the value of any open performance obligations at December 31, 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 assistance through loans fully guaranteed by the Small
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Business Administration (SBA). If the borrower meets certain criteria and uses the proceeds 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)202020192018
Net interest income
Interest income
Loans and leases$34,029 $43,086 $40,811 
Debt securities9,790 11,806 11,724 
Federal funds sold and securities borrowed or purchased under agreements to resell903 4,843 3,176 
Trading account assets4,128 5,196 4,811 
Other interest income2,735 6,305 6,247 
Total interest income51,585 71,236 66,769 
Interest expense
Deposits1,943 7,188 4,495 
Short-term borrowings987 7,208 5,839 
Trading account liabilities974 1,249 1,358 
Long-term debt4,321 6,700 6,915 
Total interest expense8,225 22,345 18,607 
Net interest income$43,360 $48,891 $48,162 
Noninterest income
Fees and commissions
Card income
Interchange fees (1)
$3,954 $3,834 $3,866 
Other card income1,702 1,963 1,958 
Total card income5,656 5,797 5,824 
Service charges
Deposit-related fees5,991 6,588 6,667 
Lending-related fees1,150 1,086 1,100 
Total service charges7,141 7,674 7,767 
Investment and brokerage services
Asset management fees10,708 10,241 10,189 
Brokerage fees3,866 3,661 3,971 
Total investment and brokerage services14,574 13,902 14,160 
Investment banking fees
Underwriting income4,698 2,998 2,722 
Syndication fees861 1,184 1,347 
Financial advisory services1,621 1,460 1,258 
Total investment banking fees7,180 5,642 5,327 
Total fees and commissions34,551 33,015 33,078 
Market making and similar activities8,355 9,034 9,008 
Other income (loss)(738)304 772 
Total noninterest income$42,168 $42,353 $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.
Bank of America 110


NOTE 3 Derivatives
Derivative Balances
Derivatives are entered into on behalf of customers, for trading or to support risk management activities. Derivatives used in risk management activities include derivatives that may or may not be designated in qualifying hedge accounting relationships. Derivatives that are not designated in qualifying hedge accounting relationships are referred to as other risk management derivatives. For more information on the
Corporation’s derivatives and hedging activities, see Note 1 – Summary of Significant Accounting Principles. The following tables present derivative instruments included on the Consolidated Balance Sheet in derivative assets and liabilities at December 31, 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.
December 31, 2020
Gross Derivative AssetsGross Derivative Liabilities
(Dollars in billions)
Contract/
Notional (1)
Trading and Other Risk Management DerivativesQualifying
Accounting
Hedges
TotalTrading and Other Risk Management DerivativesQualifying
Accounting
Hedges
Total
Interest rate contracts       
Swaps$13,242.8 $199.9 $10.9 $210.8 $209.3 $1.3 $210.6 
Futures and forwards3,222.2 3.5 0.1 3.6 3.6 0 3.6 
Written options1,530.5 0 0 0 40.5 0 40.5 
Purchased options1,545.8 45.3 0 45.3 0 0 0 
Foreign exchange contracts 
Swaps1,475.8 37.1 0.3 37.4 39.7 0.6 40.3 
Spot, futures and forwards3,710.7 53.4 0 53.4 54.5 0.5 55.0 
Written options289.6 0 0 0 4.8 0 4.8 
Purchased options279.3 5.0 0 5.0 0 0 0 
Equity contracts 
Swaps320.2 13.3 0 13.3 14.5 0 14.5 
Futures and forwards106.2 0.3 0 0.3 1.4 0 1.4 
Written options599.1 0 0 0 48.8 0 48.8 
Purchased options541.2 52.6 0 52.6 0 0 0 
Commodity contracts  
Swaps36.4 1.9 0 1.9 4.4 0 4.4 
Futures and forwards63.6 2.0 0 2.0 1.0 0 1.0 
Written options24.6 0 0 0 1.4 0 1.4 
Purchased options24.7 1.5 0 1.5 0 0 0 
Credit derivatives (2)
   
Purchased credit derivatives:   
Credit default swaps322.7 2.3 0 2.3 4.4 0 4.4 
Total return swaps/options63.6 0.2 0 0.2 1.0 0 1.0 
Written credit derivatives:  
Credit default swaps301.5 4.4 0 4.4 1.9 0 1.9 
Total return swaps/options68.6 0.6 0 0.6 0.4 0 0.4 
Gross derivative assets/liabilities$423.3 $11.3 $434.6 $431.6 $2.4 $434.0 
Less: Legally enforceable master netting agreements  (344.9)  (344.9)
Less: Cash collateral received/paid   (42.5)  (43.6)
Total derivative assets/liabilities   $47.2   $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.
111 Bank of America


December 31, 2019
Gross Derivative AssetsGross Derivative Liabilities
(Dollars in billions)
Contract/
Notional (1)
Trading and Other Risk Management DerivativesQualifying
Accounting
Hedges
TotalTrading and Other Risk Management DerivativesQualifying
Accounting
Hedges
Total
Interest rate contracts       
Swaps$15,074.4 $162.0 $9.7 $171.7 $168.5 $0.4 $168.9 
Futures and forwards3,279.8 1.0 1.0 1.0 1.0 
Written options1,767.7 32.5 32.5 
Purchased options1,673.6 37.4 37.4 
Foreign exchange contracts      
Swaps1,657.7 30.3 0.7 31.0 31.7 0.9 32.6 
Spot, futures and forwards3,792.7 35.9 0.1 36.0 38.7 0.3 39.0 
Written options274.3 3.8 3.8 
Purchased options261.6 4.0 4.0 
Equity contracts       
Swaps315.0 6.5 6.5 8.1 8.1 
Futures and forwards125.1 0.3 0.3 1.1 1.1 
Written options731.1 34.6 34.6 
Purchased options668.6 42.4 42.4 
Commodity contracts       
Swaps42.0 2.1 2.1 4.4 4.4 
Futures and forwards61.3 1.7 1.7 0.4 0.4 
Written options33.2 1.4 1.4 
Purchased options37.9 1.4 1.4 
Credit derivatives (2)
       
Purchased credit derivatives:       
Credit default swaps321.6 2.7 2.7 5.6 5.6 
Total return swaps/options86.6 0.4 0.4 1.3 1.3 
Written credit derivatives:      
Credit default swaps300.2 5.4 5.4 2.0 2.0 
Total return swaps/options86.2 0.8 0.8 0.4 0.4 
Gross derivative assets/liabilities $334.3 $10.5 $344.8 $335.5 $1.6 $337.1 
Less: Legally enforceable master netting agreements   (270.4)  (270.4)
Less: Cash collateral received/paid   (33.9)  (28.5)
Total derivative assets/liabilities   $40.5   $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.
Bank of America 112


Offsetting of Derivatives (1)
Derivative
Assets
Derivative LiabilitiesDerivative
Assets
Derivative Liabilities
(Dollars in billions)December 31, 2020December 31, 2019
Interest rate contracts    
Over-the-counter$247.7 $243.5 $203.1 $196.6 
Exchange-traded0 0 0.1 0.1 
Over-the-counter cleared10.2 9.1 6.0 5.3 
Foreign exchange contracts
Over-the-counter92.2 96.5 69.2 73.1 
Over-the-counter cleared1.4 1.3 0.5 0.5 
Equity contracts
Over-the-counter31.3 28.3 21.3 17.8 
Exchange-traded32.3 31.0 26.4 22.8 
Commodity contracts
Over-the-counter3.5 5.0 2.8 4.2 
Exchange-traded0.7 0.7 0.8 0.8 
Over-the-counter cleared0 0 0.1 
Credit derivatives
Over-the-counter5.2 5.6 6.4 6.6 
Over-the-counter cleared2.2 1.9 2.5 2.2 
Total gross derivative assets/liabilities, before netting
Over-the-counter379.9 378.9 302.8 298.3 
Exchange-traded33.0 31.7 27.3 23.7 
Over-the-counter cleared13.8 12.3 9.0 8.1 
Less: Legally enforceable master netting agreements and cash collateral received/paid
Over-the-counter(345.7)(347.2)(274.7)(269.3)
Exchange-traded(29.5)(29.5)(21.5)(21.5)
Over-the-counter cleared(12.2)(11.8)(8.1)(8.1)
Derivative assets/liabilities, after netting39.3 34.4 34.8 31.2 
Other gross derivative assets/liabilities (2)
7.9 11.1 5.7 7.0 
Total derivative assets/liabilities47.2 45.5 40.5 38.2 
Less: Financial instruments collateral (3)
(16.1)(16.6)(14.6)(16.1)
Total net derivative assets/liabilities$31.1 $28.9 $25.9 $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.
TheCorporation 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,
113 Bank of America


and other forecasted transactions (cash flow hedges). The Corporation hedges its net investment in consolidated non-U.S. operations determined to have functional currencies other than
the U.S. dollar using forward exchange contracts and cross-currency basis swaps, and by issuing foreign currency-denominated debt (net investment hedges).
Fair Value Hedges
The following table summarizes information related to fair value hedges for 2020, 2019 and 2018.
Gains and Losses on Derivatives Designated as Fair Value Hedges
DerivativeHedged Item
(Dollars in millions)202020192018202020192018
Interest rate risk on long-term debt (1)
$7,091 $6,113 $(1,538)$(7,220)$(6,110)$1,429 
Interest rate and foreign currency risk on long-term debt (2)
783 119 (1,187)(783)(101)1,079 
Interest rate risk on available-for-sale securities (3)
(44)(102)(52)49 98 50 
Total$7,830 $6,130 $(2,777)$(7,954)$(6,113)$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)
Carrying Value
Cumulative
Fair Value Adjustments (1)
Carrying Value
Cumulative
Fair Value Adjustments (1)
(Dollars in millions)December 31, 2020December 31, 2019
Long-term debt (2)
$(150,556)$(8,910)$(162,389)$(8,685)
Available-for-sale debt securities (2, 3, 4)
116,252 114 1,654 64 
Trading account assets (5)
427 15 
(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
Gains (Losses) Recognized in
Accumulated OCI on Derivatives
Gains (Losses) in Income
Reclassified from Accumulated OCI
(Dollars in millions, amounts pretax)202020192018202020192018
Cash flow hedges
Interest rate risk on variable-rate assets (1)
$763 $671 $(159)$(7)$(104)$(165)
Price risk on forecasted MBS purchases (1)
241 
Price risk on certain compensation plans (2)
85 34 12 (2)27 
Total$1,089 $705 $(155)$14 $(106)$(138)
Net investment hedges
Foreign exchange risk (3)
$(834)$22 $989 $4 $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.
Bank of America 114


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)202020192018
Interest rate risk on mortgage activities (1, 2)
$446 $315 $(107)
Credit risk on loans (2)
(68)(58)
Interest rate and foreign currency risk on ALM activities (3)
(2,971)1,112 3,278 
Price risk on certain compensation plans (4)
700 943 (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.
Sales and trading revenue includes changes in the fair value and realized gains and losses on the sales of trading and other assets, net interest income, and fees primarily from commissions on equity securities. Revenue is generated by the difference in the client price for an instrument and the price at which the trading desk can execute the trade in the dealer market. For equity securities, commissions related to purchases and sales are recorded in the “Other” column in the Sales and Trading Revenue table. Changes in the fair value of these securities are included in market making and similar activities. For debt securities, revenue, with the exception of interest associated with the debt securities, is typically included in
market making and similar activities. Unlike commissions for equity securities, the initial revenue related to broker-dealer services for debt securities is typically included in the pricing of the instrument rather than being charged through separate fee arrangements. Therefore, this revenue is recorded in market making and similar activities as part of the initial mark to fair value. For derivatives, the majority of revenue is included in market making and similar activities. In transactions where the Corporation acts as agent, which include exchange-traded futures and options, fees are recorded in other income.
The following table, which includes both derivatives and non-derivative cash instruments, identifies the amounts in the respective income statement line items attributable to the Corporation’s sales and trading revenue in Global Markets, categorized by primary risk, for 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 activitiesNet Interest
Income
Other (1)
Total
(Dollars in millions)2020
Interest rate risk$2,211 $2,400 $231 $4,842 
Foreign exchange risk1,482 (20)3 1,465 
Equity risk3,656 (77)1,801 5,380 
Credit risk812 1,638 328 2,778 
Other risk308 4 44 356 
Total sales and trading revenue$8,469 $3,945 $2,407 $14,821 
2019
Interest rate risk$1,000 $1,817 $113 $2,930 
Foreign exchange risk1,288 62 57 1,407 
Equity risk3,563 (634)1,569 4,498 
Credit risk1,091 1,807 519 3,417 
Other risk120 70 53 243 
Total sales and trading revenue$7,062 $3,122 $2,311 $12,495 
2018
Interest rate risk$810 $1,651 $245 $2,706 
Foreign exchange risk1,504 31 22 1,557 
Equity risk3,870 (657)1,643 4,856 
Credit risk1,034 1,886 600 3,520 
Other risk40 197 49 286 
Total sales and trading 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.
Credit Derivatives
The Corporation enters into credit derivatives primarily to facilitate client transactions and to manage credit risk exposures. Credit derivatives derive value based on an underlying third-party referenced obligation or a portfolio of referenced obligations and generally require the Corporation, as the seller of credit protection, to make payments to a buyer upon the occurrence of a predefined credit event. Such credit events generally include bankruptcy of the referenced credit entity and failure to pay under the obligation, as well as acceleration of indebtedness and payment repudiation or
115 Bank of America


moratorium. For credit derivatives based on a portfolio of referenced credits or credit indices, the Corporation may not be required to make payment until a specified amount of loss has occurred and/or may only be required to make payment up to a specified amount.
Credit derivatives are classified as investment and non-investment grade based on the credit quality of the underlying referenced obligation. The Corporation considers ratings of BBB-
or higher as investment grade. Non-investment grade includes non-rated credit derivative instruments. The Corporation discloses internal categorizations of investment grade and non-investment grade consistent with how risk is managed for these instruments.
Credit derivative instruments where the Corporation is the seller of credit protection and their expiration at December 31, 2020 and 2019 are summarized in the following table.
Credit Derivative Instruments
Less than
One Year
One to
Three Years
Three to
Five Years
Over Five
Years
Total
December 31, 2020
(Dollars in millions)Carrying Value
Credit default swaps:     
Investment grade$0 $1 $35 $94 $130 
Non-investment grade26 233 364 1,163 1,786 
Total26 234 399 1,257 1,916 
Total return swaps/options:     
Investment grade21 4 0 0 25 
Non-investment grade345 0 0 0 345 
Total366 4 0 0 370 
Total credit derivatives$392 $238 $399 $1,257 $2,286 
Credit-related notes:     
Investment grade$0 $0 $0 $572 $572 
Non-investment grade64 2 10 947 1,023 
Total credit-related notes$64 $2 $10 $1,519 $1,595 
 Maximum Payout/Notional
Credit default swaps:     
Investment grade$33,474 $75,731 $87,218 $16,822 $213,245 
Non-investment grade13,664 28,770 35,978 9,852 88,264 
Total47,138 104,501 123,196 26,674 301,509 
Total return swaps/options:     
Investment grade30,961 1,061 77 0 32,099 
Non-investment grade36,128 364 27 5 36,524 
Total67,089 1,425 104 5 68,623 
Total credit derivatives$114,227 $105,926 $123,300 $26,679 $370,132 
December 31, 2019
Carrying Value
Credit default swaps:
Investment grade$$$60 $164 $229 
Non-investment grade70 292 561 808 1,731 
Total70 297 621 972 1,960 
Total return swaps/options:     
Investment grade35 35 
Non-investment grade344 344 
Total379 379 
Total credit derivatives$449 $297 $621 $972 $2,339 
Credit-related notes:     
Investment grade$$$$639 $643 
Non-investment grade1,125 1,134 
Total credit-related notes$$$$1,764 $1,777 
 Maximum Payout/Notional
Credit default swaps:
Investment grade$55,827 $67,838 $71,320 $17,708 $212,693 
Non-investment grade19,049 26,521 29,618 12,337 87,525 
Total74,876 94,359 100,938 30,045 300,218 
Total return swaps/options:     
Investment grade56,488 62 76 56,626 
Non-investment grade28,707 657 104 60 29,528 
Total85,195 657 166 136 86,154 
Total credit derivatives$160,071 $95,016 $101,104 $30,181 $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.
Bank of America 116


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 112, 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)One
incremental notch
Second
incremental notch
Bank of America Corporation$300 $735 
Bank of America, N.A. and subsidiaries (1)
61 570 
(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)One
incremental notch
Second
incremental notch
Derivative liabilities$45 $1,035 
Collateral posted23 544 
Valuation Adjustments on Derivatives
TheCorporation records credit risk valuation adjustments on derivatives in order to properly reflect the credit quality of the counterparties and its own credit quality. The Corporation calculates valuation adjustments on derivatives based on a modeled expected exposure that incorporates current market risk factors. The exposure also takes into consideration credit mitigants such as enforceable master netting agreements and collateral. CDS spread data is used to estimate the default probabilities and severities that are applied to the exposures. Where no observable credit default data is available for counterparties, the Corporation uses proxies and other market data to estimate default probabilities and severity.
The table below presents credit valuation adjustment (CVA), DVA and FVA gains (losses) on derivatives (excluding the effect of any related hedge activities), which are recorded in market making and similar activities, for 2020, 2019 and 2018. CVA gains reduce the cumulative CVA thereby increasing the derivative assets balance. DVA gains increase the cumulative DVA thereby decreasing the derivative liabilities balance. CVA and DVA losses have the opposite impact. FVA gains related to derivative assets reduce the cumulative FVA thereby increasing the derivative assets balance. FVA gains related to derivative liabilities increase the cumulative FVA thereby decreasing the derivative liabilities balance. FVA losses have the opposite impact.
Valuation Adjustments Gains (Losses) on Derivatives (1)
(Dollars in millions)202020192018
Derivative assets (CVA)$(118)$72 $77 
Derivative assets/liabilities (FVA)(24)(2)(15)
Derivative liabilities (DVA)24 (147)(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.
117 Bank of America


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
Amortized
Cost
Gross
Unrealized
Gains
Gross
Unrealized
Losses
Fair
Value
(Dollars in millions)December 31, 2020
Available-for-sale debt securities
Mortgage-backed securities:
Agency$59,518 $2,370 $(39)$61,849 
Agency-collateralized mortgage obligations5,112 161 (13)5,260 
Commercial15,470 1,025 (4)16,491 
Non-agency residential (1)
899 127 (17)1,009 
Total mortgage-backed securities80,999 3,683 (73)84,609 
U.S. Treasury and agency securities114,157 2,236 (13)116,380 
Non-U.S. securities14,009 15 (7)14,017 
Other taxable securities, substantially all asset-backed securities2,656 61 (6)2,711 
Total taxable securities211,821 5,995 (99)217,717 
Tax-exempt securities16,417 389 (32)16,774 
Total available-for-sale debt securities (3)
228,238 6,384 (131)234,491 
Other debt securities carried at fair value (2)
11,720 429 (39)12,110 
Total debt securities carried at fair value239,958 6,813 (170)246,601 
Held-to-maturity debt securities, substantially all U.S. agency mortgage-backed securities (3)
438,279 10,095 (194)448,180 
Total debt securities (3,4)
$678,237 $16,908 $(364)$694,781 
December 31, 2019
Available-for-sale debt securities
Mortgage-backed securities:
Agency$121,698 $1,013 $(183)$122,528 
Agency-collateralized mortgage obligations4,587 78 (24)4,641 
Commercial14,797 249 (25)15,021 
Non-agency residential (1)
948 138 (9)1,077 
Total mortgage-backed securities142,030 1,478 (241)143,267 
U.S. Treasury and agency securities67,700 1,023 (195)68,528 
Non-U.S. securities11,987 (2)11,991 
Other taxable securities, substantially all asset-backed securities3,874 67 3,941 
Total taxable securities225,591 2,574 (438)227,727 
Tax-exempt securities17,716 202 (6)17,912 
Total available-for-sale debt securities243,307 2,776 (444)245,639 
Other debt securities carried at fair value (2)
10,596 255 (23)10,828 
Total debt securities carried at fair value253,903 3,031 (467)256,467 
Held-to-maturity debt securities, substantially all U.S. agency mortgage-backed securities215,730 4,433 (342)219,821 
Total debt securities (3, 4)
$469,633 $7,464 $(809)$476,288 
(1)At December 31, 2020 and 2019, the underlying collateral type included approximately 37 percent and 49 percent prime, 2 percent and 6 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.
(3)Includes securities pledged as collateral of $65.5 billion and $67.0 billion at December 31, 2020 and 2019.
(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.

Bank of America 118


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)202020192018
Gross gains$423 $336 $169 
Gross losses(12)(119)(15)
Net gains on sales of AFS debt securities$411 $217 $154 
Income tax expense attributable to realized net gains on sales of AFS debt securities$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
Less than Twelve MonthsTwelve Months or LongerTotal
Fair
Value
Gross Unrealized LossesFair
Value
Gross Unrealized LossesFair
Value
Gross Unrealized Losses
(Dollars in millions)December 31, 2020
Continuously unrealized loss-positioned AFS debt securities
Mortgage-backed securities:   
Agency$2,841 $(39)$2 $0 $2,843 $(39)
Agency-collateralized mortgage obligations187 (2)364 (11)551 (13)
Commercial566 (4)9 0 575 (4)
Non-agency residential342 (9)56 (8)398 (17)
Total mortgage-backed securities3,936 (54)431 (19)4,367 (73)
U.S. Treasury and agency securities8,282 (9)498 (4)8,780 (13)
Non-U.S. securities1,861 (6)135 (1)1,996 (7)
Other taxable securities, substantially all asset-backed securities576 (2)396 (4)972 (6)
Total taxable securities14,655 (71)1,460 (28)16,115 (99)
Tax-exempt securities4,108 (29)617 (3)4,725 (32)
Total AFS debt securities in a continuous
unrealized loss position
$18,763 $(100)$2,077 $(31)$20,840 $(131)
December 31, 2019
Continuously unrealized loss-positioned AFS debt securities
Mortgage-backed securities:
Agency$17,641 $(41)$17,238 $(142)$34,879 $(183)
Agency-collateralized mortgage obligations255 (1)925 (23)1,180 (24)
Commercial2,180 (22)442 (3)2,622 (25)
Non-agency residential122 (6)22 (3)144 (9)
Total mortgage-backed securities20,198 (70)18,627 (171)38,825 (241)
U.S. Treasury and agency securities12,836 (71)18,866 (124)31,702 (195)
Non-U.S. securities851 837 (2)1,688 (2)
Other taxable securities, substantially all asset-backed securities938 222 1,160 
Total taxable securities34,823 (141)38,552 (297)73,375 (438)
Tax-exempt securities4,286 (5)190 (1)4,476 (6)
Total AFS debt securities in a continuous
unrealized loss position
$39,109 $(146)$38,742 $(298)$77,851 $(444)

119 Bank of America


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
Due in One
Year or Less
Due after One Year
through Five Years
Due after Five Years
through Ten Years
Due after
Ten Years
Total
(Dollars in millions)Amount
Yield (1)
Amount
Yield (1)
Amount
Yield (1)
Amount
Yield (1)
Amount
Yield (1)
Amortized cost of debt securities carried at fair value          
Mortgage-backed securities:          
Agency$%$5.69 %$56 4.44 %$59,455 3.36 %$59,518 3.36 %
Agency-collateralized mortgage obligations24 2.57 5,088 2.94 5,112 2.94 
Commercial26 3.04 6,669 2.52 7,711 2.32 1,077 2.64 15,483 2.43 
Non-agency residential1,620 6.77 1,621 6.77 
Total mortgage-backed securities26 3.04 6,676 2.52 7,792 2.34 67,240 3.40 81,734 3.23 
U.S. Treasury and agency securities10,020 1.26 29,533 1.85 74,665 0.74 32 2.55 114,250 1.07 
Non-U.S. securities22,862 0.31 926 1.81 581 1.09 532 1.79 24,901 0.42 
Other taxable securities, substantially all asset-backed securities699 1.15 1,336 2.46 366 2.26 255 1.60 2,656 2.00 
Total taxable securities33,607 0.61 38,471 1.99 83,404 0.89 68,059 3.38 223,541 1.80 
Tax-exempt securities872 0.87 8,430 1.27 4,397 1.66 2,718 1.41 16,417 1.38 
Total amortized cost of debt securities carried at fair value$34,479 0.62 $46,901 1.86 $87,801 0.93 $70,777 3.30 $239,958 1.77 
Amortized cost of HTM debt securities (2)
$15 3.78 $66 2.73 $17,133 1.86 $421,065 2.40 $438,279 2.38 
Debt securities carried at fair value          
Mortgage-backed securities:          
Agency$ $ $61  $61,781  $61,849  
Agency-collateralized mortgage obligations  24  5,236  5,260  
Commercial26  7,077  8,242  1,160  16,505  
Non-agency residential   1,776  1,783  
Total mortgage-backed securities26 7,084 8,334 69,953 85,397 
U.S. Treasury and agency securities10,056 30,873 75,511 33 116,473 
Non-U.S. securities23,187  940  582  534  25,243  
Other taxable securities, substantially all asset-backed securities702  1,369  379  264  2,714  
Total taxable securities33,971  40,266  84,806  70,784  229,827  
Tax-exempt securities874  8,554  4,566  2,780  16,774  
Total debt securities carried at fair value$34,845  $48,820  $89,372  $73,564  $246,601  
Fair value of HTM debt securities (2)
$14 $69 $17,139 $430,958 $448,180 
(1)The weighted-average yield is computed based on a constant effective interest rate over the contractual life of each security. The average yield considers the contractual coupon and the amortization of premiums and accretion of discounts, excluding the effect of related hedging derivatives.
(2)Substantially all U.S. agency MBS.
Bank of America 120


NOTE 5Outstanding 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.
30-59 Days Past Due (1)
60-89 Days Past Due (1)
90 Days or
More
Past Due (1)
Total Past
Due 30 Days
or More
Total Current or Less Than 30 Days Past Due (1)
Loans Accounted for Under the Fair Value OptionTotal
Outstandings
(Dollars in millions)December 31, 2020
Consumer real estate      
Core portfolio
Residential mortgage$1,157 $175 $786 $2,118 $213,155 $215,273 
Home equity126 61 269 456 29,872 30,328 
Non-core portfolio
Residential mortgage273 122 913 1,308 6,974 8,282 
Home equity28 17 76 121 3,862 3,983 
Credit card and other consumer
Credit card445 341 903 1,689 77,019 78,708 
Direct/Indirect consumer (2)
209 67 37 313 91,050 91,363 
Other consumer0 0 0 0 124 124 
Total consumer2,238 783 2,984 6,005 422,056 428,061 
Consumer loans accounted for under the fair value option (3)
     $735 735 
Total consumer loans and leases2,238 783 2,984 6,005 422,056 735 428,796 
Commercial
U.S. commercial561 214 512 1,287 287,441 288,728 
Non-U.S. commercial61 44 11 116 90,344 90,460 
Commercial real estate (4)
128 113 226 467 59,897 60,364 
Commercial lease financing86 20 57 163 16,935 17,098 
U.S. small business commercial (5)
84 56 123 263 36,206 36,469 
Total commercial920 447 929 2,296 490,823 493,119 
Commercial loans accounted for under the fair value option (3)
     5,946 5,946 
Total commercial loans and leases920 447 929 2,296 490,823 5,946 499,065 
Total loans and leases (6)
$3,158 $1,230 $3,913 $8,301 $912,879 $6,681 $927,861 
Percentage of outstandings0.34 %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)Includes PPP loans.
(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 potential borrowing capacity with the Federal Reserve Bank and Federal Home Loan Bank.
121 Bank of America


30-59 Days
Past Due
(1)
60-89 Days Past Due (1)
90 Days or
More
Past Due
(1)
Total Past
Due 30 Days
or More
Total
Current or
Less Than
30 Days
Past Due (1)
Loans
Accounted
for Under
the Fair
Value Option
Total Outstandings
(Dollars in millions)December 31, 2019
Consumer real estate      
Core portfolio
Residential mortgage$1,378 $261 $565 $2,204 $223,566  $225,770 
Home equity135 70 198 403 34,823  35,226 
Non-core portfolio       
Residential mortgage458 209 1,263 1,930 8,469  10,399 
Home equity34 16 72 122 4,860  4,982 
Credit card and other consumer       
Credit card564 429 1,042 2,035 95,573  97,608 
Direct/Indirect consumer (2)
297 85 35 417 90,581  90,998 
Other consumer 192  192 
Total consumer2,866 1,070 3,175 7,111 458,064 465,175 
Consumer loans accounted for under the fair value option (3)
$594 594 
Total consumer loans and leases2,866 1,070 3,175 7,111 458,064 594 465,769 
Commercial       
U.S. commercial788 279 371 1,438 305,610  307,048 
Non-U.S. commercial35 23 66 104,900  104,966 
Commercial real estate (4)
144 19 119 282 62,407  62,689 
Commercial lease financing100 56 39 195 19,685  19,880 
U.S. small business commercial119 56 107 282 15,051  15,333 
Total commercial1,186 433 644 2,263 507,653  509,916 
Commercial loans accounted for under the fair value option (3)
7,741 7,741 
Total commercial loans and leases1,186 433 644 2,263 507,653 7,741 517,657 
Total loans and leases (5)
$4,052 $1,503 $3,819 $9,374 $965,717 $8,335 $983,426 
Percentage of outstandings0.41 %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.
Nonperforming Loans and Leases
Commercial nonperforming loans increased to $2.2 billion at December 31, 2020 from $1.5 billion at December 31, 2019 with broad-based increases across multiple industries. 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 for loan modifications related to the pandemic and the criteria for classification as nonperforming, see Note 1 – Summary of Significant Accounting Principles.
Bank of America 122


Credit Quality
Nonperforming Loans
and Leases
Accruing Past Due
90 Days or More (1)
December 31
(Dollars in millions)2020201920202019
Residential mortgage (2)
$2,005 $1,470 $762 $1,088 
With no related allowance (3)
1,378 n/a0 
Home equity (2)
649 536 0 
With no related allowance (3)
347 n/a0 
Credit Cardn/an/a903 1,042 
Direct/indirect consumer71 47 33 33 
Total consumer2,725 2,053 1,698 2,163 
U.S. commercial1,243 1,094 228 106 
Non-U.S. commercial418 43 10 
Commercial real estate404 280 6 19 
Commercial lease financing87 32 25 20 
U.S. small business commercial75 50 115 97 
Total commercial2,227 1,499 384 250 
Total nonperforming loans$4,952 $3,552 $2,082 $2,413 
Percentage of outstanding loans and leases0.54 %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, consist entirelythe primary credit quality indicators are refreshed LTV and refreshed FICO score. Refreshed LTV measures the carrying value of TDRs. Excluding PCIthe 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.
123 Bank of America


Residential Mortgage – Credit Quality Indicators By Vintage
Term Loans by Origination Year
(Dollars in millions)Total as of December 31, 202020202019201820172016Prior
Total Residential Mortgage
Refreshed LTV
   
Less than or equal to 90 percent$207,389 $68,907 $43,771 $14,658 $21,589 $22,967 $35,497 
Greater than 90 percent but less than or equal to 100 percent3,138 1,970 684 128 70 96 190 
Greater than 100 percent1,210 702 174 47 39 37 211 
Fully-insured loans11,818 3,826 2,014 370 342 1,970 3,296 
Total Residential Mortgage$223,555 $75,405 $46,643 $15,203 $22,040 $25,070 $39,194 
Total Residential Mortgage
Refreshed FICO score
Less than 620$2,717 $823 $177 $139 $170 $150 $1,258 
Greater than or equal to 620 and less than 6805,462 1,804 666 468 385 368 1,771 
Greater than or equal to 680 and less than 74025,349 8,533 4,679 1,972 2,427 2,307 5,431 
Greater than or equal to 740178,209 60,419 39,107 12,254 18,716 20,275 27,438 
Fully-insured loans11,818 3,826 2,014 370 342 1,970 3,296 
Total Residential Mortgage$223,555 $75,405 $46,643 $15,203 $22,040 $25,070 $39,194 
Home Equity - Credit Quality Indicators
Total
Home Equity Loans and Reverse Mortgages (1)
Revolving LoansRevolving Loans Converted to Term Loans
(Dollars in millions)December 31, 2020
Total Home Equity
Refreshed LTV
   
Less than or equal to 90 percent$33,447 $1,919 $22,639 $8,889 
Greater than 90 percent but less than or equal to 100 percent351 126 94 131 
Greater than 100 percent513 172 118 223 
Total Home Equity$34,311 $2,217 $22,851 $9,243 
Total Home Equity
Refreshed FICO score
Less than 620$1,082 $250 $244 $588 
Greater than or equal to 620 and less than 6801,798 263 568 967 
Greater than or equal to 680 and less than 7405,762 556 2,905 2,301 
Greater than or equal to 74025,669 1,148 19,134 5,387 
Total Home Equity$34,311 $2,217 $22,851 $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 YearCredit Card
(Dollars in millions)Total Direct/Indirect as of December 31, 2020Revolving Loans20202019201820172016PriorTotal Credit Card as of December 31, 2020Revolving Loans
Revolving Loans Converted to Term Loans (3)
Refreshed FICO score  
Less than 620$959 $19 $111 $200 $175 $243 $148 $63 $4,018 $3,832 $186 
Greater than or equal to 620 and less than 6802,143 20 653 559 329 301 176 105 9,419 9,201 218 
Greater than or equal to 680 and less than 7407,431 80 2,848 2,015 1,033 739 400 316 27,585 27,392 193 
Greater than or equal to 74036,064 120 12,540 10,588 5,869 3,495 1,781 1,671 37,686 37,642 44 
Other internal credit
   metrics (1, 2)
44,766 44,098 74 115 84 67 52 276 0 
Total credit card and other
consumer
$91,363 $44,337 $16,226 $13,477 $7,490 $4,845 $2,557 $2,431 $78,708 $78,067 $641 
(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.
Bank of America 124


Commercial – Credit Quality Indicators By Vintage (1, 2)
Term Loans
Amortized Cost Basis by Origination Year
(Dollars in millions)Total as of December 31, 202020202019201820172016PriorRevolving Loans
U.S. Commercial
Risk ratings    
Pass rated$268,812 $33,456 $33,305 $17,363 $14,102 $7,420 $21,784 $141,382 
Reservable criticized19,916 2,524 2,542 2,689 854 698 1,402 9,207 
Total U.S. Commercial$288,728 $35,980 $35,847 $20,052 $14,956 $8,118 $23,186 $150,589 
Non-U.S. Commercial
Risk ratings
Pass rated$85,914 $16,301 $11,396 $7,451 $5,037 $1,674 $2,194 $41,861 
Reservable criticized4,546 914 572 492 436 138 259 1,735 
Total Non-U.S. Commercial$90,460 $17,215 $11,968 $7,943 $5,473 $1,812 $2,453 $43,596 
Commercial Real Estate
Risk ratings
Pass rated$50,260 $8,429 $14,126 $8,228 $4,599 $3,299 $6,542 $5,037 
Reservable criticized10,104 933 2,558 2,115 1,582 606 1,436 874 
Total Commercial Real Estate$60,364 $9,362 $16,684 $10,343 $6,181 $3,905 $7,978 $5,911 
Commercial Lease Financing
Risk ratings
Pass rated$16,384 $3,083 $3,242 $2,956 $2,532 $1,703 $2,868 $
Reservable criticized714 117 117 132 81 88 179 
Total Commercial Lease Financing$17,098 $3,200 $3,359 $3,088 $2,613 $1,791 $3,047 $
U.S. Small Business Commercial (3)
Risk ratings
Pass rated$28,786 $24,539 $1,121 $837 $735 $527 $855 $172 
Reservable criticized1,148 76 239 210 175 113 322 13 
Total U.S. Small Business Commercial$29,934 $24,615 $1,360 $1,047 $910 $640 $1,177 $185 
 Total (1, 2)
$486,584 $90,372 $69,218 $42,473 $30,133 $16,266 $37,841 $200,281 
(1) Excludes $5.9 billion of loans accounted for under the fair value option at December 31, 2020.
(2)     Includes $58 million of loans that converted from revolving to term loans.
(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 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 increases spread across multiple industries, including travel and entertainment.
Troubled Debt Restructurings
The Corporation has been entering into loan modifications with borrowers in response to the pandemic, most modifications of consumer real estatewhich are not classified as TDRs, and therefore are not included in the discussion below. For more information on the criteria for classifying loans meet the definitionas TDRs, see Note 1 – Summary of TDRs when a binding offer is extended to a borrower. Significant Accounting Principles
Consumer Real Estate
Modifications of consumer real estate loans are done in accordance with government programs orclassified as TDRs when the Corporation’s proprietary programs. These modifications are considered to be TDRs if concessions have been granted to borrowersborrower is experiencing financial difficulties.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 of $1.2 billion were included in TDRs at December 31, 2017,2020, of which $358$102 million were classified as nonperforming and $419$68 million were loans fully-insured by the FHA. For more information on loans discharged in Chapter 7 bankruptcy, see Nonperforming Loans and Leases in this Note.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 reachedreach 180 days past due prior to modification had beenare charged off to their net realizable value, less costs to sell, before they wereare modified as TDRs in accordance with established policy. Therefore, modifications of consumer real estate loans that are 180 or more days past due as TDRs do not have an impact on the allowance for loan and lease losses nor are additional charge-offs required at the time of modification. Subsequent declines in the fair value of the collateral after a loan has reached 180 days past due are recorded as charge-offs. Fully-insured loans are
125 Bank of America


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, 20172020 and 2016,2019, remaining commitments to lend additional funds to debtors whose terms have been modified in a consumer real estate TDR were immaterial.not significant. Consumer real estate foreclosed properties totaled $236$123 million and $363$229 million at December 31, 20172020 and 2016.2019. The carrying value of consumer real estate loans, including fully-insured and PCI loans, for which formal foreclosure proceedings were in process at December 31, 20172020 was $3.6$1.2 billion. During 2017Although the Corporation has paused formal loan foreclosure proceedings and 2016,foreclosure sales for occupied properties, during 2020, the Corporation reclassified $815$182 million and $1.4 billion of consumer real estate
loans completed or which were in process prior to the pause in foreclosures, to foreclosed properties or, for properties acquired upon foreclosure of certain government-guaranteed loans (principally FHA-insured loans), to other assets. The reclassifications represent non-cash investing activities and, accordingly, are not reflected in the Consolidated Statement of Cash Flows.
The following table provides the unpaid principal balance, carrying value and related allowance at December 31, 2017 and 2016, and the average carrying value and interest income recognized for 2017, 2016 and 2015 for impaired loans in the Corporation’s Consumer Real Estate portfolio segment. Certain impaired consumer real estate loans do not have a related allowance as the current valuation of these impaired loans exceeded the carrying value, which is net of previously recorded charge-offs.

131Bank of America 2017



            
Impaired Loans – Consumer Real Estate  
            
 
Unpaid
Principal
Balance
 
Carrying
Value
 
Related
Allowance
 
Unpaid
Principal
Balance
 
Carrying
Value
 
Related
Allowance
(Dollars in millions)December 31, 2017 December 31, 2016
With no recorded allowance 
  
  
  
  
  
Residential mortgage$8,856
 $6,870
 $
 $11,151
 $8,695
 $
Home equity3,622
 1,956
 
 3,704
 1,953
 
With an allowance recorded     
      
Residential mortgage$2,908
 $2,828
 $174
 $4,041
 $3,936
 $219
Home equity972
 900
 174
 910
 824
 137
Total 
  
  
      
Residential mortgage$11,764
 $9,698
 $174
 $15,192
 $12,631
 $219
Home equity4,594
 2,856
 174
 4,614
 2,777
 137
            
 Average
Carrying
Value
 
Interest
Income
Recognized
(1)
 Average
Carrying
Value
 
Interest
Income
Recognized
(1)
 Average
Carrying
Value
 
Interest
Income
Recognized
(1)
 2017 2016 2015
With no recorded allowance           
Residential mortgage$7,737
 $311
 $10,178
 $360
 $13,867
 $403
Home equity1,997
 109
 1,906
 90
 1,777
 89
With an allowance recorded           
Residential mortgage$3,414
 $123
 $5,067
 $167
 $7,290
 $236
Home equity858
 24
 852
 24
 785
 24
Total           
Residential mortgage$11,151
 $434
 $15,245
 $527
 $21,157
 $639
Home equity2,855
 133
 2,758
 114
 2,562
 113
(1)
Interest income recognized includes interest accrued and collected on the outstanding balances of accruing impaired loans as well as interest cash collections on nonaccruing impaired loans for which the principal is considered collectible.
The table below presents the December 31, 2017, 20162020, 2019 and 20152018 unpaid principal balance, carrying value, and average pre- and post-modification interest rates onof consumer real estate loans that were modified in TDRs during 2017, 20162020, 2019 and 2015, and net charge-offs recorded during the period in which the modification occurred.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 2017, 2016 and 2015 (1)
  
 Unpaid Principal Balance 
Carrying
Value
 Pre-Modification Interest Rate 
Post-Modification Interest Rate (2)
 
Net
Charge-offs (3)
(Dollars in millions)December 31, 2017 2017
Residential mortgage$824
 $712
 4.43% 4.16% $6
Home equity764
 590
 4.22
 3.49
 42
Total$1,588
 $1,302
 4.33
 3.83
 $48
          
 December 31, 2016 2016
Residential mortgage$1,130
 $1,017
 4.73% 4.16% $11
Home equity849
 649
 3.95
 2.72
 61
Total$1,979
 $1,666
 4.40
 3.54
 $72
          
 December 31, 2015 2015
Residential mortgage$2,986
 $2,655
 4.98% 4.43% $97
Home equity1,019
 775
 3.54
 3.17
 84
Total$4,005
 $3,430
 4.61
 4.11
 $181
(1)
During 2017, there was no forgiveness of principal related to residential mortgage loans in connection with TDRs compared to $13 million and $396 million during 2016 and 2015.
(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.
(3)
Net charge-offs include amounts recorded on loans modified during the period that are no longer held by the Corporation at December 31, 2017, 2016 and 2015 due to sales and other dispositions.

Consumer Real Estate – TDRs Entered into During 2020, 2019 and 2018 (1)
Unpaid Principal BalanceCarrying
Value
Pre-Modification Interest Rate
Post-Modification Interest Rate (2)
(Dollars in millions)December 31, 2020
Residential mortgage$732 $646 3.66 %3.59 %
Home equity87 69 3.67 3.61 
Total$819 $715 3.66 3.59 
December 31, 2019
Residential mortgage$464 $377 4.19 %4.13 %
Home equity141 101 5.04 4.31 
Total$605 $478 4.39 4.17 
December 31, 2018
Residential mortgage$774 $641 4.33 %4.21 %
Home equity489 358 4.46 3.74 
Total$1,263 $999 4.38 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.
Bank of America 2017132


(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, 2017, 20162020, 2019 and 20152018 carrying value for consumer real estate loans that were modified in a TDR during 2017, 20162020, 2019 and 2015,2018, by type of modification.
Consumer Real Estate – Modification Programs (1)
TDRs Entered into During
(Dollars in millions)202020192018
Modifications under government programs$13 $35 $61 
Modifications under proprietary programs570 174 523 
Loans discharged in Chapter 7 bankruptcy (2)
53 68 130 
Trial modifications79 201 285 
Total modifications$715 $478 $999 
      
Consumer Real Estate – Modification Programs    
      
 TDRs Entered into During
(Dollars in millions)2017 2016 2015
Modifications under government programs     
Contractual interest rate reduction$59
 $151
 $431
Principal and/or interest forbearance4
 13
 11
Other modifications (1)
22
 23
 46
Total modifications under government programs85
 187
 488
Modifications under proprietary programs     
Contractual interest rate reduction281
 235
 219
Capitalization of past due amounts63
 40
 79
Principal and/or interest forbearance38
 72
 168
Other modifications (1)
55
 75
 129
Total modifications under proprietary programs437
 422
 595
Trial modifications569
 831
 1,968
Loans discharged in Chapter 7 bankruptcy (2)
211
 226
 379
Total modifications$1,302
 $1,666
 $3,430
(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.
(1)
(2)Includes loans discharged in Chapter 7 bankruptcy with no change in repayment terms that are classified as TDRs.
Includes other modifications such as term or payment extensions and repayment plans.
(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 2017, 20162020, 2019 and 20152018 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 three3 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)202020192018
Modifications under government programs$16 $26 $39 
Modifications under proprietary programs51 88 158 
Loans discharged in Chapter 7 bankruptcy (2)
19 30 64 
Trial modifications (3)
54 57 107 
Total modifications$140 $201 $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)Includes loans discharged in Chapter 7 bankruptcy with no change in repayment terms that are classified as TDRs.
(3)Includes trial modification offers to which the customer did not respond.

      
Consumer Real Estate – TDRs Entering Payment Default that were Modified During the Preceding 12 Months
     
(Dollars in millions)2017 2016 2015
Modifications under government programs$81
 $262
 $457
Modifications under proprietary programs138
 196
 287
Loans discharged in Chapter 7 bankruptcy (1)
116
 158
 285
Trial modifications (2)
391
 824
 3,178
Total modifications$726
 $1,440
 $4,207
(1)
Includes loans discharged in Chapter 7 bankruptcy with no change in repayment terms that are classified as TDRs.
Bank of America 126
(2)


Includes trial modification offers to which the customer did not respond.

Credit Card and Other Consumer
Impaired loans within the Credit Card and Other Consumer portfolio segment consist entirely of loans that have been modified in TDRs. The Corporation seeks to assist customers that are experiencing financial difficulty by modifying loans while ensuring compliance with federal local and internationallocal laws and guidelines. Credit card and other consumer loan modifications generally involve reducing the interest rate on the account, and placing the customer on a fixed payment plan not exceeding 60 months all of which are considered TDRs. In substantially all cases,and canceling the customer’s available line of credit, is canceled.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
renegotiation agencies that provide solutions to customers’ entire unsecured debt structures (external programs). The Corporation classifies other secured consumer loans that have been discharged in Chapter 7 bankruptcy as TDRs, which are written down to collateral value and placed on nonaccrual status no later than the time of discharge. For more information on the regulatory guidance on loans discharged in Chapter 7 bankruptcy, see Nonperforming Loans and Leases in this Note.
The following table provides the unpaid principal balance, carrying value and related allowance at December 31, 2017 and 2016, and the average carrying value and interest income recognized for 2017, 2016 and 2015 on TDRs within the Credit Card and Other Consumer portfolio segment.

133Bank of America 2017



             
Impaired Loans – Credit Card and Other Consumer  
             
  
Unpaid
Principal
Balance
 
Carrying
Value (1)
 
Related
Allowance
 
Unpaid
Principal
Balance
 
Carrying
Value (1)
 
Related
Allowance
(Dollars in millions) December 31, 2017 December 31, 2016
With no recorded allowance  
  
  
      
Direct/Indirect consumer $58
 $28
 $
 $49
 $22
 $
With an allowance recorded  
  
  
      
U.S. credit card $454
 $461
 $125
 $479
 $485
 $128
Non-U.S. credit card n/a
 n/a
 n/a
 88
 100
 61
Direct/Indirect consumer 1
 1
 
 3
 3
 
Total  
  
  
  
  
  
U.S. credit card $454
 $461
 $125
 $479
 $485
 $128
Non-U.S. credit card n/a
 n/a
 n/a
 88
 100
 61
Direct/Indirect consumer 59
 29
 
 52
 25
 
             
  Average
Carrying
Value
 
Interest
Income
Recognized
(2)
 Average
Carrying
Value
 
Interest
Income
Recognized
(2)
 Average
Carrying
Value
 
Interest
Income
Recognized
(2)
  2017 2016 2015
With no recorded allowance            
Direct/Indirect consumer $21
 $2
 $20
 $
 $22
 $
With an allowance recorded  
  
        
U.S. credit card $464
 $25
 $556
 $31
 $749
 $43
Non-U.S. credit card 47
 1
 111
 3
 145
 4
Direct/Indirect consumer 2
 
 10
 1
 51
 3
Total  
  
        
U.S. credit card $464
 $25
 $556
 $31
 $749
 $43
Non-U.S. credit card 47
 1
 111
 3
 145
 4
Direct/Indirect consumer 23
 2
 30
 1
 73
 3
(1)
Includes accrued interest and fees.
(2)
Interest income recognized includes interest accrued and collected on the outstanding balances of accruing impaired loans as well as interest cash collections on nonaccruing impaired loans for which the principal is considered collectible.
n/a = not applicable
The table below provides information on the Corporation’s primary modification programs for the Credit Card and Other Consumer TDR portfolio at December 31, 2017 and 2016.
                    
Credit Card and Other Consumer – TDRs by Program Type at December 31
          
 Internal Programs External Programs 
Other (1)
 Total Percent of Balances Current or Less Than 30 Days Past Due
(Dollars in millions)2017 2016 2017 2016 2017 2016 2017 2016 2017 2016
U.S. credit card$203
 $220
 $257
 $264
 $1
 $1
 $461
 $485
 86.92% 88.99%
Non-U.S. credit cardn/a
 11
 n/a
 7
 n/a
 82
 n/a
 100
 n/a
 38.47
Direct/Indirect consumer1
 2
 
 1
 28
 22
 29
 25
 88.16
 90.49
Total TDRs by program type$204
 $233
 $257
 $272
 $29
 $105
 $490
 $610
 87.00
 80.79
(1)
Other TDRs for non-U.S. credit card included modifications of accounts that are ineligible for a fixed payment plan.
n/a = not applicable

Bank of America 2017134


The table below provides information on the Corporation’s Credit Card and Other Consumer TDR portfolio including the December 31, 2017, 20162020, 2019 and 20152018 unpaid principal balance, carrying value, and average pre- and post-modification interest rates of loans that were modified in TDRs during 2017, 20162020, 2019 and 2015,2018.
Credit Card and Other Consumer – TDRs Entered into During 2020, 2019 and 2018 (1)
 Unpaid Principal Balance
Carrying
Value
(2)
Pre-Modification Interest RatePost-Modification Interest Rate
(Dollars in millions)December 31, 2020
Credit card$269 $277 18.16 %5.63 %
Direct/Indirect consumer52 37 5.83 5.83 
Total$321 $314 16.70 5.65 
December 31, 2019
Credit card$340 $355 19.18 %5.35 %
Direct/Indirect consumer40 21 5.23 5.21 
Total$380 $376 18.42 5.34 
December 31, 2018
Credit card$278 $292 19.49 %5.24 %
Direct/Indirect consumer42 23 5.10 4.95 
Total$320 $315 18.45 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 net charge-offs recordedfees.
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)202020192018
Internal programs$225 $247 $199 
External programs73 108 93 
Other16 21 23 
Total$314 $376 $315 
(1)Includes accrued interest and fees. For more information on the periodCorporation's loan modification programs offered in response to the pandemic, most of which the modification occurred.are not TDRs, see Note 1 – Summary of Significant Accounting Principles.
        
Credit Card and Other Consumer – TDRs Entered into During 2017, 2016 and 2015
        
 Unpaid Principal Balance 
Carrying Value (1)
 
Pre-
Modification
Interest Rate
 
Post-
Modification
Interest Rate
(Dollars in millions)December 31, 2017
U.S. credit card$203
 $213
 18.47% 5.32%
Direct/Indirect consumer37
 22
 4.81
 4.30
Total (2)
$240
 $235
 17.17
 5.22
        
 December 31, 2016
U.S. credit card$163
 $172
 17.54% 5.47%
Non-U.S. credit card66
 75
 23.99
 0.52
Direct/Indirect consumer21
 13
 3.44
 3.29
Total (2)
$250
 $260
 18.73
 3.93
        
 December 31, 2015
U.S. credit card$205
 $218
 17.07% 5.08%
Non-U.S. credit card74
 86
 24.05
 0.53
Direct/Indirect consumer19
 12
 5.95
 5.19
Total (2)
$298
 $316
 18.58
 3.84
(1)
Includes accrued interest and fees.
(2)
Net charge-offs were $52 million, $74 million and $98 million in 2017, 2016 and 2015, respectively.
Credit card and other consumer loans are deemed to be in payment default during the quarter in which a borrower misses the second of two2 consecutive payments. Payment defaults are one of the factors considered when projecting future cash flows in the calculation of the allowance for loan and lease losses for impaired credit card and other consumer loans.consumer. Based on historical experience, the Corporation estimates that 13 percent of new U.S. credit card TDRs and 1519 percent of new direct/indirect consumer TDRs may be in payment default within 12 months after modification. Loans that entered into payment default during 2017, 2016 and 2015 that had been modified in a TDR during the preceding 12 months were $28 million, $30 million and $43 million for U.S. credit card, $0, $127 million and $152 million for non-U.S. credit card, and $4 million, $2 million and $3 million for direct/indirect consumer.
Commercial Loans
Impaired commercial loans include nonperforming loans and TDRs (both performing and nonperforming). Modifications of loans to commercial borrowers that are experiencing financial difficulty are designed to reduce the Corporation’s loss exposure while providing the borrower with an opportunity to work through financial difficulties, often to avoid foreclosure or bankruptcy. Each modification is unique and reflects the individual circumstances of the borrower. Modifications that result in a TDR may include extensions of
maturity at a concessionary (below market) rate of
interest, payment forbearances or other actions designed to benefit the customerborrower while mitigating the Corporation’s risk exposure. Reductions in interest rates are rare. Instead, the interest rates are typically increased, although the increased rate may not represent a market rate of interest. Infrequently, concessions may also include principal forgiveness in connection with foreclosure, short sale or other settlement agreements leading to termination or sale of the loan.
At the time of restructuring, the loans are remeasured to reflect the impact, if any, on projected cash flows resulting from the modified terms. If there was no forgiveness of principal and the interest rate was not decreased, the modification may have little or no impact on the allowance established for the loan. If a portion of the loan is deemed to be uncollectible, a charge-off may be recorded at the time of restructuring. Alternatively, a charge-off may have already been recorded in a previous period such that no charge-off is required at the time of modification. For more information on modifications for the U.S. small business commercial portfolio, see Credit Card and Other Consumer in this Note.

127 Bank of America


At December 31, 20172020 and 2016,2019, the Corporation had $1.7 billion and $2.2 billion of commercial TDRs with remaining commitments to lend additional funds to debtors whose terms have been modified in a commercial loan TDR were $205of $402 million and $461$445 million.
Commercial foreclosed properties totaled $52 The balance of commercial TDRs in payment default was $218 million and $14$207 million at December 31, 20172020 and 2016.


135Bank of America 2017



The table below provides information on impaired loans in the Commercial loan portfolio segment including the unpaid principal balance, carrying value and related allowance at December 31, 2017 and 2016, and the average carrying value and interest income recognized for 2017, 2016 and 2015. Certain impaired commercial loans do not have a related allowance as the valuation of these impaired loans exceeded the carrying value, which is net of previously recorded charge-offs.
            
Impaired Loans – Commercial  
            
 
Unpaid
Principal
Balance
 
Carrying
Value
 
Related
Allowance
 
Unpaid
Principal
Balance
 
Carrying
Value
 
Related
Allowance
(Dollars in millions)December 31, 2017 December 31, 2016
With no recorded allowance 
  
  
  
  
  
U.S. commercial$576
 $571
 $
 $860
 $827
 $
Non-U.S. commercial14
 11
 
 130
 130
 
Commercial real estate83
 80
 
 77
 71
 
With an allowance recorded           
U.S. commercial$1,393
 $1,109
 $98
 $2,018
 $1,569
 $132
Non-U.S. commercial528
 507
 58
 545
 432
 104
Commercial real estate133
 41
 4
 243
 96
 10
Commercial lease financing20
 18
 3
 6
 4
 
U.S. small business commercial (1)
84
 70
 27
 85
 73
 27
Total 
  
  
      
U.S. commercial$1,969
 $1,680
 $98
 $2,878
 $2,396
 $132
Non-U.S. commercial542
 518
 58
 675
 562
 104
Commercial real estate216
 121
 4
 320
 167
 10
Commercial lease financing20
 18
 3
 6
 4
 
U.S. small business commercial (1)
84
 70
 27
 85
 73
 27
            
 Average
Carrying
Value
 
Interest
Income
Recognized
(2)
 Average
Carrying
Value
 
Interest
Income
Recognized
(2)
 Average
Carrying
Value
 
Interest
Income
Recognized
(2)
 2017 2016 2015
With no recorded allowance 
  
  
  
    
U.S. commercial$772
 $12
 $787
 $14
 $688
 $14
Non-U.S. commercial46
 
 34
 1
 29
 1
Commercial real estate69
 1
 67
 
 75
 1
With an allowance recorded           
U.S. commercial$1,260
 $33
 $1,569
 $59
 $953
 $48
Non-U.S. commercial463
 13
 409
 14
 125
 7
Commercial real estate73
 2
 92
 4
 216
 7
Commercial lease financing8
 
 2
 
 
 
U.S. small business commercial (1)
73
 
 87
 1
 109
 1
Total 
  
  
  
    
U.S. commercial$2,032
 $45
 $2,356
 $73
 $1,641
 $62
Non-U.S. commercial509
 13
 443
 15
 154
 8
Commercial real estate142
 3
 159
 4
 291
 8
Commercial lease financing8
 
 2
 
 
 
U.S. small business commercial (1)
73
 
 87
 1
 109
 1
(1)
Includes U.S. small business commercial renegotiated TDR loans and related allowance.
(2)
Interest income recognized includes interest accrued and collected on the outstanding balances of accruing impaired loans as well as interest cash collections on nonaccruing impaired loans for which the principal is considered collectible.

Bank of America 2017136


The table below presents the December 31, 2017, 2016 and 2015 unpaid principal balance and carrying value of commercial loans that were modified as TDRs during 2017, 2016 and 2015, and net charge-offs that were recorded during the period in which the modification occurred. The table below includes loans that were initially classified as TDRs during the period and also loans that had previously been classified as TDRs and were modified again during the period.
    
Commercial – TDRs Entered into During 2017, 2016 and 2015
  
 Unpaid Principal Balance Carrying Value
(Dollars in millions)December 31, 2017
U.S. commercial$1,033
 $922
Non-U.S. commercial105
 105
Commercial real estate35
 24
Commercial lease financing20
 17
U.S. small business commercial (1)
13
 13
Total (2)
$1,206
 $1,081
    
 December 31, 2016
U.S. commercial$1,556
 $1,482
Non-U.S. commercial255
 253
Commercial real estate77
 77
Commercial lease financing6
 4
U.S. small business commercial (1)
1
 1
Total (2)
$1,895
 $1,817
    
 December 31, 2015
U.S. commercial$853
 $779
Non-U.S. commercial329
 326
Commercial real estate42
 42
U.S. small business commercial (1)
14
 11
Total (2)
$1,238
 $1,158
(1)
U.S. small business commercial TDRs are comprised of renegotiated small business card loans.
(2)
Net charge-offs were $138 million, $137 million and $31 million in 2017, 2016 and 2015, respectively.
A commercial TDR is generally deemed to be in payment default when the loan is 90 days or more past due, including delinquencies that were not resolved as part of the modification. U.S. small business commercial TDRs are deemed to be in payment default during the quarter in which a borrower misses the second of two consecutive payments. Payment defaults are one of the factors considered when projecting future cash flows, along with observable market prices or fair value of collateral when measuring the allowance for loan and lease losses. TDRs that were in payment
default had a carrying value of $64 million, $140 million and $105 million for U.S. commercial and $19 million, $34 million and $25 million for commercial real estate at December 31, 2017, 2016 and 2015, respectively.
Purchased Credit-impaired Loans
The table below shows activity for the accretable yield on PCI loans, which include the Countrywide Financial Corporation (Countrywide) portfolio and loans repurchased in connection with the 2013 settlement with FNMA. The amount of accretable yield is affected by changes in credit outlooks, including metrics such as default rates and loss severities, prepayment speeds, which can change the amount and period of time over which interest payments are expected to be received, and the interest rates on variable rate loans. The reclassifications from nonaccretable difference during 2017 and 2016 were primarily due to an increase in the expected principal and interest cash flows due to lower default estimates and rising interest rate environment.
   
Rollforward of Accretable Yield  
   
(Dollars in millions)  
Accretable yield, January 1, 2016 $4,569
Accretion (722)
Disposals/transfers (486)
Reclassifications from nonaccretable difference 444
Accretable yield, December 31, 2016 3,805
Accretion (601)
Disposals/transfers (634)
Reclassifications from nonaccretable difference 219
Accretable yield, December 31, 2017 $2,789
During 2017 and 2016, the Corporation sold PCI loans with a carrying value of $803 million and $549 million. For more information on PCI loans, see Note 1 – Summary of Significant Accounting Principles and for the carrying value and valuation allowance for PCI loans, see Note 5 – Allowance for Credit Losses.2019.
Loans Held-for-sale
The Corporation had LHFS of $11.4 billion and $9.1$9.2 billion at both December 31, 20172020 and 2016.2019. Cash and non-cash proceeds from sales and paydowns of loans originally classified as LHFS were $41.3$20.1 billion, $32.6$30.6 billion and $41.2$29.2 billion for 2017, 20162020, 2019 and 2015,2018, respectively. Cash used for originations and purchases of LHFS totaled $43.5approximately $19.7 billion, $33.1$28.9 billion and $37.9$28.1 billion for 2017, 20162020, 2019 and 2015,2018, 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, direct/indirect consumer and commercial loan balances 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 for credit losses is estimated using quantitative and qualitative methods that consider a variety of factors, such as historical loss experience, the current credit
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 reflected in the quantitative methods or the economic assumptions. The Corporation incorporates forward-looking information through the use of several macroeconomic 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 that 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.
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 requested deferrals that take into account their credit characteristics and payment behavior subsequent to deferral.
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.





137Bank of America 2017128




NOTE 5 Allowance for Credit Losses
The table below summarizes the changes in the allowance for credit losses, byincluding net charge-offs and provision for loan and lease losses, are detailed in the table below.
Consumer
Real Estate
Credit Card and
Other Consumer
CommercialTotal
(Dollars in millions)2020
Allowance for loan and lease losses, January 1$440 $7,430 $4,488 $12,358 
Loans and leases charged off(98)(3,646)(1,675)(5,419)
Recoveries of loans and leases previously charged off201 891 206 1,298 
Net charge-offs103 (2,755)(1,469)(4,121)
Provision for loan and lease losses307 4,538 5,720 10,565 
Other (1)
8 0 (8)0 
Allowance for loan and lease losses, December 31858 9,213 8,731 18,802 
Reserve for unfunded lending commitments, January 1119 0 1,004 1,123 
Provision for unfunded lending commitments18 0 737 755 
Reserve for unfunded lending commitments, December 31137 0 1,741 1,878 
Allowance for credit losses, December 31$995 $9,213 $10,472 $20,680 
2019
Allowance for loan and lease losses, January 1$928 $3,874 $4,799 $9,601 
Loans and leases charged off(522)(4,302)(822)(5,646)
Recoveries of loans and leases previously charged off927 911 160 1,998 
Net charge-offs405 (3,391)(662)(3,648)
Provision for loan and lease losses(680)3,512 742 3,574 
Other (1)
(107)(5)(111)
Allowance for loan and lease losses, December 31546 3,996 4,874 9,416 
Reserve for unfunded lending commitments, January 1797 797 
Provision for unfunded lending commitments16 16 
Reserve for unfunded lending commitments, December 31813 813 
Allowance for credit losses, December 31$546 $3,996 $5,687 $10,229 
2018
Allowance for loan and lease losses, January 1$1,720 $3,663 $5,010 $10,393 
Loans and leases charged off(690)(4,037)(675)(5,402)
Recoveries of loans and leases previously charged off664 823 152 1,639 
Net charge-offs(26)(3,214)(523)(3,763)
Provision for loan and lease losses(492)3,441 313 3,262 
Other (1)
(274)(16)(1)(291)
Allowance for loan and lease losses, December 31928 3,874 4,799 9,601 
Reserve for unfunded lending commitments, January 1777 777 
Provision for unfunded lending commitments20 20 
Reserve for unfunded lending commitments, December 31797 797 
Allowance for credit losses, December 31$928 $3,874 $5,596 $10,398 
(1)Primarily represents write-offs of purchased credit-impaired loans in 2019, and the net impact of portfolio segment for 2017, 2016sales, transfers to held-for-sale and 2015.transfers to foreclosed properties.
        
 
Consumer
Real Estate (1)
 Credit Card and Other Consumer Commercial 
Total
Allowance
(Dollars in millions)2017
Allowance for loan and lease losses, January 1$2,750
 $3,229
 $5,258
 $11,237
Loans and leases charged off(770) (3,774) (1,075) (5,619)
Recoveries of loans and leases previously charged off657
 809
 174
 1,640
Net charge-offs (2)
(113) (2,965) (901) (3,979)
Write-offs of PCI loans (3)
(207) 
 
 (207)
Provision for loan and lease losses (4)
(710) 3,437
 654
 3,381
Other (5)

 (38) (1) (39)
Allowance for loan and lease losses, December 31 
1,720
 3,663
 5,010
 10,393
Reserve for unfunded lending commitments, January 1
 
 762
 762
Provision for unfunded lending commitments
 
 15
 15
Reserve for unfunded lending commitments, December 31
 
 777
 777
Allowance for credit losses, December 31 
$1,720
 $3,663
 $5,787
 $11,170

 2016
Allowance for loan and lease losses, January 1$3,914
 $3,471
 $4,849
 $12,234
Loans and leases charged off(1,155) (3,553) (740) (5,448)
Recoveries of loans and leases previously charged off619
 770
 238
 1,627
Net charge-offs (2)
(536) (2,783) (502) (3,821)
Write-offs of PCI loans (3)
(340) 
 
 (340)
Provision for loan and lease losses (4)
(258) 2,826
 1,013
 3,581
Other (5)
(30) (42) (102) (174)
Total allowance for loan and lease losses, December 312,750
 3,472
 5,258
 11,480
Less: Allowance included in assets of business held for sale (6)

 (243) 
 (243)
Allowance for loan and lease losses, December 312,750
 3,229
 5,258
 11,237
Reserve for unfunded lending commitments, January 1
 
 646
 646
Provision for unfunded lending commitments
 
 16
 16
Other (5)

 
 100
 100
Reserve for unfunded lending commitments, December 31
 
 762
 762
Allowance for credit losses, December 31$2,750
 $3,229
 $6,020
 $11,999
 2015
Allowance for loan and lease losses, January 1$5,935
 $4,047
 $4,437
 $14,419
Loans and leases charged off(1,841) (3,620) (644) (6,105)
Recoveries of loans and leases previously charged off732
 813
 222
 1,767
Net charge-offs(1,109) (2,807) (422) (4,338)
Write-offs of PCI loans (3)
(808) 
 
 (808)
Provision for loan and lease losses (4)
(70) 2,278
 835
 3,043
Other (5)
(34) (47) (1) (82)
Allowance for loan and lease losses, December 313,914
 3,471
 4,849
 12,234
Reserve for unfunded lending commitments, January 1
 
 528
 528
Provision for unfunded lending commitments
 
 118
 118
Reserve for unfunded lending commitments, December 31
 
 646
 646
Allowance for credit losses, December 31$3,914
 $3,471
 $5,495
 $12,880
(1)
Includes valuation allowance associated with the PCI loan portfolio.
(2)
Includes net charge-offs related to the non-U.S. credit card loan portfolio, which was included in assets of business held for sale on the Consolidated Balance Sheet at December 31, 2016. In 2017, the Corporation sold its non-U.S. consumer credit card business.
(3)
Includes write-offs of $87 million, $60 million and $234 million associated with the sale of PCI loans in 2017, 2016 and 2015, respectively.
(4)
Includes provision expense of $76 million and a benefit of $45 million and $40 million associated with the PCI loan portfolio in 2017, 2016 and 2015, respectively.
(5)
Primarily represents 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 for loan and lease losses related to the non-U.S. credit card loan portfolio, which was sold in 2017.

Bank of America 2017138


The table below presents the allowance and the carrying value of outstanding loans and leases by portfolio segment at December 31, 2017 and 2016.
        
Allowance and Carrying Value by Portfolio Segment      
        
 Consumer
Real Estate
 Credit Card and Other Consumer Commercial Total
(Dollars in millions)December 31, 2017
Impaired loans and troubled debt restructurings (1)
 
  
  
  
Allowance for loan and lease losses (2)
$348
 $125
 $190
 $663
Carrying value (3)
12,554
 490
 2,407
 15,451
Allowance as a percentage of carrying value2.77% 25.51% 7.89% 4.29%
Loans collectively evaluated for impairment 
  
  
  
Allowance for loan and lease losses$1,083
 $3,538
 $4,820
 $9,441
Carrying value (3, 4)
238,284
 192,303
 474,284
 904,871
Allowance as a percentage of carrying value (4)
0.45% 1.84% 1.02% 1.04%
Purchased credit-impaired loans 
    
  
Valuation allowance$289
 n/a
 n/a
 $289
Carrying value gross of valuation allowance10,717
 n/a
 n/a
 10,717
Valuation allowance as a percentage of carrying value2.70% n/a
 n/a
 2.70%
Total 
  
  
  
Allowance for loan and lease losses$1,720
 $3,663
 $5,010
 $10,393
Carrying value (3, 4)
261,555
 192,793
 476,691
 931,039
Allowance as a percentage of carrying value (4)
0.66% 1.90% 1.05% 1.12%
 December 31, 2016
Impaired loans and troubled debt restructurings (1)
 
  
  
  
Allowance for loan and lease losses (2)
$356
 $189
 $273
 $818
Carrying value (3)
15,408
 610
 3,202
 19,220
Allowance as a percentage of carrying value2.31% 30.98% 8.53% 4.26%
Loans collectively evaluated for impairment 
  
  
  
Allowance for loan and lease losses$1,975
 $3,283
 $4,985
 $10,243
Carrying value (3, 4)
229,094
 197,470
 449,290
 875,854
Allowance as a percentage of carrying value (4)
0.86% 1.66% 1.11% 1.17%
Purchased credit-impaired loans 
    
  
Valuation allowance$419
 n/a
 n/a
 $419
Carrying value gross of valuation allowance13,738
 n/a
 n/a
 13,738
Valuation allowance as a percentage of carrying value3.05% n/a
 n/a
 3.05%
Less: Assets of business held for sale (5)
       
Allowance for loan and lease losses (6)
n/a
 $(243) n/a
 $(243)
Carrying value (3)
n/a
 (9,214) n/a
 (9,214)
Total 
  
  
  
Allowance for loan and lease losses$2,750
 $3,229
 $5,258
 $11,237
Carrying value (3, 4)
258,240
 188,866
 452,492
 899,598
Allowance as a percentage of carrying value (4)
1.06% 1.71% 1.16% 1.25%
(1)
Impaired loans include nonperforming commercial loans and all TDRs, including both commercial and consumer TDRs. Impaired loans exclude nonperforming consumer loans unless they are TDRs, and all consumer and commercial loans accounted for under the fair value option.
(2)
Allowance for loan and lease losses includes $27 million related to impaired U.S. small business commercial at both December 31, 2017 and 2016.
(3)
Amounts are presented gross of the allowance for loan and lease losses.
(4)
Outstanding loan and lease balances and ratios do not include loans accounted for under the fair value option of $5.7 billion and $7.1 billion at December 31, 2017 and 2016.
(5)
Represents allowance for loan and lease losses and loans related to the non-U.S. credit card loan portfolio, which was included in assets of business held for sale on the Consolidated Balance Sheet at December 31, 2016. In 2017, the Corporation sold its non-U.S. consumer credit card business.
(6)
Includes $61 million of allowance for loan and lease losses related to impaired loans and TDRs and $182 million related to loans collectively evaluated for impairment at December 31, 2016.
n/a = not applicable


139Bank of America 2017



NOTE 6Securitizations 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.Principles.
The tables in this Note present the assets and liabilities of consolidated and unconsolidated VIEs at December 31, 20172020 and 20162019 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, 20172020 and 20162019 resulting from its involvement with consolidated VIEs and unconsolidated VIEs in which the Corporation holds a variable interest. The Corporation’s maximum loss exposure is based on the unlikely event that all of the assets in the VIEs become worthless and incorporates not only potential losses associated with assets recorded on the Consolidated Balance Sheet but also potential losses associated with off-balance sheet commitments, such as unfunded liquidity commitments and other contractual arrangements. The Corporation’s maximum loss exposure does not include losses previously recognized through write-downs of assets.
The Corporation invests in ABS issued by third-party VIEs with which it has no other form of involvement and enters into certain commercial lending arrangements that may also incorporate the
use of VIEs, for example to hold collateral. These securities and loans are included in Note 34 – Securities or Note 45 – Outstanding Loans and Leases.Leases and Allowance for Credit Losses. In addition, the Corporation useshas used VIEs such as trust preferred securities trusts in connection with its funding activities. For more information, see Note 11 – Long-term Debt. These VIEs, which are generally not consolidated by the Corporation, as applicable, are not included in the tables herein.
Except as described below, the
129 Bank of America


The Corporation did not provide financial support to consolidated or unconsolidated VIEs during 2017, 20162020, 2019 and 20152018 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
First-lien Mortgages
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 RMBSresidential mortgage-backed securities (RMBS) guaranteed by government-sponsored enterprises, FNMA and FHLMC (collectively the GSEs), or the Government National Mortgage Association (GNMA) primarily in the case of FHA-insuredFHA-
insured and U.S. Department of Veterans Affairs (VA)-guaranteed mortgage loans. Securitization usually occurs in conjunction with or shortly after origination or purchase, and the Corporation may also securitize loans held in its residential mortgage portfolio. In addition, the Corporation may, from time to time, securitize commercial mortgages it originates or purchases from other entities. The Corporation typically services the loans it securitizes. Further, the Corporation may retain beneficial interests in the securitization trusts including senior and subordinate securities and equity tranches issued by the trusts. Except as described belowin Note 12 – Commitments and in Note 7 – Representations and Warranties Obligations and Corporate GuaranteesContingencies, 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 2017, 20162020, 2019 and 2015.2018.
First-lien Mortgage Securitizations
 
Residential Mortgage - AgencyCommercial Mortgage
(Dollars in millions)202020192018202020192018
Proceeds from loan sales (1)
$15,823 $6,858 $5,801 $5,084 $8,661 $6,991 
Gains on securitizations (2)
728 27 62 61 103 101 
Repurchases from securitization trusts (3)
436 881 1,485 0 
            
First-lien Mortgage Securitizations          
 Residential Mortgage - Agency Commercial Mortgage
(Dollars in millions)2017 2016 2015 2017 2016 2015
Cash proceeds from new securitizations (1)
$14,467
 $24,201
 $27,164
 $5,641
 $3,887
 $7,945
Gains on securitizations (2)
158
 370
 894
 91
 38
 49
Repurchases from securitization trusts (3)
2,713
 3,611
 3,716
 
 
 
(1)
(1)The Corporation transfers residential mortgage loans to securitizations sponsored primarily by the GSEs or GNMA in the normal course of business and receives RMBS in exchange which may then be sold into the market to third-party investors for cash proceeds.
(2)
A majority of the first-lien residential mortgage loans securitized are initially classified as LHFS and accounted for under the fair value option. Gains recognized on these LHFS prior to securitization, which totaled $243 million, $487 million and $750 million net of hedges, during 2017, 2016 and 2015, respectively, are not included in the table above.
(3)
The Corporation may have the option to repurchase delinquent loans out of securitization trusts, which reduces the amount of servicing advances it is required to make. The Corporation may also repurchase loans from securitization trusts to perform modifications. Repurchased loans include FHA-insured mortgages collateralizing GNMA securities.
In addition to cash proceeds as reported in the table above, the Corporation received securities with an initial fair valuenormal course of $1.9 billion, $4.2 billionbusiness and $22.3 billionprimarily receives RMBS in connection with first-lien mortgage securitizations in 2017, 2016 and 2015. The receipt of these securities represents non-cash operating and investing activities and, accordingly, is not reflected in the Consolidated Statement of Cash Flows.exchange. Substantially all of these securities were initiallyare classified as Level 2 assets within the fair value hierarchy. During 2017, 2016hierarchy and 2015, there were no changesare 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 initial classification.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.
Bank of America 2017140


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 $277.6$160.4 billion and $326.2$192.1 billion at December 31, 20172020 and 2016.2019. Servicing fee and ancillary fee income on serviced loans was $893$474 million, $1.2 billion$585 million and $1.4 billion in 2017, 2016$710 million during 2020, 2019 and 2015.2018, respectively. Servicing advances on serviced loans, including loans serviced for others and loans held for investment, were $4.5$2.2 billion and $6.2$2.4 billion at December 31, 20172020 and 2016.2019. For more information on MSRs, see Note 20 – Fair Value Measurements.
During 2016 and 2015,2020, the Corporation deconsolidated agency residential mortgage securitization vehicles with total assets of $3.8 billion and $4.5 billion, and total liabilities of $628
million and $0 followingcompleted the sale of retained interests to third parties, after which$9.3 billion of consumer real estate loans through GNMA loan securitizations. As part of the securitizations, the Corporation no longer had the unilateral ability to liquidate the vehicles. Of the balances deconsolidated in 2016, $706 millionretained $8.4 billion of assets and $628 million of liabilities represent non-cash investing and financing activities and, accordingly,MBS, which are not reflectedclassified as debt securities carried at fair value on the Consolidated StatementBalance Sheet. Total gains on loan sales of Cash Flows. Gains on sale of $125$704 million and $287 million in 2016 and 2015 related to these deconsolidations were recorded in other income in the Consolidated Statement of Income. There were no deconsolidations of agency residential mortgage securitizations in 2017.
The following table below summarizes select information related to first-lien mortgage securitization trusts in which the Corporation held a variable interest at December 31, 20172020 and 2016.2019.
               
First-lien Mortgage VIEs           
 Residential Mortgage  
 
  
 
 Non-agency  
 
 Agency Prime Subprime Alt-A Commercial Mortgage
 December 31
(Dollars in millions)20172016 20172016 20172016 20172016 20172016
Unconsolidated VIEs 
 
  
 
  
 
  
 
  
 
Maximum loss exposure (1)
$19,110
$22,661
 $689
$757
 $2,643
$2,750
 $403
$560
 $585
$344
On-balance sheet assets 
 
  
 
  
 
  
 
  
 
Senior securities: 
 
  
 
  
 
  
 
  
 
Trading account assets$716
$1,399
 $6
$20
 $10
$112
 $50
$118
 $108
$51
Debt securities carried at fair value15,036
17,620
 477
441
 2,221
2,235
 351
305
 

Held-to-maturity securities3,348
3,630
 

 

 

 274
64
Subordinate securities

 5
9
 38
25
 2
24
 69
81
Residual interests

 

 

 

 19
25
All other assets (2)
10
12
 
28
 

 
113
 

Total retained positions$19,110
$22,661
 $488
$498
 $2,269
$2,372
 $403
$560
 $470
$221
Principal balance outstanding (3)
$232,761
$265,332
 $10,549
$16,280
 $10,254
$19,373
 $28,129
$35,788
 $26,504
$23,826
               
Consolidated VIEs 
 
  
 
  
 
  
 
  
 
Maximum loss exposure (1)
$14,502
$18,084
 $571
$
 $
$
 $
$25
 $
$
On-balance sheet assets 
 
  
 
  
 
  
 
  
 
Trading account assets$232
$434
 $571
$
 $
$
 $
$99
 $
$
Loans and leases, net14,030
17,223
 

 

 

 

All other assets240
427
 

 

 

 

Total assets$14,502
$18,084
 $571
$
 $
$
 $
$99
 $
$
On-balance sheet liabilities 
 
  
 
  
 
  
 
  
 
Long-term debt$
$
 $
$
 $
$
 $
$74
 $
$
All other liabilities3
4
 

 

 

 

Total liabilities$3
$4
 $
$
 $
$
 $
$74
 $
$
(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 7 – Representations and Warranties Obligations and Corporate Guarantees and Note 20 – Fair Value Measurements.
(2)
Not included in the table above are all other assets of $148 million and $189 million, representing the unpaid principal balance of mortgage loans eligible for repurchase from unconsolidated residential mortgage securitization vehicles, principally guaranteed by GNMA, and all other liabilities of $148 million and $189 million, representing the principal amount that would be payable to the securitization vehicles if the Corporation was to exercise the repurchase option, at December 31, 2017 and 2016.
(3)
Principal balance outstanding includes loans where the Corporation was the transferor to securitization vehicles with which it has continuing involvement, which may include servicing the loans.

141Bank of America 2017130





First-lien Mortgage VIEs
Residential Mortgage  
   Non-agency  
 AgencyPrimeSubprimeAlt-ACommercial Mortgage
 December 31
(Dollars in millions)2020201920202019202020192020201920202019
Unconsolidated VIEs          
Maximum loss exposure (1)
$13,477 $12,554 $250 $340 $1,031 $1,622 $46 $98 $1,169 $1,036 
On-balance sheet assets          
Senior securities:          
Trading account assets$152 $627 $2 $$8 $54 $12 $24 $60 $65 
Debt securities carried at fair value7,588 6,392 103 193 676 1,178 33 72 0 
Held-to-maturity securities5,737 5,535 0 0 0 925 809 
All other assets0 6 26 49 1 50 38 
Total retained positions$13,477 $12,554 $111 $200 $710 $1,281 $46 $98 $1,035 $912 
Principal balance outstanding (2)
$133,497 $160,226 $6,081 $7,268 $6,691 $8,594 $16,554 $19,878 $59,268 $60,129 
Consolidated VIEs          
Maximum loss exposure (1)
$1,328 $10,857 $66 $$53 $44 $0 $$0 $
On-balance sheet assets          
Trading account assets$1,328 $780 $350 $116 $260 $149 $0 $$0 $
Loans and leases, net0 9,917 0 0 0 0 
All other assets0 161 0 0 0 0 
Total assets$1,328 $10,858 $350 $116 $260 $149 $0 $$0 $
Total liabilities$0 $$284 $111 $207 $105 $0 $$0 $
(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 below summarizes select information related to home equity, loan, credit card and other asset-backed VIEs in which the Corporation held a variable interest at December 31, 20172020 and 2016.2019.
Home Equity Loan, Credit Card and Other Asset-backed VIEs
 
Home Equity (1)
Credit Card (2)
Resecuritization TrustsMunicipal Bond Trusts
 December 31
(Dollars in millions)20202019202020192020201920202019
Unconsolidated VIEs      
Maximum loss exposure$206 $412 $0 $$8,543 $7,526 $3,507 $3,701 
On-balance sheet assets      
Securities (3):
      
Trading account assets$0 $$0 $$948 $2,188 $0 $
Debt securities carried at fair value2 11 0 2,727 1,126 0 
Held-to-maturity securities0 0 4,868 4,212 0 
Total retained positions$2 $11 $0 $$8,543 $7,526 $0 $
Total assets of VIEs$609 $1,023 $0 $$17,250 $21,234 $4,042 $4,395 
Consolidated VIEs      
Maximum loss exposure$58 $64 $14,606 $17,915 $217 $54 $1,030 $2,656 
On-balance sheet assets      
Trading account assets$0 $$0 $$217 $73 $990 $2,480 
Loans and leases218 122 21,310 26,985 0 0 
Allowance for loan and lease losses14 (2)(1,704)(800)0 0 
All other assets4 1,289 119 0 40 176 
Total assets$236 $123 $20,895 $26,304 $217 $73 $1,030 $2,656 
On-balance sheet liabilities      
Short-term borrowings$0 $$0 $$0 $$432 $2,175 
Long-term debt178 64 6,273 8,372 0 19 0 
All other liabilities0 16 17 0 0 
Total liabilities$178 $64 $6,289 $8,389 $0 $19 $432 $2,175 
            
Home Equity Loan, Credit Card and Other Asset-backed VIEs    
         
 
Home Equity Loan (1)
 
Credit Card (2, 3)
 Resecuritization Trusts Municipal Bond Trusts
 December 31
(Dollars in millions)20172016 20172016 20172016 20172016
Unconsolidated VIEs 
 
     
 
  
 
Maximum loss exposure$1,522
$2,732
 $
$
 $8,204
$9,906
 $1,631
$1,635
On-balance sheet assets 
 
     
 
  
 
Senior securities (4):
 
 
     
 
  
 
Trading account assets$
$
 $
$
 $869
$902
 $33
$
Debt securities carried at fair value36
46
 

 1,661
2,338
 

Held-to-maturity securities

 

 5,644
6,569
 

Subordinate securities (4)


 

 30
97
 

Total retained positions$36
$46
 $
$
 $8,204
$9,906
 $33
$
Total assets of VIEs (5)
$2,432
$4,274
 $
$
 $19,281
$22,155
 $2,287
$2,406
            
Consolidated VIEs 
 
     
 
  
 
Maximum loss exposure$112
$149
 $24,337
$25,859
 $628
$420
 $1,453
$1,442
On-balance sheet assets 
 
     
 
  
 
Trading account assets$
$
 $
$
 $1,557
$1,428
 $1,452
$1,454
Loans and leases177
244
 32,554
35,135
 

 

Allowance for loan and lease losses(9)(16) (988)(1,007) 

 

All other assets6
7
 1,385
793
 

 1

Total assets$174
$235
 $32,951
$34,921
 $1,557
$1,428
 $1,453
$1,454
On-balance sheet liabilities 
 
     
 
  
 
Short-term borrowings$
$
 $
$
 $
$
 $312
$348
Long-term debt76
108
 8,598
9,049
 929
1,008
 
12
All other liabilities

 16
13
 

 

Total liabilities$76
$108
 $8,614
$9,062
 $929
$1,008
 $312
$360
(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.
(1)
(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).
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 7 – Representations and Warranties Obligations and Corporate Guarantees.
(2)
At December 31, 2017 and 2016, loans and leases in the consolidated credit card trust included $15.6 billion and $17.6 billion of seller’s interest.
(3)
At December 31, 2017 and 2016, all other assets in the consolidated credit card trust included restricted cash, certain short-term investments, and unbilled accrued interest and fees.
(4)
The retained senior and subordinate securities were valued using quoted market prices or observable market inputs (Level 2 of the fair value hierarchy).
(5)
Total assets include loans the Corporation transferred with which it has continuing involvement, which may include servicing the loan.
Home Equity Loans
The Corporation retains interests, primarily senior securities, in home equity securitization trusts to which it transferred home equity loans. These retained interests primarily include senior securities. 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
131 Bank of America


events depend on the undrawn portion of the home equity lines of credit (HELOCs),HELOCs, performance of the loans, the amount of subsequent draws and the timing of related cash flows.
During 2015, the Corporation deconsolidated several HELOC trusts with total assets of $488 million and total liabilities of $611 million as its obligation to provide subordinated funding is no longer considered to be a potentially significant variable interest in the trusts following a decline in the amount of credit available to be drawn by borrowers. In connection with deconsolidation, the Corporation recorded a gain of $123 million in other income in the Consolidated Statement of Income. The derecognition of assets and liabilities represents non-cash investing and financing activities and, accordingly, is not reflected on the Consolidated Statement of Cash Flows. There were no deconsolidations of HELOC trusts in 2017 or 2016.
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 2017, 20162020, 2019 and 2015, 2018, the Corporation issued new senior debt securities issued to third-party investors from the credit card securitization trust were $3.1of $1.0 billion, $750 million$1.3 billion and $2.3 billion.$4.0 billion, respectively.
At December 31, 20172020 and 2016,2019, the Corporation held subordinate securities issued by the credit card securitization trust with a notional principal amount of $7.4$6.8 billion and $7.5$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.0 percent. During 2017, 20162020, 2019 and 2015,2018, the credit card securitization trust issued $500$161 million, $121$202 million and $371$650 million, respectively, of these subordinate securities.


Bank of America 2017142


Resecuritization Trusts
The Corporation transfers securities, typically MBS, into resecuritization vehiclesVIEs 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.
The Corporation resecuritized $25.1$39.0 billion, $23.4$24.4 billion and $30.7$22.8 billion of securities in 2017, 2016during 2020, 2019 and 2015.2018, respectively. Securities transferred into resecuritization vehicles during 2017, 2016 and 2015VIEs were measured at fair value with changes in fair value recorded
in trading account profitsmarket making and similar activities prior to the resecuritization and, accordingly, no gain or loss on sale was recorded. During 2017, 2016 and 2015,Securities received from the resecuritization proceeds included securities with an initialVIEs were recognized at their fair value of $3.3$6.1 billion, $3.3$5.2 billion and $9.8$4.1 billion including $6.9 billion whichduring 2020, 2019 and 2018, respectively. In 2019 and 2018, substantially all of the securities were classified as HTM during 2015. Substantially alltrading account assets. All of the other 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 fair value and HTM securities, respectively. 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 $1.6$3.5 billion and $3.7 billion at both December 31, 20172020 and 2016.2019. The weighted-average remaining life of bonds held in the trusts at December 31, 20172020 was 6.06.8 years. There were no materialsignificant write-downs or downgrades of assets or issuers during 2017, 20162020, 2019 and 2015.2018.
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, 20172020 and 2016.2019.
Other VIEs
ConsolidatedUnconsolidatedTotalConsolidatedUnconsolidatedTotal
(Dollars in millions)December 31, 2020December 31, 2019
Maximum loss exposure (1)
$4,106 $23,870 $27,976 $4,055 $21,069 $25,124 
On-balance sheet assets      
Trading account assets (1)
$2,080 $623 $2,703 $2,213 $549 $2,762 
Debt securities carried at fair value (1)
0 9 9 10 10 
Loans and leases (1)
2,108 184 2,292 1,810 533 2,343 
Allowance for loan and lease losses (1)
(3)(3)(6)(2)(2)
All other assets (1)
54 22,553 22,607 81 19,354 19,435 
Total (1)
$4,239 $23,366 $27,605 $4,102 $20,446 $24,548 
On-balance sheet liabilities      
Short-term borrowings$22 $0 $22 $$$
Long-term debt111 0 111 46 46 
All other liabilities (1)
0 5,658 5,658 4,896 4,898 
Total (1)
$133 $5,658 $5,791 $48 $4,896 $4,944 
Total assets of VIEs (1)
$4,239 $77,984 $82,223 $4,102 $70,120 $74,222 
            
Other VIEs        
    
 Consolidated Unconsolidated Total Consolidated Unconsolidated Total
 December 31
(Dollars in millions)2017 2016
Maximum loss exposure$4,660
 $19,785
 $24,445
 $6,114
 $17,754
 $23,868
On-balance sheet assets 
  
  
  
  
  
Trading account assets$2,709
 $346
 $3,055
 $2,358
 $233
 $2,591
Debt securities carried at fair value
 160
 160
 
 122
 122
Loans and leases2,152
 3,596
 5,748
 3,399
 3,249
 6,648
Allowance for loan and lease losses(3) (32) (35) (9) (24) (33)
Loans held-for-sale27
 940
 967
 188
 464
 652
All other assets62
 14,276
 14,338
 369
 13,156
 13,525
Total$4,947
 $19,286
 $24,233
 $6,305
 $17,200
 $23,505
On-balance sheet liabilities 
  
  
  
  
  
Long-term debt (1)
$270
 $
 $270
 $395
 $
 $395
All other liabilities18
 3,417
 3,435
 24
 2,959
 2,983
Total$288
 $3,417
 $3,705
 $419
 $2,959
 $3,378
Total assets of VIEs$4,947
 $69,746
 $74,693
 $6,305
 $62,269
 $68,574
(1)Prior-period amounts have been revised to remove certain entities that are no longer considered VIEs.
(1)
Includes $1 million and $229 million of long-term debt at December 31, 2017 and 2016 issued by other consolidated VIEs, which has recourse to the general credit of the Corporation.
Customer VehiclesVIEs
Customer vehiclesVIEs include credit-linked, equity-linked and commodity-linked note vehicles,VIEs, repackaging vehicles,VIEs and asset acquisition vehicles,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 vehiclesVIEs totaled $2.3 billion and $2.9$2.2 billion at December 31, 20172020 and 2016,2019, including the notional amount of derivatives to which the Corporation is a counterparty, net of losses previously recorded, and the
Corporation’s investment, if any, in securities issued by the vehicles. The Corporation also had liquidity commitments, including written put options and collateral value guarantees, with certain unconsolidated vehicles of $442 million and $323 million at December 31, 2017 and 2016, that are included in the table above.VIEs.
Collateralized Debt Obligation VehiclesVIEs
The Corporation receives fees for structuring CDO vehicles,VIEs, which hold diversified pools of fixed-income securities, typically corporate debt or ABS, which the CDO vehiclesVIEs 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
Bank of America 132


counterparty to the CDOs. The Corporation’s maximum loss exposure to consolidated and unconsolidated CDOs totaled $358$298 million and $430$304 million at December 31, 20172020 and 2016.2019.
Investment VehiclesVIEs
The Corporation sponsors, invests in or provides financing, which may be in connection with the sale of assets, to a variety of investment vehiclesVIEs 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, 20172020 and 2016,2019, the Corporation’s consolidated investment vehiclesVIEs had total assets of $249$494 million and $846 million.$104 million. The Corporation also held investments in unconsolidated vehiclesVIEs with total assets of $20.3$5.4 billion and $17.3$5.1 billion at December 31, 20172020 and 2016.2019. The Corporation’s maximum loss exposure associated with both consolidated and unconsolidated investment vehiclesVIEs totaled $5.7$1.5 billion and $5.1$1.6 billion at December 31, 20172020 and 20162019 comprised primarily of on-balance sheet assets less non-recourse liabilities.
In prior periods, the Corporation transferred servicing advance receivables to independent third parties in connection with the sale of MSRs. Portions of the receivables were transferred into unconsolidated securitization trusts. The Corporation retained senior interests in such receivables with a maximum loss exposure and funding obligation of $50 million and $150 million,

143Bank of America 2017



including a funded balance of $39 million and $75 million at December 31, 2017 and 2016, which were classified in other debt securities carried at fair value.
Leveraged Lease Trusts
The Corporation’s net investment in consolidated leveraged lease trusts totaled $2.0 billion and $2.6$1.7 billion at both December 31, 20172020 and 2016.2019. 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 VehiclesVIEs
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 vehicle.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 $13.8$22.0 billion and $12.6$18.9 billion at December 31, 20172020 and 2016.2019. 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 investments in affordable housing partnerships, which are reported in other assets on the Consolidated Balance Sheet, totaled $8.0$11.2 billion and $7.4$10.0 billion, including unfunded commitments to provide capital contributions of $3.1$5.0 billion and $2.7$4.3 billion at December 31, 20172020 and 2016.2019. The unfunded commitments are expected to be paid over the next 5five years. During 2017, 20162020, 2019 and 2015,2018, the Corporation recognized tax credits and other tax

benefits from investments in affordable housing partnerships of $1.2 billion, $1.0 billion $1.1 billion and $928$981 million and reported pre-taxpretax losses in other noninterest income of $766 million, $789$1.0 billion, $882 million and $629$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 7Goodwill 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
December 31
(Dollars in millions)December 31
2020
December 31
2019
Consumer Banking$30,123 $30,123 
Global Wealth & Investment Management9,677 9,677 
Global Banking23,923 23,923 
Global Markets5,182 5,182 
All Other46 46 
Total goodwill$68,951 $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 0 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.
133 Bank of America


NOTE 8 Leases
The Corporation enters into both lessor and lessee arrangements. For more information on lease accounting, see Note 1 – Summary of Significant Accounting Principles and on lease financing receivables, see Note 5 – Outstanding Loans and Leases and Allowance for Credit Losses.
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.
Net Investment (1)
December 31
(Dollars in millions)20202019
Lease receivables$17,627 $19,312 
Unguaranteed residuals2,303 2,550 
   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.
The following table presents lease income at December 31, 2020 and 2019.
Lease Income
December 31
(Dollars in millions)20202019
Sales-type and direct financing leases$707 $797 
Operating leases931 891 
   Total lease income$1,638 $1,688 
Lessee Arrangements
The Corporation's lessee arrangements predominantly consist of operating leases for premises and equipment; the Corporation's financing leases are not significant.
Lease terms may contain renewal and extension options and early termination features. Generally, these options do not impact the lease term because the Corporation is not reasonably certain that it will exercise the options.
The 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.
Lessee Arrangements
December 31
(Dollars in millions)20202019
Right-of-use asset$10,000 $9,735 
Lease liabilities10,474 10,093 
Weighted-average discount rate used to calculate present value of future minimum lease payments3.38 %3.68 %
Weighted-average lease term (in years)8.48.2
Lease Cost and Supplemental Information:
Operating lease cost$2,149 $2,085 
Variable lease cost (1)
474 498 
   Total lease cost (2)
$2,623 $2,583 
Right-of-use assets obtained in exchange for
new operating lease liabilities (3)
$851 $931 
Operating cash flows from operating
    leases (4)
2,039 2,009 
(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.
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.
Maturities of Lessor and Lessee Arrangements
Lessor
Lessee (1)
Operating
Leases
Sales-type and
Direct Financing
Leases (2)
Operating
Leases
(Dollars in millions)December 31, 2020
2021$843 $5,424 $1,927 
2022748 4,934 1,715 
2023630 3,637 1,454 
2024479 2,089 1,308 
2025339 1,143 1,087 
Thereafter886 1,668 4,609 
Total undiscounted
cash flows
$3,925 18,895 12,100 
Less: Net present
value adjustment
1,268 1,626 
Total (3)
$17,627 $10,474 
(1)Excludes $885 million in commitments under lessee arrangements that have not yet commenced with lease terms that will begin in 2021.
(2)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
December 31, 2020December 31
2019
(Dollars in millions)Three Months
or Less
Over Three
Months to
Twelve Months
ThereafterTotalTotal
U.S. certificates of deposit and other time deposits$12,485 $10,668 $1,445 $24,598 $39,739 
Non-U.S. certificates of deposit and other time deposits8,568 1,925 1,432 11,925 13,034 
Bank of America 134


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)U.S.Non-U.S.Total
Due in 2021$40,052 $10,609 $50,661 
Due in 20222,604 167 2,771 
Due in 2023431 435 
Due in 2024222 227 
Due in 2025186 13 199 
Thereafter276 1,287 1,563 
Total time deposits$43,771 $12,085 $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.
AmountRateAmountRate
(Dollars in millions)20202019
Federal funds sold and securities borrowed or purchased under agreements to resell
Average during year$309,945 0.29 %$279,610 1.73 %
Maximum month-end balance during year451,179 n/a281,684 n/a
Federal funds purchased and securities loaned or sold under agreements to repurchase
Average during year$192,479 0.69 %$201,797 2.31 %
Maximum month-end balance during year206,493 n/a203,063 n/a
Short-term borrowings
Average during year22,486 0.54 24,301 2.42 
Maximum month-end balance during year30,118 n/a36,538 n/a
n/a = not applicable
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 repurchase agreements or legally enforceable master securities lending agreements that give the Corporation, in the event of default by the counterparty, the right
to liquidate securities held and to offset receivables and payables with the same counterparty. The Corporation offsets securities financing transactions with the same counterparty on the Consolidated Balance Sheet where it has such a legally enforceable master netting agreement and the transactions have the same maturity date.
The Securities Financing Agreements table presents securities financing agreements included on the Consolidated Balance Sheet in federal funds sold and securities borrowed or purchased under agreements to resell, and in federal funds purchased and securities loaned or sold under agreements to repurchase at December 31, 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.
135 Bank of America


Securities Financing Agreements
Gross Assets/Liabilities (1)
Amounts OffsetNet Balance Sheet Amount
Financial Instruments (2)
Net Assets/Liabilities
(Dollars in millions)December 31, 2020
Securities borrowed or purchased under agreements to resell (3)
$492,387 $(188,329)$304,058 $(272,351)$31,707 
Securities loaned or sold under agreements to repurchase$358,652 $(188,329)$170,323 $(158,867)$11,456 
Other (4)
16,210 0 16,210 (16,210)0 
Total$374,862 $(188,329)$186,533 $(175,077)$11,456 
December 31, 2019
Securities borrowed or purchased under agreements to resell (3)
$434,257 $(159,660)$274,597 $(244,486)$30,111 
Securities loaned or sold under agreements to repurchase$324,769 $(159,660)$165,109 $(141,482)$23,627 
Other (4)
15,346 15,346 (15,346)
Total$340,115 $(159,660)$180,455 $(156,828)$23,627 
(1)Includes activity where uncertainty exists as to the enforceability of certain master netting agreements under bankruptcy laws in some countries or industries.
(2)Includes securities collateral received or pledged under repurchase or securities lending agreements where there is a legally enforceable master netting agreement. These amounts are not offset on the Consolidated Balance Sheet, but are shown as a reduction to derive a net asset or liability. Securities collateral received or pledged where the legal enforceability of the master netting agreements is uncertain is excluded from the table.
(3)Excludes repurchase activity of $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
Overnight and Continuous30 Days or LessAfter 30 Days Through 90 Days
Greater than
90 Days (1)
Total
(Dollars in millions)December 31, 2020
Securities sold under agreements to repurchase$158,400 $122,448 $32,149 $22,684 $335,681 
Securities loaned19,140 271 1,029 2,531 22,971 
Other16,210 0 0 0 16,210 
Total$193,750 $122,719 $33,178 $25,215 $374,862 
December 31, 2019
Securities sold under agreements to repurchase$129,455 $122,685 $25,322 $21,922 $299,384 
Securities loaned18,766 3,329 1,241 2,049 25,385 
Other15,346 15,346 
Total$163,567 $126,014 $26,563 $23,971 $340,115 
(1)NaN agreements have maturities greater than three years.
Class of Collateral Pledged
Securities Sold Under Agreements to RepurchaseSecurities
Loaned
OtherTotal
(Dollars in millions)December 31, 2020
U.S. government and agency securities$195,167 $5 $0 $195,172 
Corporate securities, trading loans and other8,633 1,628 1,217 11,478 
Equity securities14,752 21,125 14,931 50,808 
Non-U.S. sovereign debt113,142 213 62 113,417 
Mortgage trading loans and ABS3,987 0 0 3,987 
Total$335,681 $22,971 $16,210 $374,862 
December 31, 2019
U.S. government and agency securities$173,533 $$$173,534 
Corporate securities, trading loans and other10,467 2,014 258 12,739 
Equity securities14,933 20,026 15,024 49,983 
Non-U.S. sovereign debt96,576 3,344 64 99,984 
Mortgage trading loans and ABS3,875 3,875 
Total$299,384 $25,385 $15,346 $340,115 
Bank of America 136


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.
Weighted-average RateDecember 31
(Dollars in millions)Interest RatesMaturity Dates20202019
Notes issued by Bank of America Corporation (1)
  
Senior notes:  
Fixed3.05 %0.25 - 8.05%2021 - 2051$174,385 $140,265 
Floating0.74 0.09 - 4.962021 - 204416,788 19,552 
Senior structured notes17,033 16,941 
Subordinated notes:
Fixed4.89 2.94 - 8.572021 - 204523,337 21,632 
Floating1.15 0.88 - 1.412022 - 2026799 782 
Junior subordinated notes:
Fixed6.71 6.45 - 8.052027 - 2066738 736 
Floating1.03 1.03 20561 
Total notes issued by Bank of America Corporation233,081 199,909 
Notes issued by Bank of America, N.A.  
Senior notes:  
Fixed3.34 3.34 2023511 508 
Floating0.33 0.28 - 0.492021 - 20412,323 6,519 
Subordinated notes6.00 6.00 20361,883 1,744 
Advances from Federal Home Loan Banks:
Fixed0.99 0.01 - 7.722021 - 2034599 112 
Floating0 2,500 
Securitizations and other BANA VIEs (2)
6,296 8,373 
Other683 402 
Total notes issued by Bank of America, N.A.12,295 20,158 
Other debt  
Structured liabilities16,792 20,442 
Nonbank VIEs (2)
757 347 
Other9 
Total notes issued by nonbank and other entities17,558 20,789 
Total long-term debt$262,934 $240,856 
(1)Includes total loss-absorbing capacity compliant debt.
(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.
137 Bank of America


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
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 repayment terms linked to the performance of debt or equity securities, indices, currencies or commodities, and the maturity may be accelerated based on the value of a referenced index or security. In both cases, the Corporation or a subsidiary may be required to settle the obligation for cash or other securities prior to the contractual maturity date. These borrowings are reflected in the table as maturing at their contractual maturity date.
Long-term Debt by Maturity
(Dollars in millions)20212022202320242025ThereafterTotal
Bank of America Corporation
Senior notes$8,888 $15,380 $23,872 $21,407 $15,723 $105,903 $191,173 
Senior structured notes469 2,034 597 190 549 13,194 17,033 
Subordinated notes371 393 3,351 5,537 14,484 24,136 
Junior subordinated notes739 739 
Total Bank of America Corporation9,728 17,807 24,469 24,948 21,809 134,320 233,081 
Bank of America, N.A.
Senior notes1,340 975 511 2,834 
Subordinated notes1,883 1,883 
Advances from Federal Home Loan Banks502 18 75 599 
Securitizations and other Bank VIEs (1)
4,056 1,241 977 22 6,296 
Other112 16 189 279 87 683 
Total Bank of America, N.A.6,010 2,235 1,678 297 2,075 12,295 
Other debt
Structured Liabilities4,613 2,414 2,221 655 859 6,030 16,792 
Nonbank VIEs (1)
756 757 
Other9 
Total other debt4,614 2,414 2,221 655 859 6,795 17,558 
Total long-term debt$20,352 $22,456 $28,368 $25,603 $22,965 $143,190 $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.
Legally binding commitments to extend credit generally have specified rates and maturities. Certain of these commitments have adverse change clauses that help to protect the Corporation against deterioration in the borrower’s ability to pay.
The table below includes 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.
Bank of America 138


Credit Extension Commitments
Expire in One
Year or Less
Expire After One
Year Through
Three Years
Expire After Three Years Through
Five Years
Expire After
Five Years
Total
(Dollars in millions)December 31, 2020
Notional amount of credit extension commitments     
Loan commitments (1)
$109,406 $171,887 $139,508 $16,091 $436,892 
Home equity lines of credit710 2,992 8,738 29,892 42,332 
Standby letters of credit and financial guarantees (2)
19,962 12,038 2,397 1,257 35,654 
Letters of credit (3)
886 197 25 27 1,135 
Legally binding commitments130,964 187,114 150,668 47,267 516,013 
Credit card lines (4)
384,955 0 0 0 384,955 
Total credit extension commitments$515,919 $187,114 $150,668 $47,267 $900,968 
 December 31, 2019
Notional amount of credit extension commitments     
Loan commitments (1)
$97,454 $148,000 $173,699 $24,487 $443,640 
Home equity lines of credit1,137 1,948 6,351 34,134 43,570 
Standby letters of credit and financial guarantees (2)
21,311 11,512 3,712 408 36,943 
Letters of credit (3)
1,156 254 65 25 1,500 
Legally binding commitments121,058 161,714 183,827 59,054 525,653 
Credit card lines (4)
376,067 376,067 
Total credit extension commitments$497,125 $161,714 $183,827 $59,054 $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 and Other Variable Interest Entities.
(4)    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 related to these guarantees totaled $1.1 billion, with estimated maturity dates between 2033 and 2039.
Indemnifications
In the ordinary course of business, the Corporation enters into various agreements that contain indemnifications, such as tax indemnifications, whereupon payment may become due if certain external events occur, such as a change in tax law. The indemnification clauses are often standard contractual terms and were entered into in the normal course of business based on an assessment that the risk of loss would be remote. These agreements typically contain an early termination clause that permits the Corporation to exit the agreement upon these events. The maximum potential future payment under indemnification agreements is difficult to assess for several reasons, including the occurrence of an external event, the inability to predict future changes in tax and other laws, the difficulty in determining how such laws would apply to parties in contracts, the absence of exposure limits contained in standard contract language and the timing of any early termination clauses. Historically, any payments made under these guarantees have been de minimis. The Corporation has assessed the probability of making such payments in the future as remote.
Merchant Services
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.
139 Bank of America


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 program, the Corporation guarantees the payment and performance of its sponsored members to the Fixed Income Clearing Corporation. The Corporation’s guarantee obligation is
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 potential future payments under these agreements are 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.
In the normal course of business, the Corporation periodically guarantees the obligations of its affiliates in a variety of transactions including ISDA-related transactions and non-ISDA related transactions such as commodities trading, repurchase agreements, prime brokerage agreements and other transactions.
Guarantees of Certain Long-term Debt
The Corporation, as the parent company, fully and unconditionally guarantees the securities issued by BofA Finance LLC, a consolidated finance subsidiary of the Corporation, and effectively provides for the full and unconditional guarantee of trust securities issued by certain statutory trust companies that are 100 percent owned finance subsidiaries of the Corporation.
Representations and WarrantiesObligations 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).
Settlement Actions
The Corporation has vigorously contested any request for repurchase where it has concluded that a valid basis for repurchase does not exist and will continue to do so in the future. However, in an effort to resolve legacy mortgage-related issues, the Corporation has reached bulk settlements, certain of which have been for significant amounts, in lieu of a loan-by-loan review process. The Corporation’s liability in connection with the transactions and claims not covered by these settlements could be material to the Corporation’s results of operations or liquidity for any particular reporting period. The Corporation may reach other settlements in the future if opportunities arise on terms it believes to be advantageous. However, there can be no assurance that the Corporation will reach future settlements or, if it does, that the terms of past settlements can be relied upon to predict the terms of future settlements.
Unresolved Repurchase ClaimsIntangible Assets
Unresolved representationsAt December 31, 2020 and warranties repurchase claims represent2019, the notional amountnet carrying value of repurchase claims made by counterparties, typicallyintangible assets was $2.2 billion and $1.7 billion. During 2020, the outstanding principal balance or the unpaid principal balance at the time of default. In the case of first-lien mortgages, the claim amountCorporation recognized a $585 million intangible asset, which is often significantly greater than the expected loss amount duebeing amortized over a 10-year life, related to the benefit of collateral and, in some cases, mortgage insurance or mortgage guarantee payments. Claims received from a counterparty remain outstanding until the underlying loan is repurchased, the claim is rescinded by the counterparty,merchant contracts that were distributed to the Corporation determines that the applicable statute of limitations has expired, or representations and warranties claims with respect to the applicable trust are settled, and fully and finally released. The Corporation does not include duplicate claims in the amounts disclosed.
The table below presents unresolved repurchase claims at December 31, 2017 and 2016. The unresolved repurchase claims include only claims where the Corporation believes that the counterparty has the contractual right to submit claims. The unresolved repurchase claims predominantly relate to subprime and pay option first-lien loans and home equity loans originated primarily between 2004 and 2008.from its merchant servicing joint venture. For more information, see Private-label Securitizations and Whole-loan Sales Experience in this Note and Note 12 – Commitments and Contingencies.
    
Unresolved Repurchase Claims by Counterparty, Net of Duplicate Claims
    
 December 31
(Dollars in millions)2017 2016
By counterparty 
  
Private-label securitization trustees, whole-loan investors, including third-party securitization sponsors and other (1)
$16,064
 $16,685
Monolines1,565
 1,583
GSEs5
 9
Total unresolved repurchase claims by counterparty, net of duplicate claims$17,634
 $18,277
(1)
Includes $11.4 billion and $11.9 billion of claims based on individual file reviews and $4.7 billion and $4.8 billion of claims submitted without individual file reviews at December 31, 2017 and 2016.
During 2017, the Corporation received $151 million in new repurchase claimsAt both December 31, 2020 and $794 million in claims were resolved, including $640 million related to settlements. Of the remaining unresolved monoline claims,2019, intangible assets included $1.6 billion of intangible assets associated with trade names, substantially all of the claims pertain to second-lien loanswhich had an indefinite life and, accordingly, are currently the subjectnot being amortized. Amortization of litigation with a single monoline insurer. There may be additional claims or file requests in the future.intangibles expense was $95 million, $112 million and $538 million for 2020, 2019 and 2018.

133 Bank of America


NOTE 8 Leases
The Corporation enters into both lessor and lessee arrangements. For more information on lease accounting, see Note 1 – Summary of Significant Accounting Principles and on lease financing receivables, see Note 5 – Outstanding Loans and Leases and Allowance for Credit Losses.
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.
Net Investment (1)
December 31
(Dollars in millions)20202019
Lease receivables$17,627 $19,312 
Unguaranteed residuals2,303 2,550 
   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.
The following table presents lease income at December 31, 2020 and 2019.
Lease Income
December 31
(Dollars in millions)20202019
Sales-type and direct financing leases$707 $797 
Operating leases931 891 
   Total lease income$1,638 $1,688 
Lessee Arrangements
The Corporation's lessee arrangements predominantly consist of operating leases for premises and equipment; the Corporation's financing leases are not significant.
Lease terms may contain renewal and extension options and early termination features. Generally, these options do not impact the lease term because the Corporation is not reasonably certain that it will exercise the options.
The 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.
Lessee Arrangements
December 31
(Dollars in millions)20202019
Right-of-use asset$10,000 $9,735 
Lease liabilities10,474 10,093 
Weighted-average discount rate used to calculate present value of future minimum lease payments3.38 %3.68 %
Weighted-average lease term (in years)8.48.2
Lease Cost and Supplemental Information:
Operating lease cost$2,149 $2,085 
Variable lease cost (1)
474 498 
   Total lease cost (2)
$2,623 $2,583 
Right-of-use assets obtained in exchange for
new operating lease liabilities (3)
$851 $931 
Operating cash flows from operating
    leases (4)
2,039 2,009 
(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.
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.
Maturities of Lessor and Lessee Arrangements
Lessor
Lessee (1)
Operating
Leases
Sales-type and
Direct Financing
Leases (2)
Operating
Leases
(Dollars in millions)December 31, 2020
2021$843 $5,424 $1,927 
2022748 4,934 1,715 
2023630 3,637 1,454 
2024479 2,089 1,308 
2025339 1,143 1,087 
Thereafter886 1,668 4,609 
Total undiscounted
cash flows
$3,925 18,895 12,100 
Less: Net present
value adjustment
1,268 1,626 
Total (3)
$17,627 $10,474 
(1)Excludes $885 million in commitments under lessee arrangements that have not yet commenced with lease terms that will begin in 2021.
(2)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
December 31, 2020December 31
2019
(Dollars in millions)Three Months
or Less
Over Three
Months to
Twelve Months
ThereafterTotalTotal
U.S. certificates of deposit and other time deposits$12,485 $10,668 $1,445 $24,598 $39,739 
Non-U.S. certificates of deposit and other time deposits8,568 1,925 1,432 11,925 13,034 
Bank of America 2017144134



In addition to the unresolved repurchase claims in the Unresolved Repurchase Claims by Counterparty, Net of Duplicate Claims table, the Corporation has received notifications from a sponsor of third-party securitizations with whom the Corporation engaged in whole-loan transactions indicating that the Corporation may have indemnity obligations with respect to specific loans for which the Corporation has not received a repurchase request. These notifications were received prior to 2015, and totaled $1.3 billion at both December 31, 2017 and 2016. During 2017, the Corporation reached agreements with certain parties requesting indemnity. One such agreement is subject to acceptance by a securitization trustee. The impact of these agreements is included in the provision and reserve for representations and warranties.
The presence of repurchase claims on a given trust, receipt of notices of indemnification obligations and receipt of other communications, as discussed above, are all factors that inform the Corporation’s reservescheduled contractual maturities for representations and warranties and the corresponding estimated range of possible loss.
Private-label Securitizations and Whole-loan Sales Experience
The notional amount of unresolved repurchase claimstotal time deposits at December 31, 20172020 are presented in the table below.
Contractual Maturities of Total Time Deposits
(Dollars in millions)U.S.Non-U.S.Total
Due in 2021$40,052 $10,609 $50,661 
Due in 20222,604 167 2,771 
Due in 2023431 435 
Due in 2024222 227 
Due in 2025186 13 199 
Thereafter276 1,287 1,563 
Total time deposits$43,771 $12,085 $55,856 
NOTE 10 Federal Funds Sold or Purchased, Securities Financing Agreements, Short-term Borrowings and 2016 included $6.9Restricted 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.
AmountRateAmountRate
(Dollars in millions)20202019
Federal funds sold and securities borrowed or purchased under agreements to resell
Average during year$309,945 0.29 %$279,610 1.73 %
Maximum month-end balance during year451,179 n/a281,684 n/a
Federal funds purchased and securities loaned or sold under agreements to repurchase
Average during year$192,479 0.69 %$201,797 2.31 %
Maximum month-end balance during year206,493 n/a203,063 n/a
Short-term borrowings
Average during year22,486 0.54 24,301 2.42 
Maximum month-end balance during year30,118 n/a36,538 n/a
n/a = not applicable
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 $5.6$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 claims relatedSecurities Financing Agreements
The Corporation enters into securities financing agreements to loans in specific private-label securitization groups or tranches where the Corporation owns substantiallyaccommodate customers (also referred to as “matched-book transactions”), obtain securities to cover short positions and finance inventory positions. Substantially all of the outstandingCorporation’s securities financing activities are transacted under legally enforceable master repurchase agreements or will otherwise realizelegally enforceable master securities lending agreements that give the benefit of any repurchase claims paid.
The overall decreaseCorporation, in the notional amountevent of outstanding unresolved repurchase claims in 2017 was primarily due default by the counterparty, the right
to claims that were resolved as a result of settlements. Outstanding repurchase claims remained unresolved primarily dueliquidate securities held and to (1)offset receivables and payables with the level of detail, support and analysis accompanying such claims, which impact overall claim quality and, therefore, claims resolution, and (2) the lack of an established process to resolve disputes related to these claims.
same counterparty. The Corporation reviews properlyoffsets 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 repurchase claims on a loan-by-loan basis.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 time-barred claims, the counterparty is informed that the claim is deniedmore information on the basisoffsetting of derivatives, see Note 3 – Derivatives.
135 Bank of America


Securities Financing Agreements
Gross Assets/Liabilities (1)
Amounts OffsetNet Balance Sheet Amount
Financial Instruments (2)
Net Assets/Liabilities
(Dollars in millions)December 31, 2020
Securities borrowed or purchased under agreements to resell (3)
$492,387 $(188,329)$304,058 $(272,351)$31,707 
Securities loaned or sold under agreements to repurchase$358,652 $(188,329)$170,323 $(158,867)$11,456 
Other (4)
16,210 0 16,210 (16,210)0 
Total$374,862 $(188,329)$186,533 $(175,077)$11,456 
December 31, 2019
Securities borrowed or purchased under agreements to resell (3)
$434,257 $(159,660)$274,597 $(244,486)$30,111 
Securities loaned or sold under agreements to repurchase$324,769 $(159,660)$165,109 $(141,482)$23,627 
Other (4)
15,346 15,346 (15,346)
Total$340,115 $(159,660)$180,455 $(156,828)$23,627 
(1)Includes activity where uncertainty exists as to the statuteenforceability of limitations and the claim is treated as resolved. For timely claims, if the Corporation, after review, does not believe a claim is valid, it will deny the claim and generally indicate a reason for the denial. If the counterparty agrees with the Corporation’s denial of the claim, the counterparty may rescind the claim. Ifcertain master netting agreements under bankruptcy laws in some countries or industries.
(2)Includes securities collateral received or pledged under repurchase or securities lending agreements where there is a disagreementlegally 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 resolutionlegal enforceability of the claim, meaningful dialoguemaster netting agreements is uncertain is excluded from the table.
(3)Excludes repurchase activity of $14.7 billion and negotiation between$12.9 billion reported in loans and leases on the parties are generally necessary to reach a resolution on an individual claim. The Corporation has performed an initial review with respect to substantially all outstanding claimsConsolidated Balance Sheet at December 31, 2020 and although the Corporation does not believe a valid basis for repurchase has been established by the claimant, it considers such claims activity in the computation of its liability for representations and warranties.2019.
Reserve and Estimated Range of Possible Loss
The reserve for representations and warranties and corporate guarantees(4)Balance is includedreported in accrued expenses and other liabilities on the Consolidated Balance Sheet and the related provision is included in mortgage banking income in the Consolidated Statement of Income. The reserve for representations and
warranties is established when those obligations are both probable and reasonably estimable.
The Corporation’s representations and warranties reserve and the corresponding estimated range of possible loss at December 31, 2017 consider, among other things, the repurchase experience implied in prior settlements, and uses the experience implied in those prior settlements in the assessment for those trustsrelates to transactions where the Corporation hasacts as the lender in a continuing possibilitysecurities 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 timely claimscollateral pledged. Included in order“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
Overnight and Continuous30 Days or LessAfter 30 Days Through 90 Days
Greater than
90 Days (1)
Total
(Dollars in millions)December 31, 2020
Securities sold under agreements to repurchase$158,400 $122,448 $32,149 $22,684 $335,681 
Securities loaned19,140 271 1,029 2,531 22,971 
Other16,210 0 0 0 16,210 
Total$193,750 $122,719 $33,178 $25,215 $374,862 
December 31, 2019
Securities sold under agreements to repurchase$129,455 $122,685 $25,322 $21,922 $299,384 
Securities loaned18,766 3,329 1,241 2,049 25,385 
Other15,346 15,346 
Total$163,567 $126,014 $26,563 $23,971 $340,115 
(1)NaN agreements have maturities greater than three years.
Class of Collateral Pledged
Securities Sold Under Agreements to RepurchaseSecurities
Loaned
OtherTotal
(Dollars in millions)December 31, 2020
U.S. government and agency securities$195,167 $5 $0 $195,172 
Corporate securities, trading loans and other8,633 1,628 1,217 11,478 
Equity securities14,752 21,125 14,931 50,808 
Non-U.S. sovereign debt113,142 213 62 113,417 
Mortgage trading loans and ABS3,987 0 0 3,987 
Total$335,681 $22,971 $16,210 $374,862 
December 31, 2019
U.S. government and agency securities$173,533 $$$173,534 
Corporate securities, trading loans and other10,467 2,014 258 12,739 
Equity securities14,933 20,026 15,024 49,983 
Non-U.S. sovereign debt96,576 3,344 64 99,984 
Mortgage trading loans and ABS3,875 3,875 
Total$299,384 $25,385 $15,346 $340,115 
Bank of America 136


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 representations and warranties reservemarket value of the underlying collateral remains sufficient, collateral is generally valued daily, and the corresponding estimatedCorporation 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 possible loss.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 a rollforwardthe balance of long-term debt at December 31, 2020 and 2019, and the reserve for representationsrelated contractual rates and warranties and corporate guarantees.
    
Representations and Warranties and Corporate Guarantees
  
(Dollars in millions)2017 2016
Reserve for representations and warranties and corporate guarantees, January 1$2,339
 $11,326
Additions for new sales4
 4
Payments (1)
(814) (9,097)
Provision393
 106
Reserve for representations and warranties and corporate guarantees, December 31$1,922
 $2,339
(1)
In February 2016, the Corporation made an $8.5 billion settlement payment as part of the settlement with BNY Mellon.
The representations and warranties reserve represents the Corporation’s best estimate of probable incurred lossesmaturity dates as of December 31, 2017. However, it2020.
Weighted-average RateDecember 31
(Dollars in millions)Interest RatesMaturity Dates20202019
Notes issued by Bank of America Corporation (1)
  
Senior notes:  
Fixed3.05 %0.25 - 8.05%2021 - 2051$174,385 $140,265 
Floating0.74 0.09 - 4.962021 - 204416,788 19,552 
Senior structured notes17,033 16,941 
Subordinated notes:
Fixed4.89 2.94 - 8.572021 - 204523,337 21,632 
Floating1.15 0.88 - 1.412022 - 2026799 782 
Junior subordinated notes:
Fixed6.71 6.45 - 8.052027 - 2066738 736 
Floating1.03 1.03 20561 
Total notes issued by Bank of America Corporation233,081 199,909 
Notes issued by Bank of America, N.A.  
Senior notes:  
Fixed3.34 3.34 2023511 508 
Floating0.33 0.28 - 0.492021 - 20412,323 6,519 
Subordinated notes6.00 6.00 20361,883 1,744 
Advances from Federal Home Loan Banks:
Fixed0.99 0.01 - 7.722021 - 2034599 112 
Floating0 2,500 
Securitizations and other BANA VIEs (2)
6,296 8,373 
Other683 402 
Total notes issued by Bank of America, N.A.12,295 20,158 
Other debt  
Structured liabilities16,792 20,442 
Nonbank VIEs (2)
757 347 
Other9 
Total notes issued by nonbank and other entities17,558 20,789 
Total long-term debt$262,934 $240,856 
(1)Includes total loss-absorbing capacity compliant debt.
(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 reasonably possible that future representations and warranties losses may occur in excesscollateralized by the assets of the amounts recorded for these exposures.
The Corporation currently estimates that the range of possible loss for representationsVIEs. For more information, see Note 6 – Securitizations and warranties exposures could be up to $1 billion over existing accruals at December 31, 2017. This estimate is lower than the estimate at December 31, 2016 due to recent reductions in risk as we reach settlements with counterparties. The Corporation treats claims that are time-barred as resolved and does not consider such claims in the estimated range of possible loss. The estimated range of possible loss reflects principally exposures related to loans in private-label securitization trusts, including related indemnity claims. It represents a reasonably possible loss, but does not represent a probable loss, and is based on currently available information, significant judgment and a number of assumptions that are subject to change.
The reserve for representations and warranties exposures and the corresponding estimated range of possible loss do not consider certain losses related to servicing, including foreclosure and related costs, fraud, indemnity, or claims (including for RMBS) related to securities law or monoline insurance litigation. Losses with respect to one or more of these matters could be material to the Corporation’s results of operations or liquidity for any particular reporting period.
Future provisions and/or ranges of possible loss for representations and warranties may be significantly impacted if actual experiences are different from the Corporation’s assumptions in predictive models.Other Variable Interest Entities.


145137 Bank of America


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
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 repayment terms linked to the performance of debt or equity securities, indices, currencies or commodities, and the maturity may be accelerated based on the value of a referenced index or security. In both cases, the Corporation or a subsidiary may be required to settle the obligation for cash or other securities prior to the contractual maturity date. These borrowings are reflected in the table as maturing at their contractual maturity date.
Long-term Debt by Maturity
(Dollars in millions)20212022202320242025ThereafterTotal
Bank of America Corporation
Senior notes$8,888 $15,380 $23,872 $21,407 $15,723 $105,903 $191,173 
Senior structured notes469 2,034 597 190 549 13,194 17,033 
Subordinated notes371 393 3,351 5,537 14,484 24,136 
Junior subordinated notes739 739 
Total Bank of America Corporation9,728 17,807 24,469 24,948 21,809 134,320 233,081 
Bank of America, N.A.
Senior notes1,340 975 511 2,834 
Subordinated notes1,883 1,883 
Advances from Federal Home Loan Banks502 18 75 599 
Securitizations and other Bank VIEs (1)
4,056 1,241 977 22 6,296 
Other112 16 189 279 87 683 
Total Bank of America, N.A.6,010 2,235 1,678 297 2,075 12,295 
Other debt
Structured Liabilities4,613 2,414 2,221 655 859 6,030 16,792 
Nonbank VIEs (1)
756 757 
Other9 
Total other debt4,614 2,414 2,221 655 859 6,795 17,558 
Total long-term debt$20,352 $22,456 $28,368 $25,603 $22,965 $143,190 $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.
Legally binding commitments to extend credit generally have specified rates and maturities. Certain of these commitments have adverse change clauses that help to protect the Corporation against deterioration in the borrower’s ability to pay.
The table below includes 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.
Bank of America 2017138




Credit Extension Commitments
Expire in One
Year or Less
Expire After One
Year Through
Three Years
Expire After Three Years Through
Five Years
Expire After
Five Years
Total
(Dollars in millions)December 31, 2020
Notional amount of credit extension commitments     
Loan commitments (1)
$109,406 $171,887 $139,508 $16,091 $436,892 
Home equity lines of credit710 2,992 8,738 29,892 42,332 
Standby letters of credit and financial guarantees (2)
19,962 12,038 2,397 1,257 35,654 
Letters of credit (3)
886 197 25 27 1,135 
Legally binding commitments130,964 187,114 150,668 47,267 516,013 
Credit card lines (4)
384,955 0 0 0 384,955 
Total credit extension commitments$515,919 $187,114 $150,668 $47,267 $900,968 
 December 31, 2019
Notional amount of credit extension commitments     
Loan commitments (1)
$97,454 $148,000 $173,699 $24,487 $443,640 
Home equity lines of credit1,137 1,948 6,351 34,134 43,570 
Standby letters of credit and financial guarantees (2)
21,311 11,512 3,712 408 36,943 
Letters of credit (3)
1,156 254 65 25 1,500 
Legally binding commitments121,058 161,714 183,827 59,054 525,653 
Credit card lines (4)
376,067 376,067 
Total credit extension commitments$497,125 $161,714 $183,827 $59,054 $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.
NOTE 8 Goodwill(2)     The notional amounts of SBLCs and Intangible Assets
Goodwill
The table below presents goodwill balances by business segmentfinancial guarantees classified as investment grade and All Othernon-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, 20172020, and 2016. $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 and Other Variable Interest Entities.
(4)    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 reporting units utilizedCorporation 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 related to these guarantees totaled $1.1 billion, with estimated maturity dates between 2033 and 2039.
Indemnifications
In the ordinary course of business, the Corporation enters into various agreements that contain indemnifications, such as tax indemnifications, whereupon payment may become due if certain external events occur, such as a change in tax law. The indemnification clauses are often standard contractual terms and were entered into in the normal course of business based on an assessment that the risk of loss would be remote. These agreements typically contain an early termination clause that permits the Corporation to exit the agreement upon these events. The maximum potential future payment under indemnification agreements is difficult to assess for goodwill impairment testing areseveral reasons, including the operating segmentsoccurrence 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 one level below.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.
    
Goodwill   
    
 December 31
(Dollars in millions)2017 2016
Consumer Banking$30,123
 $30,123
Global Wealth & Investment Management9,677
 9,681
Global Banking23,923
 23,923
Global Markets5,182
 5,197
All Other46
 820
Less: Goodwill of business held for sale (1)

 (775)
Total goodwill$68,951
 $68,969
(1)139 Bank of America
Reflects the goodwill assigned to the non-U.S. consumer credit card business, which was included in assets of business held for sale on the Consolidated Balance Sheet at December 31, 2016. In 2017, the Corporation sold its non-U.S. consumer credit card business.

During 2017,

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 completedmay 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 annual goodwill impairment test asexposure in this area due to the potential economic impacts of June 30, 2017 for all applicable reporting units. Based onCOVID-19.
Exchange and Clearing House Member Guarantees
The Corporation is a member of various securities and derivative exchanges and clearinghouses, both in the resultsU.S. and other countries. As a member, the Corporation may be required to pay a pro-rata share of the annual goodwill impairment test,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 determined therehas 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 program, the Corporation guarantees the payment and performance of its sponsored members to the Fixed Income Clearing Corporation. The Corporation’s guarantee obligation is
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 potential future payments under these agreements are 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 impairment.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.
In the normal course of business, the Corporation periodically guarantees the obligations of its affiliates in a variety of transactions including ISDA-related transactions and non-ISDA related transactions such as commodities trading, repurchase agreements, prime brokerage agreements and other transactions.
Guarantees of Certain Long-term Debt
The Corporation, as the parent company, fully and unconditionally guarantees the securities issued by BofA Finance LLC, a consolidated finance subsidiary of the Corporation, and effectively provides for the full and unconditional guarantee of trust securities issued by certain statutory trust companies that are 100 percent owned finance subsidiaries of the Corporation.
Representations and Warranties Obligations and Corporate Guarantees
The Corporation securitizes first-lien residential mortgage loans generally in the form of RMBS guaranteed by the GSEs or by GNMA in the case of FHA-insured, VA-guaranteed and Rural Housing Service-guaranteed mortgage loans, and sells pools of first-lien residential mortgage loans in the form of whole loans. In addition, in prior years, legacy companies and certain subsidiaries sold pools of first-lien residential mortgage loans and home equity loans as private-label securitizations or in the form of whole loans. In connection with these transactions, the Corporation or certain of its subsidiaries or legacy companies make and have made various representations 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).
Intangible Assets
The table below presentsAt December 31, 2020 and 2019, the gross and net carrying values and accumulated amortization forvalue of intangible assets atwas $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, 20172020 and 2016.
            
Intangible Assets (1, 2)
           
            
 Gross
Carrying Value
 Accumulated
Amortization
 Net
Carrying Value
 Gross
Carrying Value
 Accumulated
Amortization
 Net
Carrying Value
(Dollars in millions)December 31, 2017 December 31, 2016
Purchased credit card and affinity relationships$5,919
 $5,604
 $315
 $6,830
 $6,243
 $587
Core deposit and other intangibles (3)
3,835
 2,140
 1,695
 3,836
 2,046
 1,790
Customer relationships3,886
 3,584
 302
 3,887
 3,275
 612
Total intangible assets (4)
$13,640
 $11,328
 $2,312
 $14,553
 $11,564
 $2,989
(1)
Excludes fully amortized intangible assets.
(2)
At December 31, 2017 and 2016, none of the intangible assets were impaired.
(3)
Includes $1.6 billion at both December 31, 2017 and 2016 of intangible assets associated with trade names that have an indefinite life and, accordingly, are not amortized.
(4)
Includes $67 million at December 31, 2016 of intangible assets assigned to the non-U.S. consumer credit card business, which was included in assets of business held for sale on the Consolidated Balance Sheet at December 31, 2016.
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 $621$95 million, $730$112 million and $834$538 million for 2017, 20162020, 2019 and 2015. The Corporation estimates aggregate amortization expense will be $538 million, $105 million and $53 million for the years through 2020 and none for the years thereafter.2018.

133Bank of America 2017146



NOTE 8 Leases
The Corporation enters into both lessor and lessee arrangements. For more information on lease accounting, see Note 1 – Summary of Significant Accounting Principles and on lease financing receivables, see Note 5 – Outstanding Loans and Leases and Allowance for Credit Losses.
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.
Net Investment (1)
December 31
(Dollars in millions)20202019
Lease receivables$17,627 $19,312 
Unguaranteed residuals2,303 2,550 
   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.
The following table presents lease income at December 31, 2020 and 2019.
Lease Income
December 31
(Dollars in millions)20202019
Sales-type and direct financing leases$707 $797 
Operating leases931 891 
   Total lease income$1,638 $1,688 
Lessee Arrangements
The Corporation's lessee arrangements predominantly consist of operating leases for premises and equipment; the Corporation's financing leases are not significant.
Lease terms may contain renewal and extension options and early termination features. Generally, these options do not impact the lease term because the Corporation is not reasonably certain that it will exercise the options.
The 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.
Lessee Arrangements
December 31
(Dollars in millions)20202019
Right-of-use asset$10,000 $9,735 
Lease liabilities10,474 10,093 
Weighted-average discount rate used to calculate present value of future minimum lease payments3.38 %3.68 %
Weighted-average lease term (in years)8.48.2
Lease Cost and Supplemental Information:
Operating lease cost$2,149 $2,085 
Variable lease cost (1)
474 498 
   Total lease cost (2)
$2,623 $2,583 
Right-of-use assets obtained in exchange for
new operating lease liabilities (3)
$851 $931 
Operating cash flows from operating
    leases (4)
2,039 2,009 
(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.
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.
Maturities of Lessor and Lessee Arrangements
Lessor
Lessee (1)
Operating
Leases
Sales-type and
Direct Financing
Leases (2)
Operating
Leases
(Dollars in millions)December 31, 2020
2021$843 $5,424 $1,927 
2022748 4,934 1,715 
2023630 3,637 1,454 
2024479 2,089 1,308 
2025339 1,143 1,087 
Thereafter886 1,668 4,609 
Total undiscounted
cash flows
$3,925 18,895 12,100 
Less: Net present
value adjustment
1,268 1,626 
Total (3)
$17,627 $10,474 
(1)Excludes $885 million in commitments under lessee arrangements that have not yet commenced with lease terms that will begin in 2021.
(2)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 thousand$100,000 or more at December 31, 20172020 and 2016.2019. The Corporation also had aggregate time deposits of $17.0$10.7 billion and $18.3$15.8 billion in denominations that met or exceeded the Federal Deposit Insurance Corporation (FDIC) insurance limit at December 31, 20172020 and 2016.2019.
Time Deposits of $100,000 or More
December 31, 2020December 31
2019
(Dollars in millions)Three Months
or Less
Over Three
Months to
Twelve Months
ThereafterTotalTotal
U.S. certificates of deposit and other time deposits$12,485 $10,668 $1,445 $24,598 $39,739 
Non-U.S. certificates of deposit and other time deposits8,568 1,925 1,432 11,925 13,034 
          
Time Deposits of $100 Thousand or More         
          
 December 31, 2017 December 31
2016
(Dollars in millions)
Three Months
or Less
 
Over Three
Months to
Twelve Months
 Thereafter Total Total
U.S. certificates of deposit and other time deposits$12,505
 $10,660
 $2,027
 $25,192
 $32,898
Non-U.S. certificates of deposit and other time deposits10,561
 3,652
 1,259
 15,472
 14,677
Bank of America 134


The scheduled contractual maturities for total time deposits at December 31, 20172020 are presented in the table below.
Contractual Maturities of Total Time Deposits
(Dollars in millions)U.S.Non-U.S.Total
Due in 2021$40,052 $10,609 $50,661 
Due in 20222,604 167 2,771 
Due in 2023431 435 
Due in 2024222 227 
Due in 2025186 13 199 
Thereafter276 1,287 1,563 
Total time deposits$43,771 $12,085 $55,856 
      
Contractual Maturities of Total Time Deposits     
      
(Dollars in millions)U.S. Non-U.S. Total
Due in 2018$46,774
 $14,264
 $61,038
Due in 20192,623
 657
 3,280
Due in 20201,661
 49
 1,710
Due in 2021514
 15
 529
Due in 2022452
 562
 1,014
Thereafter264
 9
 273
Total time deposits$52,288
 $15,556
 $67,844
NOTE 10 Federal Funds Sold or Purchased, Securities Financing Agreements, and Short-term Borrowings and Restricted Cash
The table below presents federal funds sold or purchased, securities financing agreements which(which include securities borrowed or purchased under agreements to resell and securities loaned or sold under agreements to repurchase,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 election of the fair value option, see Note 21 – Fair Value Option.
       AmountRateAmountRate
Amount Rate Amount Rate
(Dollars in millions)2017 2016(Dollars in millions)20202019
Federal funds sold and securities borrowed or purchased under agreements to resell       Federal funds sold and securities borrowed or purchased under agreements to resell
Average during year$222,818
 1.07% $216,161
 0.52%Average during year$309,945 0.29 %$279,610 1.73 %
Maximum month-end balance during year237,064
 n/a
 225,015
 n/a
Maximum month-end balance during year451,179 n/a281,684 n/a
Federal funds purchased and securities loaned or sold under agreements to repurchase       Federal funds purchased and securities loaned or sold under agreements to repurchase
Average during year$199,501
 1.30% $183,818
 0.97%Average during year$192,479 0.69 %$201,797 2.31 %
Maximum month-end balance during year218,017
 n/a
 196,631
 n/a
Maximum month-end balance during year206,493 n/a203,063 n/a
Short-term borrowings       Short-term borrowings
Average during year37,337
 2.48% 29,440
 1.95%Average during year22,486 0.54 24,301 2.42 
Maximum month-end balance during year46,202
 n/a
 33,051
 n/a
Maximum month-end balance during year30,118 n/a36,538 n/a
n/a = not applicable
Bank of America, N.A. maintains a global program to offer up to a maximum of $75$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 $14.2$3.9 billion and $9.3$11.7 billion at December 31, 20172020 and 2016.2019. These short-term bank notes, along with FHLBFederal 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.

147Bank of America 2017



Offsetting of Securities Financing Agreements
The Corporation enters into securities financing agreements to accommodate customers (also referred to as “matched-book transactions”), obtain securities to cover short positions and to finance inventory positions. Substantially all of the Corporation’s securities financing activities are transacted under legally enforceable master repurchase agreements or legally enforceable master securities lending agreements that give the Corporation, in the event of default by the counterparty, the right
to liquidate securities held and to offset receivables and payables with the same counterparty.
The Corporation offsets securities financing transactions with the same counterparty on the Consolidated Balance Sheet where it has such a legally enforceable master netting agreement and the transactions have the same maturity date.
The Securities Financing Agreements table presents securities financing agreements included on the Consolidated Balance Sheet in federal funds sold and securities borrowed or purchased under agreements to resell, and in federal funds purchased and securities loaned or sold under agreements to repurchase at December 31, 20172020 and 2016.2019. 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 23 – Derivatives.
          
Securities Financing Agreements         
          
 
Gross Assets/Liabilities (1)
 Amounts Offset Net Balance Sheet Amount 
Financial Instruments (2)
 Net Assets/Liabilities
(Dollars in millions)December 31, 2017
Securities borrowed or purchased under agreements to resell (3)
$348,472
 $(135,725) $212,747
 $(165,720) $47,027
Securities loaned or sold under agreements to repurchase$312,582
 $(135,725) $176,857
 $(146,205) $30,652
Other (4)
22,711
 
 22,711
 (22,711) 
Total$335,293
 $(135,725) $199,568
 $(168,916) $30,652
          
 December 31, 2016
Securities borrowed or purchased under agreements to resell (3)
$326,970
 $(128,746) $198,224
 $(154,974) $43,250
Securities loaned or sold under agreements to repurchase$299,028
 $(128,746) $170,282
 $(140,774) $29,508
Other (4)
14,448
 
 14,448
 (14,448) 
Total$313,476
 $(128,746) $184,730
 $(155,222) $29,508
(1)135 Bank of America
Includes activity where uncertainty exists as to the enforceability of certain master netting agreements under bankruptcy laws in some countries or industries.
(2)
Includes securities collateral received or pledged under repurchase or securities lending agreements where there is a legally enforceable master netting agreement. These amounts are not offset on the Consolidated Balance Sheet, but are shown as a reduction to derive a net asset or liability. Securities collateral received or pledged where the legal enforceability of the master netting agreements is uncertain is excluded from the table.
(3)
Excludes repurchase activity of $10.2 billion and $10.1 billion reported in loans and leases on the Consolidated Balance Sheet at December 31, 2017 and 2016.
(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.


Securities Financing Agreements
Gross Assets/Liabilities (1)
Amounts OffsetNet Balance Sheet Amount
Financial Instruments (2)
Net Assets/Liabilities
(Dollars in millions)December 31, 2020
Securities borrowed or purchased under agreements to resell (3)
$492,387 $(188,329)$304,058 $(272,351)$31,707 
Securities loaned or sold under agreements to repurchase$358,652 $(188,329)$170,323 $(158,867)$11,456 
Other (4)
16,210 0 16,210 (16,210)0 
Total$374,862 $(188,329)$186,533 $(175,077)$11,456 
December 31, 2019
Securities borrowed or purchased under agreements to resell (3)
$434,257 $(159,660)$274,597 $(244,486)$30,111 
Securities loaned or sold under agreements to repurchase$324,769 $(159,660)$165,109 $(141,482)$23,627 
Other (4)
15,346 15,346 (15,346)
Total$340,115 $(159,660)$180,455 $(156,828)$23,627 
(1)Includes activity where uncertainty exists as to the enforceability of certain master netting agreements under bankruptcy laws in some countries or industries.
(2)Includes securities collateral received or pledged under repurchase or securities lending agreements where there is a legally enforceable master netting agreement. These amounts are not offset on the Consolidated Balance Sheet, but are shown as a reduction to derive a net asset or liability. Securities collateral received or pledged where the legal enforceability of the master netting agreements is uncertain is excluded from the table.
(3)Excludes repurchase activity of $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
Overnight and Continuous30 Days or LessAfter 30 Days Through 90 Days
Greater than
90 Days (1)
Total
(Dollars in millions)December 31, 2020
Securities sold under agreements to repurchase$158,400 $122,448 $32,149 $22,684 $335,681 
Securities loaned19,140 271 1,029 2,531 22,971 
Other16,210 0 0 0 16,210 
Total$193,750 $122,719 $33,178 $25,215 $374,862 
December 31, 2019
Securities sold under agreements to repurchase$129,455 $122,685 $25,322 $21,922 $299,384 
Securities loaned18,766 3,329 1,241 2,049 25,385 
Other15,346 15,346 
Total$163,567 $126,014 $26,563 $23,971 $340,115 
(1)NaN agreements have maturities greater than three years.
Class of Collateral Pledged
Securities Sold Under Agreements to RepurchaseSecurities
Loaned
OtherTotal
(Dollars in millions)December 31, 2020
U.S. government and agency securities$195,167 $5 $0 $195,172 
Corporate securities, trading loans and other8,633 1,628 1,217 11,478 
Equity securities14,752 21,125 14,931 50,808 
Non-U.S. sovereign debt113,142 213 62 113,417 
Mortgage trading loans and ABS3,987 0 0 3,987 
Total$335,681 $22,971 $16,210 $374,862 
December 31, 2019
U.S. government and agency securities$173,533 $$$173,534 
Corporate securities, trading loans and other10,467 2,014 258 12,739 
Equity securities14,933 20,026 15,024 49,983 
Non-U.S. sovereign debt96,576 3,344 64 99,984 
Mortgage trading loans and ABS3,875 3,875 
Total$299,384 $25,385 $15,346 $340,115 
          
Remaining Contractual Maturity         
          
 Overnight and Continuous 30 Days or Less After 30 Days Through 90 Days 
Greater than 90 Days (1)
 Total
(Dollars in millions)December 31, 2017
Securities sold under agreements to repurchase$125,956
 $79,913
 $46,091
 $38,935
 $290,895
Securities loaned9,853
 5,658
 2,043
 4,133
 21,687
Other22,711
 
 
 
 22,711
Total$158,520
 $85,571
 $48,134
 $43,068
 $335,293
          
 December 31, 2016
Securities sold under agreements to repurchase$129,853
 $77,780
 $31,851
 $40,752
 $280,236
Securities loaned8,564
 6,602
 1,473
 2,153
 18,792
Other14,448
 
 
 
 14,448
Total$152,865
 $84,382
 $33,324
 $42,905
 $313,476
(1)
No agreements have maturities greater than three years.

Bank of America 2017148136



        
Class of Collateral Pledged       
        
 Securities Sold Under Agreements to Repurchase Securities Loaned Other Total
(Dollars in millions)December 31, 2017
U.S. government and agency securities$158,299
 $
 $409
 $158,708
Corporate securities, trading loans and other12,787
 2,669
 624
 16,080
Equity securities23,975
 13,523
 21,628
 59,126
Non-U.S. sovereign debt90,857
 5,495
 50
 96,402
Mortgage trading loans and ABS4,977
 
 
 4,977
Total$290,895
 $21,687
 $22,711
 $335,293
        
 December 31, 2016
U.S. government and agency securities$153,184
 $
 $70
 $153,254
Corporate securities, trading loans and other11,086
 1,630
 127
 12,843
Equity securities24,007
 11,175
 14,196
 49,378
Non-U.S. sovereign debt84,171
 5,987
 55
 90,213
Mortgage trading loans and ABS7,788
 
 
 7,788
Total$280,236
 $18,792
 $14,448
 $313,476
TheUnder repurchase agreements, the Corporation is required to post collateral with a market value equal to or in excess of the principal amount borrowed under repurchase agreements.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.
149Bank of America 2017



NOTE 11Long-term Debt
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, 20172020 and 2016,2019, and the related contractual rates and maturity dates as of December 31, 2017.2020.
Weighted-average RateDecember 31
(Dollars in millions)Interest RatesMaturity Dates20202019
Notes issued by Bank of America Corporation (1)
  
Senior notes:  
Fixed3.05 %0.25 - 8.05%2021 - 2051$174,385 $140,265 
Floating0.74 0.09 - 4.962021 - 204416,788 19,552 
Senior structured notes17,033 16,941 
Subordinated notes:
Fixed4.89 2.94 - 8.572021 - 204523,337 21,632 
Floating1.15 0.88 - 1.412022 - 2026799 782 
Junior subordinated notes:
Fixed6.71 6.45 - 8.052027 - 2066738 736 
Floating1.03 1.03 20561 
Total notes issued by Bank of America Corporation233,081 199,909 
Notes issued by Bank of America, N.A.  
Senior notes:  
Fixed3.34 3.34 2023511 508 
Floating0.33 0.28 - 0.492021 - 20412,323 6,519 
Subordinated notes6.00 6.00 20361,883 1,744 
Advances from Federal Home Loan Banks:
Fixed0.99 0.01 - 7.722021 - 2034599 112 
Floating0 2,500 
Securitizations and other BANA VIEs (2)
6,296 8,373 
Other683 402 
Total notes issued by Bank of America, N.A.12,295 20,158 
Other debt  
Structured liabilities16,792 20,442 
Nonbank VIEs (2)
757 347 
Other9 
Total notes issued by nonbank and other entities17,558 20,789 
Total long-term debt$262,934 $240,856 
(1)Includes total loss-absorbing capacity compliant debt.
(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.
    
 December 31
(Dollars in millions)2017 2016
Notes issued by Bank of America Corporation 
  
Senior notes: 
  
Fixed, with a weighted-average rate of 3.64%, ranging from 0.39% to 8.40%, due 2018 to 2048$119,548
 $108,933
Floating, with a weighted-average rate of 1.54%, ranging from 0.04% to 6.13%, due 2018 to 204421,048
 13,164
Senior structured notes15,460
 17,049
Subordinated notes:   
Fixed, with a weighted-average rate of 4.90%, ranging from 2.94% to 8.57%, due 2018 to 204522,004
 26,047
Floating, with a weighted-average rate of 1.00%, ranging from 0.20% to 2.56%, due 2018 to 20264,058
 4,350
Junior subordinated notes (related to trust preferred securities):   
Fixed, with a weighted-average rate of 6.91%, ranging from 5.25% to 8.05%, due 2027 to 20673,282
 3,280
Floating, with a weighted-average rate of 2.13%, ranging from 1.91% to 2.60%, due 2027 to 2056553
 552
Total notes issued by Bank of America Corporation185,953
 173,375
Notes issued by Bank of America, N.A. 
  
Senior notes: 
  
Fixed, with a weighted-average rate of 1.78%, ranging from 0.02% to 2.05%, due in 20184,686
 5,936
Floating, with a weighted-average rate of 2.60%, ranging from 1.44% to 2.80%, due 2018 to 20411,033
 3,383
Subordinated notes:   
Fixed, with a rate of 6.00%, due in 20361,679
 4,424
Floating, with a rate of 1.33%, due in 20191
 598
Advances from Federal Home Loan Banks:   
Fixed, with a weighted-average rate of 5.22%, ranging from 0.01% to 7.72%, due 2018 to 2034146
 162
Floating, with a weighted-average rate of 1.42%, ranging from 1.35% to 1.60%, due 2018 to 20195,000
 
Securitizations and other BANA VIEs (1)
8,641
 9,164
Other432
 3,084
Total notes issued by Bank of America, N.A.21,618
 26,751
Other debt 
  
Structured liabilities18,574
 15,171
Nonbank VIEs (1)
1,232
 1,482
Other25
 44
Total other debt19,831
 16,697
Total long-term debt$227,402
 $216,823
(1)
Represents the total long-term debt included in the liabilities of consolidated VIEs on the Consolidated Balance Sheet.
Bank of America Corporation and Bank of America, N.A. maintain various U.S. and non-U.S. debt programs to offer both senior and subordinated notes. The notes may be denominated in U.S. dollars or foreign currencies. At December 31, 20172020 and 2016,2019, the amount of foreign currency-denominated debt translated into U.S. dollars included in total long-term debt was $51.8$54.6 billion and $44.7$49.6 billion. Foreign currency contracts may be used to convert certain foreign currency-denominated debt into U.S. dollars.
At December 31, 2017,2020, long-term debt of consolidated VIEs in the table above included debt from credit card, residential mortgage, home equity and all other VIEs of $8.6$6.3 billion, $76$491 million, $178 million and $1.2 billion,$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.
137 Bank of America


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 3.443.02 percent, 3.873.29 percent and 1.490.71 percent, respectively, at December 31, 2017,2020, and 3.803.26 percent, 4.363.55 percent and 1.521.92 percent, respectively, at December 31, 2016.2019. 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 that are caused by interest rate volatility. The Corporation’s goal is to manage interest rate sensitivity so that movements in interest rates do not have a significantly adversely affectadverse 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.
Certain senior structured notes and structured liabilities are accounted for under the fair value option. For more information on these notes, see Note 21 – Fair Value Option.Debt outstanding of $2.7$4.8 billion at December 31, 20172020 was issued by BofA Finance LLC, a 100 percent ownedconsolidated finance subsidiary
of Bank of America Corporation, the parent company, and is fully and unconditionally guaranteed by the parent company.
The following table below shows the carrying value for aggregate annual contractual maturities of long-term debt as of December 31, 2017.2020. 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 repayment terms linked to the performance of debt or equity securities, indices, currencies or commodities, and the maturity may be accelerated based on the value of a referenced index or security. In both cases, the Corporation or a subsidiary may be required to settle the obligation for cash or other securities prior to the contractual maturity date. These borrowings are reflected in the table as maturing at their contractual maturity date.
During 2017, the Corporation had
Long-term Debt by Maturity
(Dollars in millions)20212022202320242025ThereafterTotal
Bank of America Corporation
Senior notes$8,888 $15,380 $23,872 $21,407 $15,723 $105,903 $191,173 
Senior structured notes469 2,034 597 190 549 13,194 17,033 
Subordinated notes371 393 3,351 5,537 14,484 24,136 
Junior subordinated notes739 739 
Total Bank of America Corporation9,728 17,807 24,469 24,948 21,809 134,320 233,081 
Bank of America, N.A.
Senior notes1,340 975 511 2,834 
Subordinated notes1,883 1,883 
Advances from Federal Home Loan Banks502 18 75 599 
Securitizations and other Bank VIEs (1)
4,056 1,241 977 22 6,296 
Other112 16 189 279 87 683 
Total Bank of America, N.A.6,010 2,235 1,678 297 2,075 12,295 
Other debt
Structured Liabilities4,613 2,414 2,221 655 859 6,030 16,792 
Nonbank VIEs (1)
756 757 
Other9 
Total other debt4,614 2,414 2,221 655 859 6,795 17,558 
Total long-term debt$20,352 $22,456 $28,368 $25,603 $22,965 $143,190 $262,934 
(1)     Represents liabilities of consolidated VIEs included in total long-term debt maturities and redemptions inon the aggregate of $48.8 billion consisting of $29.1 billion for Bank of America Corporation, $13.3 billion for Bank of America, N.A. and $6.4 billion of other debt. During 2016, the Corporation had total long-term debt maturities and redemptions in the aggregate of $51.6 billion consisting of
Consolidated Balance Sheet.

Bank of America 2017150


$30.6 billion for Bank of America Corporation, $11.6 billion for Bank of America, N.A. and $9.4 billion of other debt.
In December 2017, pursuant to a private offering, the Corporation exchanged $11.0 billion of outstanding long-term debt for new fixed/floating-rate senior notes, subject to certain terms and conditions. Based on the attributes of the exchange transactions, the newly issued securities are not considered
substantially different,for accounting purposes, from the exchanged securities. Therefore, there was no impact to the Corporation’s results of operations as any amounts paid to debt holders were capitalized, and the premiums or discounts on the outstanding long-term debt were carried over to the new securities and will be amortized over their contractual lives using a revised effective interest rate.
               
Long-term Debt by Maturity
               
(Dollars in millions)2018 2019 2020 2021 2022 Thereafter Total
Bank of America Corporation             
Senior notes$19,577
 $15,115
 $10,580
 $16,196
 $9,691
 $69,437
 $140,596
Senior structured notes2,749
 1,486
 950
 437
 2,017
 7,821
 15,460
Subordinated notes2,973
 1,552
 
 375
 476
 20,686
 26,062
Junior subordinated notes
 
 
 
 
 3,835
 3,835
Total Bank of America Corporation25,299
 18,153
 11,530
 17,008
 12,184
 101,779
 185,953
Bank of America, N.A.

            
Senior notes5,699
 
 
 
 
 20
 5,719
Subordinated notes
 1
 
 
 
 1,679
 1,680
Advances from Federal Home Loan Banks3,009
 2,013
 11
 2
 3
 108
 5,146
Securitizations and other Bank VIEs (1)
2,300
 3,200
 3,098
 
 
 43
 8,641
Other51
 194
 15
 
 9
 163
 432
Total Bank of America, N.A.11,059
 5,408
 3,124
 2
 12
 2,013
 21,618
Other debt             
Structured liabilities5,677
 2,340
 1,545
 870
 803
 7,339
 18,574
Nonbank VIEs (1)
22
 45
 
 
 
 1,165
 1,232
Other
 
 
 
 
 25
 25
Total other debt5,699
 2,385
 1,545
 870
 803
 8,529
 19,831
Total long-term debt$42,057
 $25,946
 $16,199
 $17,880
 $12,999
 $112,321
 $227,402
(1)
Represents the total long-term debt included in the liabilities of consolidated VIEs on the Consolidated Balance Sheet.
Trust Preferred and Hybrid Securities
Trust preferred securities (Trust Securities) are primarily issued by trust companies (the Trusts) that are not consolidated. These Trust Securities are mandatorily redeemable preferred security obligations of the Trusts. The sole assets of the Trusts generally are junior subordinated deferrable interest notes of the Corporation or its subsidiaries (the Notes). The Trusts generally are 100 percent-owned finance subsidiaries of the Corporation. Obligations associated with the Notes are included in the long-term debt table on page 150.
Certain of the Trust Securities were issued at a discount and may be redeemed prior to maturity at the option of the Corporation. The Trusts generally have invested the proceeds of such Trust Securities in the Notes. Each issue of the Notes has an interest rate equal to the corresponding Trust Securities distribution rate. The Corporation has the right to defer payment of interest on the Notes at any time or from time to time for a period not exceeding five years provided that no extension period may extend beyond the stated maturity of the relevant Notes. During any such
extension period, distributions on the Trust Securities will also be deferred, and the Corporation’s ability to pay dividends on its common and preferred stock will be restricted.
The Trust Securities generally are subject to mandatory redemption upon repayment of the related Notes at their stated maturity dates or their earlier redemption at a redemption price equal to their liquidation amount plus accrued distributions to the date fixed for redemption and the premium, if any, paid by the Corporation upon concurrent repayment of the related Notes.
Periodic cash payments and payments upon liquidation or redemption with respect to Trust Securities are guaranteed by the Corporation or its subsidiaries to the extent of funds held by the Trusts (the Preferred Securities Guarantee). The Preferred Securities Guarantee, when taken together with the Corporation’s other obligations including its obligations under the Notes, generally will constitute a full and unconditional guarantee, on a subordinated basis, by the Corporation of payments due on the Trust Securities.



151Bank of America 2017



The Trust Securities Summary table details the outstanding Trust Securities and the related Notes previously issued which remained outstanding at December 31, 2017.
            
Trust Securities Summary        
(Dollars in millions)

           
            
IssuerIssuance Date Aggregate Principal Amount of Trust Securities Aggregate Principal Amount of the Notes
Stated Maturity
of the Trust Securities
Per Annum Interest
Rate of the Notes
 
Interest Payment
Dates
 Redemption Period
   December 31, 2017      
Bank of America   
  
  
    
Capital Trust VIMarch 2005 $27
 $27
March 20355.63% Semi-Annual Any time
Capital Trust VII (1)
August 2005 6
 6
August 20355.25
 Semi-Annual Any time
Capital Trust XIMay 2006 658
 678
May 20366.63
 Semi-Annual Any time
Capital Trust XVMay 2007 1
 1
June 20563-mo. LIBOR + 80 bps
 Quarterly On or after 6/01/37
NationsBank   
  
  
    
Capital Trust IIIFebruary 1997 131
 135
January 20273-mo. LIBOR + 55 bps
 Quarterly On or after 1/15/07
BankAmerica   
    
    
Capital IIIJanuary 1997 103
 105
January 20273-mo. LIBOR + 57 bps
 Quarterly On or after 1/15/02
Fleet   
  
  
    
Capital Trust VDecember 1998 79
 82
December 20283-mo. LIBOR + 100 bps
 Quarterly On or after 12/18/03
BankBoston   
    
    
Capital Trust IIIJune 1997 53
 55
June 20273-mo. LIBOR + 75 bps
 Quarterly On or after 6/15/07
Capital Trust IVJune 1998 102
 106
June 20283-mo. LIBOR + 60 bps
 Quarterly On or after 6/08/03
MBNA   
    
    
Capital Trust BJanuary 1997 70
 73
February 20273-mo. LIBOR + 80 bps
 Quarterly On or after 2/01/07
Countrywide   
    
    
Capital IIIJune 1997 200
 206
June 20278.05
 Semi-Annual Only under special event
Capital VNovember 2006 1,495
 1,496
November 20367.00
 Quarterly On or after 11/01/11
Merrill Lynch   
    
    
Capital Trust IDecember 2006 1,050
 1,051
December 20666.45
 Quarterly On or after 12/11
Capital Trust IIIAugust 2007 750
 751
September 20677.375
 Quarterly On or after 9/12
Total  $4,725
 $4,772
  
    
(1)
Notes are denominated in British pound. Presentation currency is U.S. dollar.

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 (e.g.(i.e., syndicated or participated) to other financial institutions. The distributed amounts were $11.0$10.5 billion and $12.1$10.6 billion at December 31, 20172020 and 2016. At2019. The carrying value of these commitments at December 31, 2017, the carrying value of
these commitments,2020 and 2019, excluding commitments accounted for under the fair value option, was
$793 million, including deferred revenue of $16 million1.9 billion and a$829 million, which primarily related to the reserve for unfunded lending commitments of $777 million. At December 31, 2016, the comparable amounts were $779 million, $17 million and $762 million, respectively.commitments. The carrying value of these commitments is classified in accrued expenses and other liabilities on the Consolidated Balance Sheet.
The following table also includes the notional amount of commitments of $4.8 billion and $7.0 billion at December 31, 2017 and 2016 that are accounted for under the fair value option. However, the following table excludes cumulative net fair value of $120 million and $173 million on these commitments, which is classified in accrued expenses and other liabilities. For more information regarding the Corporation’s loan commitments accounted for under the fair value option, see Note 21 – Fair Value Option.

Bank of America 2017152


          
Credit Extension Commitments         
  
 Expire in One
Year or Less
 Expire After One
Year Through
Three Years
 Expire After Three Years Through Five Years Expire After Five
Years
 Total
(Dollars in millions)December 31, 2017
Notional amount of credit extension commitments 
  
  
  
  
Loan commitments$85,804
 $140,942
 $147,043
 $21,342
 $395,131
Home equity lines of credit6,172
 4,457
 2,288
 31,250
 44,167
Standby letters of credit and financial guarantees (1)
19,976
 11,261
 3,420
 1,144
 35,801
Letters of credit1,291
 117
 129
 87
 1,624
Legally binding commitments113,243
 156,777
 152,880
 53,823
 476,723
Credit card lines (2)
362,030
 
 
 
 362,030
Total credit extension commitments$475,273
 $156,777
 $152,880
 $53,823
 $838,753
          
 December 31, 2016
Notional amount of credit extension commitments 
  
  
  
  
Loan commitments$82,609
 $133,063
 $152,854
 $22,129
 $390,655
Home equity lines of credit8,806
 10,701
 2,644
 25,050
 47,201
Standby letters of credit and financial guarantees (1)
19,165
 10,754
 3,225
 1,027
 34,171
Letters of credit1,285
 103
 114
 53
 1,555
Legally binding commitments111,865
 154,621
 158,837
 48,259
 473,582
Credit card lines (2)
377,773
 
 
 
 377,773
Total credit extension commitments$489,638
 $154,621
 $158,837
 $48,259
 $851,355
(1)
The notional amounts of SBLCs and financial guarantees classified as investment grade and non-investment grade based on the credit quality of the underlying reference name within the instrument were $27.3 billion and $8.1 billion at December 31, 2017, and $25.5 billion and $8.3 billion at December 31, 2016. Amounts in the table include consumer SBLCs of $421 million and $376 million at December 31, 2017 and 2016.
(2)
Includes business card unused lines of credit.
Legally binding commitments to extend credit generally have specified rates and maturities. Certain of these commitments have adverse change clauses that help to protect the Corporation against deterioration in the borrower’s ability to pay.
The table below includes 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.
Bank of America 138


Credit Extension Commitments
Expire in One
Year or Less
Expire After One
Year Through
Three Years
Expire After Three Years Through
Five Years
Expire After
Five Years
Total
(Dollars in millions)December 31, 2020
Notional amount of credit extension commitments     
Loan commitments (1)
$109,406 $171,887 $139,508 $16,091 $436,892 
Home equity lines of credit710 2,992 8,738 29,892 42,332 
Standby letters of credit and financial guarantees (2)
19,962 12,038 2,397 1,257 35,654 
Letters of credit (3)
886 197 25 27 1,135 
Legally binding commitments130,964 187,114 150,668 47,267 516,013 
Credit card lines (4)
384,955 0 0 0 384,955 
Total credit extension commitments$515,919 $187,114 $150,668 $47,267 $900,968 
 December 31, 2019
Notional amount of credit extension commitments     
Loan commitments (1)
$97,454 $148,000 $173,699 $24,487 $443,640 
Home equity lines of credit1,137 1,948 6,351 34,134 43,570 
Standby letters of credit and financial guarantees (2)
21,311 11,512 3,712 408 36,943 
Letters of credit (3)
1,156 254 65 25 1,500 
Legally binding commitments121,058 161,714 183,827 59,054 525,653 
Credit card lines (4)
376,067 376,067 
Total credit extension commitments$497,125 $161,714 $183,827 $59,054 $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 and Other Variable Interest Entities.
(4)    Includes business card unused lines of credit.
Other Commitments
At December 31, 20172020 and 2016,2019, the Corporation had commitments to purchase loans (e.g., residential mortgage and commercial real estate) of $344$93 million and $767 million, and commitments to purchase commercial loans of $994 million and $636$86 million, which upon settlement will be included in trading account assets, loans or LHFS.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, 20172020 and 2016,2019, the Corporation had commitments to purchase commodities, primarily liquefied natural gas, of $1.5 billion$582 million and $1.9 billion,$830 million, which upon settlement will be included in trading account assets.
At December 31, 20172020 and 2016,2019, the Corporation had commitments to enter into resale and forward-dated resale and securities borrowing agreements of $56.8$66.5 billion and $48.9$97.2 billion, and commitments to enter into forward-dated repurchase and securities lending agreements of $34.3$32.1 billion and $24.4$24.9 billion. These commitments generally expire primarily within the next 12 months.
The Corporation has entered into agreements to purchase retail automobile loans from certain auto loan originators. These agreements provide for stated purchase amounts and contain cancellation provisions that allow the Corporation to terminate its commitment to purchase at any time, with a minimum notification period. At December 31, 20172020 and 2016, the Corporation’s maximum purchase commitment was $345 million and $475 million. In addition,2019, the Corporation hashad 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 up to $3.0 billion from a strategic partner during 2018.partner. This commitment extends through November 2022 and can be terminated with 12 months prior notice.
The Corporation is a party to operating leases for certain of its premises and equipment. Commitments under these leases are approximately $2.3 billion, $2.1 billion, $1.9 billion, $1.7 billion
and $1.4 billion for 2018 through 2022, respectively, and $5.1 billion in the aggregate for all years thereafter.
Other Guarantees
Bank-owned Life Insurance Book Value Protection
The Corporation sells products that offer book value protection to insurance carriers who offer group life insurance policies to corporations, primarily banks. At December 31, 20172020 and 2016,2019, the notional amount of these guarantees which is recorded as derivatives totaled $10.4$7.1 billion and $13.9$7.3 billion. At both December 31, 20172020 and 2016,2019, the Corporation’s maximum exposure related to these guarantees totaled $1.6 billion and $3.2$1.1 billion, with estimated maturity dates between 2033 and 2039. The net fair value including the fee receivable associated with these guarantees was $3 million and $4 million at December 31, 2017 and 2016, and reflects the probability of surrender as well as the multiple structural protection features in the contracts.
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

153Bank of America 2017



Corporation has assessed the probability of making such payments in the future as remote.
Merchant Services
In accordance with credit and debit card association rules, the Corporation sponsors merchant processing servicers that process credit and debit card transactions on behalf of various merchants. In connection with these services,Prior to July 1, 2020, a liability may arise in the event of a billing dispute between the merchant and a cardholder that is ultimately resolved in the cardholder’s favor. If the merchant defaults on its obligation to reimburse the cardholder, the cardholder, through its issuing bank, generally has until six months after the date of the transaction to present a chargeback to the merchant processor, which is primarily liable for any losses on covered transactions. However, if the merchant processor fails to meet its obligation to reimburse the cardholder for disputed transactions, then the Corporation, as the sponsor, could be held liable for the disputed amount. In 2017 and 2016, the sponsored entities processed and settled $812.2 billion and $731.4 billion of transactions and recorded losses of $28 million and $33 million. A significant portion of thisthe Corporation's merchant processing activity was processedperformed by a joint venture in which the Corporation holdsheld 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.
139 Bank of America


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 is recorded in other assets oninclude, but are not limited to, the Consolidated Balance Sheettype of charge, type of payment used and in All Other. At bothtime limits. For the six-months ended December 31, 20172020, 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 2016, the carrying value of the Corporation’s investment inlosses incurred related to the merchant services joint venture was $2.9 billion.
Asprocessing activity were not significant. The Corporation continues to monitor its exposure in this area due to the potential economic impacts of December 31, 2017 and 2016, the maximum potential exposure for sponsored transactions totaled $346.4 billion and $325.7 billion. However, the Corporation believes that the maximum potential exposure is not representative of the actual potential loss exposure and does not expect to make material payments in connection with these guarantees.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 potential forCorporation has assessed the Corporation to be required to make theseprobability of making any such payments isas 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 firmCorporation 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 program, the Corporation guarantees the payment and performance of its sponsored members to the Fixed Income Clearing Corporation. The Corporation’s guarantee obligation is
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 potential future paymentpayments under these agreements wasare approximately $5.9$8.8 billion and $6.7$8.7 billion at December 31, 20172020 and 2016.2019. The estimated maturity dates of these obligations extend up to 2040.2049. 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.
In the normal course of business, the Corporation periodically guarantees the obligations of its affiliates in a variety of transactions including ISDA-related transactions and non-ISDA related transactions such as commodities trading, repurchase agreements, prime brokerage agreements and other transactions.
Payment Protection Insurance Claims MatterGuarantees of Certain Long-term Debt
On June 1, 2017,The Corporation, as the parent company, fully and unconditionally guarantees the securities issued by BofA Finance LLC, a consolidated finance subsidiary of the Corporation, sold its non-U.S. consumer credit card business. Includedand effectively provides for the full and unconditional guarantee of trust securities issued by certain statutory trust companies that are 100 percent owned finance subsidiaries of the Corporation.
Representations and Warranties Obligations and Corporate Guarantees
The Corporation securitizes first-lien residential mortgage loans generally in the calculationform 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
Bank of America 140


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 gain on sale,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 an obligationfor these exposures; however, the Corporation does not expect such amounts to indemnifybe material to the purchaserCorporation's financial condition and liquidity. See Litigation and Regulatory Matters below for substantially all PPI exposure above reserves assumed by the purchaser.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 what the eventual outcome of the pending matters, will be, what the timing of the ultimate resolution of these matters, will be, or what the eventual loss, fines or penalties related to each pending matter may be.matter.
In accordance with applicable accounting guidance, the Corporation establishes an accrued liability when those matters present loss contingencies that are both probable and estimable. In such cases, there may be an exposure to loss in excess of any amounts accrued. As a matter develops, the Corporation, in conjunction with any outside counsel handling the matter, evaluates on an ongoing basis whether such matter presents a loss contingency that is probable and estimable.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 $753$823 million and $681 million was recognized for 2017 compared to $1.2 billion for 2016.
in 2020 and 2019.


Bank of America 2017154


For a limited number of the matters disclosed in this Note for which a loss whetherin future periods is reasonably possible and estimable (whether in excess of a relatedan accrued liability or where there is no accrued liability, is reasonably possible in future periods,liability) and for representations and warranties exposures, the Corporation is able to estimate a range of possible loss. In determining whether it is possible to estimate a range of possible loss, the Corporation reviews and evaluates its matters on an ongoing basis, in conjunction with any outside counsel handling the matter, in light of potentially relevant factual and legal developments. In cases in which the Corporation possesses sufficient appropriate information to estimate a range of possible loss, that estimate is aggregated and disclosed below. There may be other disclosed matters for which a loss is probable or reasonably possible but such an estimate of the range of possible loss may not be possible. For those matters where an estimate of the range of possible loss is possible, management currently estimates the aggregateCorporation’s estimated range of possible loss is $0 to $1.3
billion in excess of the accrued liability, (if any) related to those matters. Thisif any, as of December 31, 2020.
The accrued liability and estimated range of possible loss isare based upon currently available information and is subject to significant judgment, and a variety of assumptions and known and unknown uncertainties. The matters underlying the accrued liability and estimated range willof possible loss are unpredictable and may change from time to time, and actual resultslosses may vary significantly from the current estimate. Therefore, thisestimate and accrual. The estimated range of possible loss represents what the Corporation believes to be an estimate of possible loss only for certain matters meeting these criteria. It does not represent the Corporation’s maximum loss exposure.
Information is provided below regarding the nature of all of these contingenciesthe litigation and where specified, the amount of the claim associated with these loss contingencies.claimed damages. Based on current knowledge, and taking into account accrued 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 positioncondition or liquidity of the Corporation. However, in light of the inherentsignificant 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 or liquidity for any particular reporting period.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 fivefour 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 assertasserts 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, Countrywide and otherseveral Countrywide entities are named as defendants in an action filed on September 29,28, 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 unspecified punitive damages.
On May 16, 2017, the First Department issued its decisiondecisions on the parties’parties' cross-appeals of the trial court’scourt's October 22, 2015 summary judgment rulings. Among other things,Ambac appealed the First Department reversed on the applicability of New York insurance lawDepartment's rulings requiring Ambac to Ambac’s common-law fraud claim, ruling that Ambac must prove all of the elements of its fraudulent inducement claim, including justifiable reliance and loss causation; reversed as to Ambac’srestricting Ambac's sole remedy for its breach of contract claims finding that Ambac’s sole remedy isto the repurchase protocol of cure, repurchasesrepurchase or substitution of any materially defective loan; affirmed the trial court’s ruling that Ambac’s compensatory damages claim was an impermissible request for rescissory damages; reversed the dismissal of Ambac’s claim for reimbursement of claims payments, but affirmed the dismissal of Ambac’sand dismissing Ambac's claim for reimbursements of attorneys’ fees; and reversed as toattorneys' fees. On June 27, 2018, the meaningNew York Court of specific representations and warranties, ruling that disputed issues of fact precluded summary judgment. On July 25, 2017,Appeals affirmed the First Department grantedrulings that Ambac appealed.
141 Bank of America


On December 4, 2020, the New York Supreme Court dismissed Ambac’s motion for leave to appeal tofraudulent inducement claim. Ambac appealed the Court of Appeals. That appeal is pending. 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 liability against the Corporation. Ambac claimsseeks damages in excess of $600 million, plus punitive damages. On December 19, 2016, the Court granted in part and denied in part Countrywide’s motion to dismiss the complaint.
Ambac v. Countrywide III
On December 30, 2014, Ambac filed an action in Wisconsin state court against Countrywide. The complaint seeks damages in excess of $350 million plus punitive damages. Countrywide has challenged the Wisconsin courts’ jurisdiction over it. Following a ruling by the lower court that jurisdiction did not exist, the Wisconsin Court of Appeals reversed. On June 30, 2017, the Wisconsin Supreme Court reversed the decision of the Wisconsin Court of Appeals and held that Countrywide did not consent to the jurisdiction of the Wisconsin courts and remanded the case to the Court of Appeals for further consideration of whether specific jurisdiction exists. On December 14, 2017, the Wisconsin Court of Appeals ruled that specific jurisdiction over Countrywide does not exist for this matter. On January 16, 2018, Ambac asked the Wisconsin Supreme Court to review the decision of the Court of Appeals.

155Bank of America 2017



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.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 simultaneously moved to stayappealed the action pending resolution of its appeal in Ambac v. Countrywide III. Countrywide moved to dismiss the complaint. On September 20, 2016, the Court granted Ambac’s motion to stay the action pending resolution of Ambac v. Countrywide III.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, (MLPF&S) in New York Supreme Court relating to guaranty insurance Ambac provided on a First Franklin securitization sponsored by Merrill Lynch. The complaint alleges fraudulent inducement and breach of contract, including breach of contract claims against BANA based upon its servicing of the loans in the securitization. The complaint alleges that Ambac has paidseeks as damages hundreds of millions of dollars in claims and has accrued and continues to accrue tens of millions of dollars in additional claims.that Ambac seeks as damages the total claimsalleges it has paid and its projected future claims payment obligations, as well as specific performance of defendants’ contractual repurchase obligations.
ATM Access Fee Litigation
On January 10, 2012, a putative consumer class action was filedor will pay in U.S. District Court for the District of Columbia against Visa, Inc., MasterCard, Inc. and several financial institutions, including the Corporation and BANA alleging that surcharges paid at financial institution ATMs are artificially inflated by Visa and MasterCard rules and regulations. The network rules are alleged to be the product of a conspiracy between Visa, MasterCard and financial institutions in violation of Section 1 of the Sherman Act. Plaintiffs seek compensatory and treble damages and injunctive relief.
On February 13, 2013, the District Court granted defendants’ motion to dismiss. On August 4, 2015, the U.S. Court of Appeals for the District of Columbia Circuit vacated the District Court’s decision and remanded the case to the District Court, where proceedings have resumed.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.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.
Interchange and Related Litigation
In 2005, a group of merchants filed a series of putative class actions and individual actions directed at interchange fees associated with Visa and MasterCard payment card transactions. These actions, which were consolidated in On March 27, 2018, the U.S. District Court for the Eastern District of New York underColumbia denied BANA’s partial motion to dismiss certain of the caption In re Payment Card Interchange Fee and Merchant Discount Anti-Trust Litigation (Interchange), named Visa, MasterCard and several banks and bank holding companies, including the Corporation, as defendants. Plaintiffs allege that defendants conspired to fix the level of default interchange rates and that certain rules of Visa and MasterCard were unreasonable restraints of trade. Plaintiffs sought compensatory and treble damages and injunctive relief.FDIC’s claims.
On October 19, 2012, defendants reached a proposed settlement that would have provided for, among other things, (i) payments by defendants to the class and individual plaintiffs totaling approximately $6.6 billion, allocated to each defendant based upon various loss-sharing agreements; (ii) distribution to class merchants of an amount equal to 10 basis points (bps) of default interchange across all Visa and MasterCard credit card transactions; and (iii) modifications to certain Visa and MasterCard rules. Although the District Court approved the class settlement agreement, the U.S. Court of Appeals for the Second Circuit reversed the decision on appeal. The Interchange class case was remanded to the District Court, where proceedings have resumed.
In addition to the class actions, a number of merchants filed individual actions against the defendants. The Corporation was named as a defendant in one such individual action. In addition, a number of individual actions were filed that do not name the Corporation as a defendant. As a result of various loss-sharing agreements, however, the Corporation remains liable for any settlement or judgment in these individual suits where it is not named as a defendant.


Bank of America 2017156


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, a significant number of FX market participants, including the Corporation
and its subsidiaries regarding FX market participants’ conduct and systems and controls. Government authorities also continue to conduct investigations concerning conduct and systems and controls of panel banks in connection with the setting of other reference rates as well as the trading of government, sovereign, supranational and agency bonds.bonds in connection with conduct and systems and controls. The Corporation is responding to and cooperating with these proceedingsinquiries and investigations.investigations, and responding to the proceedings.
In addition, theLIBOR
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, (CEA), Racketeer Influenced and Corrupt Organizations (RICO), Securities Exchange Act of 1934, (Exchange Act), common law fraud and breach of contract claims, and seek 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 have been consolidated for pre-trial purposesare pending in the U.S. District Court for the Southern District of New York.
In a series of rulings beginning in March 2013, theThe District Court has dismissed antitrust,all RICO Exchange Actclaims, and certain state law claims, dismissed all manipulation claims against Bank of America entities based on alleged trader conduct as to the Corporation and BANA, andconduct. The District Court has also substantially limited the scope of CEAantitrust, Commodity Exchange Act and various other claims. On May 23, 2016, the U.S. Court of Appeals for the Second Circuit reversed the District Court’s dismissal of the antitrust claims, including by dismissing in their entirety certain individual and remanded for further proceedings in the District Court, and on December 20, 2016, the District Court again dismissed certainputative class plaintiffs’ antitrust claims in their entirety and substantially limited the scopefor lack of the remaining antitrust claims.
Certain antitrust, CEA and state law claims remain pending in the District Court against the Corporation, BANA and certain Merrill Lynch entities, and the Court is continuing to consider motions regarding them.standing and/or personal jurisdiction. Plaintiffs whose antitrust Exchange Act and/or state law claims were previously dismissed by the District Court are pursuing appeals in the Second Circuit.
In addition, Certain individual and putative class actions remain pending against the Corporation, BANA and MLPF&S were named as defendants along with other FX market participants incertain Merrill Lynch entities.
On February 28, 2018, the District Court granted certification of a putative class action filed inof persons that purchased OTC swaps and notes that referenced U.S. dollar LIBOR from one of the U.S. Districtdollar LIBOR panel banks, limited to claims under Section 1 of the Sherman Act. The U.S. Court of Appeals for the Southern DistrictSecond Circuit subsequently denied a petition filed by the defendants for interlocutory appeal of New York, in which plaintiffs allege that they sustained losses as a result of the defendants’ alleged conspiracy to manipulate the prices of over-the-counter FX transactions and FX transactions on an exchange. Plaintiffs assert antitrust claims and claims for violations of the CEA and seek compensatory and treble damages, as well as declaratory and injunctive relief. On October 1, 2015, the Corporation, BANA and MLPF&S executed a final settlement agreement, in which they agreed to pay $187.5 million to settle the litigation. The settlement is subject to final District Court approval.
Mortgage-backed Securities Litigation
The Corporation and its affiliates, Countrywide entities and their affiliates, and Merrill Lynch entities and their affiliates have been named as defendants in cases relating to their various roles in MBS offerings and,in certain instances, have received claims for contractual indemnification related to the MBS securities actions. Plaintiffs in these cases generally sought unspecified compensatory and/or rescissory damages, unspecified costs and legal fees and generally alleged false and misleading statements. The indemnification claims include claims from underwriters of MBS that were issued by these entities, and from underwriters and issuers of MBS backed by loans originated by these entities.
Mortgage Repurchase Litigationruling.
U.S. Bank - Harborview and SURF/OWNIT Repurchase Litigation
On August 29,Beginning in 2011, U.S. Bank, National Association (U.S. Bank), as trustee for the HarborView Mortgage Loan Trust 2005-10 (the Trust), a mortgage pool backed by loans originated byand various SURF/OWNIT RMBS trusts filed complaints against the Corporation, Countrywide Home Loans, Inc. (CHL), filed a complaintentities, Merrill Lynch entities and other affiliates in New York Supreme Court in a case entitled U.S. Bank National Association, as Trustee for HarborView Mortgage Loan Trust, Series 2005-10 v. Countrywide Home Loans, Inc. (dba Bank of America Home Loans), Bank of America Corporation, Countrywide Financial Corporation, Bank of America, N.A. and NB Holdings Corporation, alleging breaches of representations and warranties. This litigation has been stayed since March 23, 2017, pending finalization of the settlement discussed below.
On December 5, 2016, theThe defendants and certain certificate-holders in the Trusttrusts agreed to settle the litigationrespective matters in an amountamounts not material to the Corporation, subject to acceptance by U.S. Bank. U.S. Bank has initiated a trust instruction proceeding in Minnesota state court relating to the proposed settlement, and that proceeding is ongoing.
U.S. Bank - SURF/OWNIT Repurchase Litigation
On August 29, 2014 and September 2, 2014, U.S. Bank, solely in its capacity as Trustee for seven securitization trusts (the Trusts), served seven summonses with notice commencing actions against First Franklin Financial Corporation, Merrill Lynch Mortgage Lending, Inc., Merrill Lynch Mortgage Investors, Inc. (MLMI) and Ownit Mortgage Solutions Inc. in New York Supreme Court. The summonses advance breach of contract claims alleging that defendants breached representations and warranties related to loans securitized in the Trusts. The summonses allege that defendants failed to repurchase breaching mortgage loans from the Trusts, and seek specific performance of defendants’ alleged obligation to repurchase breaching loans, declaratory judgment, compensatory, rescissory and other damages, and indemnity.
On February 25, 2015 and March 11, 2015, U.S. Bank served complaints regarding fourlitigations have been stayed pending finalization of the seven Trusts. On December 7, 2015, the Court granted in part and denied in part defendants’ motion to dismiss the complaints. The Court dismissed claims for breach of representations and warranties against MLMI, dismissed U.S. Bank’s claims for indemnity and attorneys’ fees, and deferred a ruling regarding defendants’ alleged failure to provide notice of alleged representations and warranties breaches, but upheld the complaints in all other respects. On December 28, 2016, U.S. Bank filed a complaint with respect to a fifth Trust.

settlements.

Bank of America 142


NOTE 13 Shareholders’ Equity
Common Stock
157Bank of America 2017



NOTE 13 Shareholders’ Equity
Common Stock
       
Declared Quarterly Cash Dividends on Common Stock (1)
       
Declaration Date Record Date Payment Date Dividend Per Share
January 31, 2018 March 2, 2018 March 30, 2018 $0.12
October 25, 2017 December 1, 2017 December 29, 2017 0.12
July 26, 2017 September 1, 2017 September 29, 2017 0.12
April 26, 2017 June 2, 2017 June 30, 2017 0.075
January 26, 2017 March 3, 2017 March 31, 2017 0.075
Declared Quarterly Cash Dividends on Common Stock (1)
In 2017 and through February 22, 2018.
Declaration DateRecord DatePayment DateDividend Per Share
January 19, 2021March 5, 2021March 26, 2021$0.18 
October 21, 2020December 4, 2020December 24, 20200.18 
July 22, 2020September 4, 2020September 25, 20200.18 
April 22, 2020June 5, 2020June 26, 20200.18 
January 29, 2020March 6, 2020March 27, 20200.18 
(1)In 2020, and through February 24, 2021.
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 2017, 20162020, 2019 and 2015.2018.
Common Stock Repurchase Summary
(in millions)202020192018
Total share repurchases, including CCAR
capital plan repurchases
227 956 676 
Purchase price of shares repurchased
and retired
CCAR capital plan repurchases$7,025 $25,644 $16,754 
Other authorized repurchases0 2,500 3,340 
Total shares repurchased$7,025 $28,144 $20,094 
    
Common Stock Repurchase Summary
    
(in millions)201720162015
Total share repurchases, including CCAR capital plan repurchases509
333
140
    
Purchase price of shares repurchased and retired (1)
   
CCAR capital plan repurchases$9,347
$4,312
$2,374
Other authorized repurchases3,467
800

Total shares repurchased$12,814
$5,112
$2,374
(1)
Represents reductions to shareholders’ equity due to common stock repurchases.
On June 28, 2017, following the Federal Reserve’s non-objection to the Corporation’s 2017 Comprehensive Capital Analysis and Review (CCAR) capital plan,During 2020, the Board of Directors (Board) authorizedGovernors 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 $12.0 billion2020, 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.
The Federal Reserve’s directives regarding share repurchases aligned with the Corporation's decision 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.
During 2020, the Corporation repurchased and retired 227 million shares of common stock, from July 1, 2017 through June 30, 2018, plus repurchases expected to be approximately $900 million to offset the effect of equity-based compensation plans during the same period. The common stock repurchase authorization includes both common stock and warrants. The Corporation’s 2017 capital plan also included a request to increase the quarterly common stock dividend from $0.075 per share to $0.12 per share. On December 5, 2017, following approvalwhich reduced shareholders’ equity by the Federal Reserve, the Board authorized the repurchase of an additional $5.0 billion of common stock through June 30, 2018.$7.0 billion.
In 2017, the Corporation repurchased $12.8 billion of common stockDuring 2020, in connection with the 2017 and 2016 CCAR capitalemployee stock plans, and pursuant to other repurchases approved by the Board and the Federal Reserve. Other authorized repurchases included $1.8 billion of common stock pursuant to the Corporation’s plan announced on January 13, 2017 and $1.7 billion under the authorization announced on December 5, 2017.
At December 31, 2017, the Corporation had warrants outstanding and exercisable to purchase 122issued 66 million shares of its common stock expiring on October 28, 2018, and, warrants outstanding and exercisable to purchase 143 million shares of common stock expiring on January 16, 2019. These warrants were originally issued in connection with preferred stock issuances to the U.S. Department of the Treasury in 2009 and 2008, and are listed on the New York Stock Exchange. The exercise price of the warrants expiring on January 16, 2019 is subject to continued adjustment each time the quarterly cash dividend is in excess of $0.01 per common share to compensate the holders of the warrants for dilution resulting from an increased dividend. The Corporation had cash dividends of $0.12 per share for the third
and fourth quarters of 2017, and cash dividends of $0.075 per share for the first and second quarter of 2017, or $0.39 per share for the year, resulting in an adjustment to the exercise price of these warrants in each quarter. As a result of the Corporation’s 2017 dividends of $0.39 per common share, the exercise price of the warrants expiring on January 16, 2019 was adjusted to $12.757 per share. The warrants expiring on October 28, 2018, which have an exercise price of $30.79 per share, also contain this anti-dilution provision except the adjustment is triggered only when the Corporation declares quarterly dividends at a level greater than $0.32 per common share.
On August 24, 2017, the holders of the Corporation’s Series T 6% Non-cumulative preferred stock (Series T) exercised warrants to acquire 700 million shares of the Corporation’s common stock. The carrying value of the preferred stock was $2.9 billion and, upon conversion, was recorded as additional paid-in capital. For more information, see Note 15 – Earnings Per Common Share.
In connection with employee stock plans, in 2017, the Corporation issued approximately 66 million shares andsatisfy tax withholding obligations, repurchased approximately 2726 million shares of its common stock to satisfy tax withholding obligations.stock.At December 31, 2017,2020, the Corporation had reserved 869513 million unissued shares of common stock for future issuances under employee stock plans, common stock warrants, convertible notes and preferred stock.
Preferred Stock
The cash dividends declared on preferred stock were $1.6$1.4 billion, $1.7$1.4 billion and $1.5 billion for 2017, 20162020, 2019 and 2015,2018, 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
fixed-rate period, then quarterly during the floating-rate period. The following table presents a summary of perpetualSeries MM preferred stock outstanding at December 31, 2017.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 three3 or more semi-annual or six6 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 two2 additional directors. These voting rights terminate when the Corporation has paid in full dividends on these series for at least two2 semi-annual or four4 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

Bank of America 2017158


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.

              
Preferred Stock Summary          
              
(Dollars in millions, except as noted)            
SeriesDescription Initial
Issuance
Date
 Total
Shares
Outstanding
 Liquidation
Preference per Share
(in dollars)
 
Carrying
Value 
(1)
 Per Annum
Dividend Rate
 
Redemption Period (2)
Series B7% Cumulative Redeemable June
1997
 7,110
 $100
 $1
 7.00% n/a
Series D (3)
6.204% Non-Cumulative September
2006
 26,174
 25,000
 654
 6.204% On or after
September 14, 2011
Series E (3)
Floating Rate Non-Cumulative November
2006
 12,691
 25,000
 317
 
3-mo. LIBOR + 35 bps (4)

 On or after
November 15, 2011
Series FFloating Rate Non-Cumulative March
2012
 1,409
 100,000
 141
 
3-mo. LIBOR + 40 bps (4)

 On or after
March 15, 2012
Series GAdjustable Rate Non-Cumulative March
2012
 4,926
 100,000
 493
 
3-mo. LIBOR + 40 bps (4)

 On or after
March 15, 2012
Series I (3)
6.625% Non-Cumulative September
2007
 14,584
 25,000
 365
 6.625% On or after
October 1, 2017
Series K (5)
Fixed-to-Floating Rate Non-Cumulative January
2008
 61,773
 25,000
 1,544
 8.00% to, but excluding, 1/30/18; 3-mo. LIBOR + 363 bps thereafter
 On or after
January 30, 2018
Series L7.25% Non-Cumulative Perpetual Convertible January
2008
 3,080,182
 1,000
 3,080
 7.25% n/a
Series M (5)
Fixed-to-Floating Rate Non-Cumulative April
2008
 52,399
 25,000
 1,310
 8.125% to, but excluding, 5/15/18; 3-mo. LIBOR + 364 bps thereafter
 On or after
May 15, 2018
Series T (6)
6% Non-cumulative September
2011
 354
 100,000
 35
 6.00% After May 7, 2019
Series U (5)
Fixed-to-Floating Rate Non-Cumulative May
2013
 40,000
 25,000
 1,000
 5.2% to, but excluding, 6/1/23;
3-mo. LIBOR + 313.5 bps thereafter

 On or after
June 1, 2023
Series V (5)
Fixed-to-Floating Rate Non-Cumulative June
2014
 60,000
 25,000
 1,500
 5.125% to, but excluding, 6/17/19; 3-mo. LIBOR + 338.7 bps thereafter
 On or after
June 17, 2019
Series W (3)
6.625% Non-Cumulative September 2014 44,000
 25,000
 1,100
 6.625% On or after
September 9, 2019
Series X (5)
Fixed-to-Floating Rate Non-Cumulative September 2014 80,000
 25,000
 2,000
 6.250% to, but excluding, 9/5/24; 3-mo. LIBOR + 370.5 bps thereafter
 On or after
September 5, 2024
Series Y (3)
6.500% Non-Cumulative January 2015 44,000
 25,000
 1,100
 6.500% On or after
January 27, 2020
Series Z (5)
Fixed-to-Floating Rate Non-Cumulative October 2014 56,000
 25,000
 1,400
 6.500% to, but excluding,10/23/24; 3-mo. LIBOR + 417.4 bps thereafter
 On or after
October 23, 2024
Series AA (5)
Fixed-to-Floating Rate Non-Cumulative March 2015 76,000
 25,000
 1,900
 6.100% to, but excluding, 3/17/25; 3-mo. LIBOR + 389.8 bps thereafter
 On or after
March 17, 2025
Series CC (3)
6.200% Non-Cumulative January 2016 44,000
 25,000
 1,100
 6.200% On or after
January 29, 2021
Series DD (5)
Fixed-to-Floating Rate Non-Cumulative March 2016 40,000
 25,000
 1,000
 6.300% to, but excluding, 3/10/26; 3-mo. LIBOR + 455.3 bps thereafter
 On or after
March 10, 2026
Series EE (3)
6.000% Non-Cumulative April 2016 36,000
 25,000
 900
 6.000% On or after
April 25, 2021
Series 1 (7)
Floating Rate Non-Cumulative November
2004
 3,275
 30,000
 98
 
3-mo. LIBOR + 75 bps (8)

 On or after
November 28, 2009
Series 2 (7)
Floating Rate Non-Cumulative March
2005
 9,967
 30,000
 299
 
3-mo. LIBOR + 65 bps (8)

 On or after
November 28, 2009
Series 3 (7)
6.375% Non-Cumulative November
2005
 21,773
 30,000
 653
 6.375% On or after
November 28, 2010
Series 4 (7)
Floating Rate Non-Cumulative November
2005
 7,010
 30,000
 210
 
3-mo. LIBOR + 75 bps (4)

 On or after
November 28, 2010
Series 5 (7)
Floating Rate Non-Cumulative March
2007
 14,056
 30,000
 422
 
3-mo. LIBOR + 50 bps (4)

 On or after
May 21, 2012
Total    3,837,683
  
 $22,622
  
  
(1)143 Bank of America
Amounts shown are before third-party issuance costs and certain book value adjustments of $299 million.
(2)


The table below presents a summary of perpetual preferred stock outstanding at December 31, 2020.
Preferred Stock Summary
(Dollars in millions, except as noted)
SeriesDescriptionInitial
Issuance
Date
Total
Shares
Outstanding
Liquidation
Preference
per Share
(in dollars)
Carrying
Value
Per Annum
Dividend Rate
Dividend per Share
(in dollars)
Annual Dividend
Redemption Period (1)
Series B7% Cumulative RedeemableJune
1997
7,110 $100 $7.00 %$$n/a
Series E (2)
Floating Rate Non-CumulativeNovember
2006
12,691 25,000 317 
3-mo. LIBOR + 35 bps (3)
1.02 13 On or after
November 15, 2011
Series FFloating Rate Non-CumulativeMarch
2012
1,409 100,000 141 
3-mo. LIBOR + 40 bps (3)
4,066.67 On or after
March 15, 2012
Series GAdjustable Rate Non-CumulativeMarch
2012
4,926 100,000 493 
3-mo. LIBOR + 40 bps (3)
4,066.67 20 On or after
March 15, 2012
Series L7.25% Non-Cumulative Perpetual ConvertibleJanuary
2008
3,080,182 1,000 3,080 7.25 %72.50 223 n/a
Series T 6% Non-cumulativeSeptember
2011
354 100,000 35 6.00 %6,000.00 After May 7, 2019
Series U (4)
Fixed-to-Floating Rate Non-CumulativeMay
2013
40,000 25,000 1,000 5.2% to, but excluding, 6/1/23; 3-mo. LIBOR + 313.5 bps thereafter52.00 52 On or after
June 1, 2023
Series X (4)
Fixed-to-Floating Rate Non-CumulativeSeptember
2014
80,000 25,000 2,000 6.250% to, but excluding, 9/5/24; 3-mo. LIBOR + 370.5 bps thereafter62.50 125 On or after
September 5, 2024
Series Z (4)
Fixed-to-Floating Rate Non-CumulativeOctober
2014
56,000 25,000 1,400 6.500% to, but excluding, 10/23/24; 3-mo. LIBOR + 417.4 bps thereafter65.00 91 On or after
October 23, 2024
Series AA (4)
Fixed-to-Floating Rate Non-CumulativeMarch
2015
76,000 25,000 1,900 6.100% to, but excluding, 3/17/25; 3-mo. LIBOR + 389.8 bps thereafter61.00 116 On or after
March 17, 2025
Series CC (2)
6.200% Non-CumulativeJanuary
2016
44,000 25,000 1,100 6.200 %1.55 68 On or after
January 29, 2021
Series DD (4)
Fixed-to-Floating Rate Non-CumulativeMarch
2016
40,000 25,000 1,000 6.300% to, but excluding, 3/10/26; 3-mo. LIBOR + 455.3 bps thereafter63.00 63 On or after
March 10, 2026
Series EE (2)
6.000% Non-CumulativeApril
2016
36,000 25,000 900 6.000 %1.50 54 On or after
April 25, 2021
Series FF (4)
Fixed-to-Floating Rate Non-CumulativeMarch
2018
94,000 25,000 2,350 5.875% to, but excluding, 3/15/28; 3-mo. LIBOR + 293.1 bps thereafter58.75 138 On or after
March 15, 2028
Series GG (2)
6.000% Non-CumulativeMay
2018
54,000 25,000 1,350 6.000 %1.50 81 On or after
May 16, 2023
Series HH (2)
5.875% Non-CumulativeJuly
2018
34,160 25,000 854 5.875 %1.47 50 On or after
July 24, 2023
Series JJ (4)
Fixed-to-Floating Rate Non-CumulativeJune
2019
40,000 25,000 1,000 5.125% to, but excluding, 6/20/24; 3-mo. LIBOR + 329.2 bps thereafter51.25 51 On or after
June 20, 2024
Series KK (2)
5.375% Non-CumulativeJune
2019
55,900 25,000 1,398 5.375 %1.34 75 On or after
June 25, 2024
Series LL (2)
5.000% Non-CumulativeSeptember
2019
52,400 25,000 1,310 5.000 %1.25 66 On or after
September 17, 2024
Series MM (4)
Fixed-to-Floating Rate Non-CumulativeJanuary
2020
44,000 25,000 1,100 4.300 %43.48 48 On or after
January 28, 2025
Series NN (2)
4.375% Non-CumulativeOctober
2020
44,000 25,000 1,100 4.375 %0.29 13 On or after
November 3, 2025
Series 1 (5)
Floating Rate Non-CumulativeNovember
2004
3,275 30,000 98 
3-mo. LIBOR + 75 bps (6)
0.75 On or after
November 28, 2009
Series 2 (5)
Floating Rate Non-CumulativeMarch
2005
9,967 30,000 299 
3-mo. LIBOR + 65 bps (6)
0.76 10 On or after
November 28, 2009
Series 4 (5)
Floating Rate Non-CumulativeNovember
2005
7,010 30,000 210 
3-mo. LIBOR + 75 bps (3)
1.02 On or after
November 28, 2010
Series 5 (5)
Floating Rate Non-CumulativeMarch
2007
14,056 30,000 422 
3-mo. LIBOR + 50 bps (3)
1.02 17 On or after
May 21, 2012
Issuance costs and certain adjustments(348)
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.
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.
(3)
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.
(4)
Subject to 4.00% minimum rate per annum.
(5)
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.
(6)
Represents shares that were not surrendered when the holders of Series T preferred stock exercised warrants to acquire 700 million shares of common stock in the third quarter of 2017.
(7)
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.
(8)
Subject to 3.00% minimum rate per annum.
n/a = not applicable


159Bank of America 2017144




NOTE 14Accumulated Other Comprehensive Income (Loss)
The table below presents the changes in accumulated OCI after-tax for 2015, 20162020, 2019 and2017. 2018.
(Dollars in millions)(Dollars in millions)Debt SecuritiesDebit Valuation AdjustmentsDerivativesEmployee
Benefit Plans
Foreign
Currency
Total
             
(Dollars in millions)
Debt
Securities
 
Available-for-
Sale Marketable
Equity Securities
 Debit Valuation Adjustments Derivatives 
Employee
Benefit Plans
 
Foreign
Currency (1)
 Total
Balance, December 31, 2014$1,641
 $17
 n/a
 $(1,661) $(3,350) $(669) $(4,022)
Cumulative adjustment for accounting change
 
 $(1,226) 
 
 
 (1,226)
Balance, December 31, 2017Balance, December 31, 2017$(1,206)$(1,060)$(831)$(3,192)$(793)$(7,082)
Accounting change related to certain tax effectsAccounting change related to certain tax effects(393)(220)(189)(707)239 (1,270)
Cumulative adjustment for hedge accounting changeCumulative adjustment for hedge accounting change57 57 
Net change(1,625) 45
 615
 584
 394
 (123) (110)Net change(3,953)749 (53)(405)(254)(3,916)
Balance, December 31, 2015$16
 $62
 $(611) $(1,077) $(2,956) $(792) $(5,358)
Balance, December 31, 2018Balance, December 31, 2018$(5,552)$(531)$(1,016)$(4,304)$(808)$(12,211)
Net change(1,315) (30) (156) 182
 (524) (87) (1,930)Net change5,875 (963)616 136 (86)5,578 
Balance, December 31, 2016$(1,299) $32
 $(767) $(895) $(3,480) $(879) $(7,288)
Balance, December 31, 2019Balance, December 31, 2019$323 $(1,494)$(400)$(4,168)$(894)$(6,633)
Net change91
 (30) (293) 64
 288
 86
 206
Net change4,799 (498)826 (98)(52)4,977 
Balance, December 31, 2017$(1,208) $2
 $(1,060) $(831) $(3,192) $(793) $(7,082)
Balance, December 31, 2020Balance, December 31, 2020$5,122 $(1,992)$426 $(4,266)$(946)$(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 before-pre- and after-tax for 2017, 20162020, 2019 and 2015.2018.
PretaxTax
effect
After-
tax
PretaxTax
effect
After-
tax
PretaxTax effectAfter-
tax
(Dollars in millions)202020192018
Debt securities:
Net increase (decrease) in fair value$6,819 $(1,712)$5,107 $8,020 $(2,000)$6,020 $(5,189)$1,329 $(3,860)
Net realized (gains) reclassified into earnings (1)
(411)103 (308)(193)48 (145)(123)30 (93)
Net change6,408 (1,609)4,799 7,827 (1,952)5,875 (5,312)1,359 (3,953)
Debit valuation adjustments:
Net increase (decrease) in fair value(669)156 (513)(1,276)289 (987)952 (224)728 
Net realized losses reclassified into earnings (1)
19 (4)15 18 24 26 (5)21 
Net change(650)152 (498)(1,258)295 (963)978 (229)749 
Derivatives:
Net increase (decrease) in fair value1,098 (268)830 692 (156)536 (232)74 (158)
Reclassifications into earnings:
Net interest income6 (1)5 104 (26)78 165 (40)125 
Compensation and benefits expense(12)3 (9)(27)(20)
Net realized (gains) losses reclassified into earnings(6)2 (4)106 (26)80 138 (33)105 
Net change1,092 (266)826 798 (182)616 (94)41 (53)
Employee benefit plans:
Net increase (decrease) in fair value(381)80 (301)41 (21)20 (703)164 (539)
Net actuarial losses and other reclassified into earnings (2)
261 (63)198 150 (36)114 171 (46)125 
Settlements, curtailments and other5 0 5 (1)11 (2)
Net change(115)17 (98)194 (58)136 (521)116 (405)
Foreign currency:
Net (decrease) in fair value(251)199 (52)(13)(52)(65)(8)(195)(203)
Net realized (gains) reclassified into earnings (1)
(1)1 0 (110)89 (21)(149)98 (51)
Net change(252)200 (52)(123)37 (86)(157)(97)(254)
Total other comprehensive income (loss)$6,483 $(1,506)$4,977 $7,438 $(1,860)$5,578 $(5,106)$1,190 $(3,916)
(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.
                  
Changes in OCI Components Before- and After-tax              
        
 Before-tax 
Tax
effect
 
After-
tax
 Before-tax Tax effect 
After-
tax
 Before-tax Tax effect 
After-
tax
(Dollars in millions)2017 2016 2015
Debt securities:                 
Net increase in fair value$202
 $26
 $228
 $(1,645) $622
 $(1,023) $(1,564) $595
 $(969)
Reclassifications into earnings:                 
Gains on sales of debt securities(255) 97
 (158) (490) 186
 (304) (1,138) 432
 (706)
Other income41
 (20) 21
 19
 (7) 12
 81
 (31) 50
Net realized gains reclassified into earnings(214) 77
 (137) (471) 179
 (292) (1,057) 401
 (656)
Net change(12) 103
 91
 (2,116) 801
 (1,315) (2,621) 996
 (1,625)
Available-for-sale marketable equity securities:                 
Net increase (decrease) in fair value38
 (12) 26
 (49) 19
 (30) 72
 (27) 45
Net realized gains reclassified into earnings (2)
(90) 34
 (56) 
 
 
 
 
 
Net change(52) 22
 (30) (49) 19
 (30) 72
 (27) 45
Debit valuation adjustments:                 
Net increase (decrease) in fair value(490) 171
 (319) (271) 104
 (167) 436
 (166) 270
Net realized losses reclassified into earnings (2)
42
 (16) 26
 17
 (6) 11
 556
 (211) 345
Net change(448) 155
 (293) (254) 98
 (156) 992
 (377) 615
Derivatives:                 
Net increase (decrease) in fair value(50) 1
 (49) (299) 113
 (186) 55
 (22) 33
Reclassifications into earnings:                 
Net interest income327
 (122) 205
 553
 (205) 348
 974
 (367) 607
Personnel(148) 56
 (92) 32
 (12) 20
 (91) 35
 (56)
Net realized losses reclassified into earnings179
 (66) 113
 585
 (217) 368
 883
 (332) 551
Net change129
 (65) 64
 286
 (104) 182
 938
 (354) 584
Employee benefit plans:                 
Net increase (decrease) in fair value223
 (55) 168
 (921) 329
 (592) 408
 (121) 287
Reclassifications into earnings:                 
Prior service cost4
 (1) 3
 5
 (2) 3
 5
 (2) 3
Net actuarial losses175
 (60) 115
 92
 (34) 58
 164
 (60) 104
Net realized losses reclassified into earnings (3)
179
 (61) 118
 97
 (36) 61
 169
 (62) 107
Settlements, curtailments and other3
 (1) 2
 15
 (8) 7
 1
 (1) 
Net change405
 (117) 288
 (809) 285
 (524) 578
 (184) 394
Foreign currency:                 
Net increase (decrease) in fair value(439) 430
 (9) 514
 (601) (87) 600
 (723) (123)
Net realized gains reclassified into earnings (1,2)
(606) 701
 95
 
 
 
 (38) 38
 
Net change(1,045) 1,131
 86
 514
 (601) (87) 562
 (685) (123)
Total other comprehensive income (loss)$(1,023) $1,229
 $206
 $(2,428) $498
 $(1,930) $521
 $(631) $(110)
(1)
During 2017, foreign currency included a pre-tax gain on derivatives and related income tax expense associated with the Corporation’s net investment in its non-U.S. consumer credit card business, which was sold in 2017. The derivative gain was partially offset by a loss on the related foreign currency translation adjustment.
(2)
Reclassifications of pre-tax AFS marketable equity securities, DVA and foreign currency are recorded in other income in the Consolidated Statement of Income.
(3)
Reclassifications of pre-tax employee benefit plan costs are recorded in personnel expense in the Consolidated Statement of Income.
n/a = not applicable


Bank of America 2017160


NOTE 15 Earnings Per Common Share
The calculation of EPS and diluted EPS for 2017, 20162020, 2019 and 20152018 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)202020192018
Earnings per common share 
Net income$17,894 $27,430 $28,147 
Preferred stock dividends(1,421)(1,432)(1,451)
Net income applicable to common shareholders$16,473 $25,998 $26,696 
Average common shares issued and outstanding8,753.2 9,390.5 10,096.5 
Earnings per common share$1.88 $2.77 $2.64 
Diluted earnings per common share  
Net income applicable to common shareholders$16,473 $25,998 $26,696 
Average common shares issued and outstanding8,753.2 9,390.5 10,096.5 
Dilutive potential common shares (1)
43.7 52.4 140.4 
Total diluted average common shares issued and outstanding8,796.9 9,442.9 10,236.9 
Diluted earnings per common share$1.87 $2.75 $2.61 
(1)Includes incremental dilutive shares from RSUs, restricted stock and warrants.
      
(Dollars in millions, except per share information; shares in thousands)2017 2016 2015
Earnings per common share   
  
Net income$18,232
 $17,822
 $15,910
Preferred stock dividends(1,614) (1,682) (1,483)
Net income applicable to common shareholders$16,618
 $16,140
 $14,427
Average common shares issued and outstanding10,195,646
 10,284,147
 10,462,282
Earnings per common share$1.63
 $1.57
 $1.38
      
Diluted earnings per common share 
  
  
Net income applicable to common shareholders$16,618
 $16,140
 $14,427
Add preferred stock dividends due to assumed conversions (1)
186
 300
 300
Net income allocated to common shareholders$16,804
 $16,440
 $14,727
Average common shares issued and outstanding10,195,646
 10,284,147
 10,462,282
Dilutive potential common shares (2)
582,782
 762,659
 773,948
Total diluted average common shares issued and outstanding10,778,428
 11,046,806
 11,236,230
Diluted earnings per common share$1.56
 $1.49
 $1.31
(1)145 Bank of America
Represents the Series T dividends under the “if-converted” method prior to conversion.
(2)


Includes incremental dilutive shares from RSUs, restricted stock and warrants.
In connection with an investment in the Corporation’s Series T preferred stock in 2011, the Series T holders also received warrants to purchase 700 million shares of the Corporation’s common stock at an exercise price of $7.142857 per share. On August 24, 2017, the Series T holders exercised the warrantsFor 2020, 2019 and acquired the 700 million shares of the Corporation’s common stock using the Series T preferred stock as consideration for the exercise price, which increased common shares outstanding, but had no effect on diluted earnings per share as this conversion had been included in the Corporation’s diluted earnings per share calculation under the applicable accounting guidance. The use of the Series T preferred stock as consideration represents a non-cash financing activity and, accordingly, is not reflected in the Consolidated Statement of Cash Flows. For 2016 and 2015, the 700 million average dilutive potential common shares were included in the diluted share count under the “if-converted” method.
For 2017, 2016 and 2015,2018, 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 2017, 2016 and 2015,2018, average options to purchase 21 million, 45 million and 66 million shares of common stock, respectively, were outstanding but not included in the computation of EPS because the result would have been antidilutive under the treasury stock method. For 2017, 2016 and 2015, average warrants to purchase 122 million4000000 shares of common stock were outstanding but not included in the computation of EPS because the result would have been antidilutive under the treasury stock method. For 2017,2019 and 2018, average warrants to purchase 1433000000 and 136 million shares of common stock, respectively, were included in the diluted EPS calculation under the treasury stock method compared to 150 million sharesmethod. Substantially all of common stock in both 2016 and 2015.
these warrants were exercised on or before their expiration date of January 16, 2019.
NOTE 16 Regulatory Requirements andRestrictions
The Federal Reserve, Office of the Comptroller of the Currency (OCC) and FDIC (collectively, U.S. banking regulators) jointly establish regulatory capital adequacy guidelinesrules, 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.
Basel 3 updated the composition of capital and established a Common equity tier 1 capital ratio. Common equity tier 1 capital primarily includes common stock, retained earnings and accumulated OCI. Basel 3 revised minimum capital ratios and buffer requirements, added a supplementary leverage ratio, and addressed the adequately capitalized minimum requirements under the Prompt Corrective Action (PCA) framework. Finally, Basel 3 established two methods of calculating risk-weighted assets, the Standardized approach and the Advanced approaches.
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, and was the Advanced approaches method at December 31, 2017 and 2016.framework.
The following table presents capital ratios and related information in accordance with Basel 3 Standardized and Advanced approaches – Transition as measured at December 31, 20172020 and 20162019 for the Corporation and BANA.

Regulatory Capital under Basel 3
Bank of America CorporationBank of America, N.A.
Standardized Approach (1, 2)
Advanced Approaches (1)
Regulatory Minimum (3)
Standardized Approach (1, 2)
Advanced Approaches (1)
Regulatory Minimum (4)
(Dollars in millions, except as noted)December 31, 2020
Risk-based capital metrics:  
Common equity tier 1 capital$176,660 $176,660 $164,593 $164,593 
Tier 1 capital200,096 200,096 164,593 164,593 
Total capital (5)
237,936 227,685 181,370 170,922 
Risk-weighted assets (in billions)1,480 1,371 1,221 1,014 
Common equity tier 1 capital ratio11.9 %12.9 %9.5 %13.5 %16.2 %7.0 %
Tier 1 capital ratio13.5 14.6 11.0 13.5 16.2 8.5 
Total capital ratio16.1 16.6 13.0 14.9 16.9 10.5 
Leverage-based metrics:
Adjusted quarterly average assets (in billions) (6)
$2,719 $2,719 $2,143 $2,143 
Tier 1 leverage ratio7.4 %7.4 %4.0 7.7 %7.7 %5.0 
Supplementary leverage exposure (in billions) (7)
$2,786 $2,525 
Supplementary leverage ratio7.2 %5.0 6.5 %6.0 
 December 31, 2019
Risk-based capital metrics:    
Common equity tier 1 capital$166,760 $166,760 $154,626 $154,626 
Tier 1 capital188,492 188,492 154,626 154,626 
Total capital (5)
221,230 213,098 166,567 158,665 
Risk-weighted assets (in billions)1,493 1,447 1,241 991 
Common equity tier 1 capital ratio11.2 %11.5 %9.5 %12.5 %15.6 %7.0 %
Tier 1 capital ratio12.6 13.0 11.0 12.5 15.6 8.5 
Total capital ratio14.8 14.7 13.0 13.4 16.0 10.5 
Leverage-based metrics:
Adjusted quarterly average assets (in billions) (6)
$2,374 $2,374 $1,780 $1,780 
Tier 1 leverage ratio7.9 %7.9 %4.0 8.7 %8.7 %5.0 
Supplementary leverage exposure (in billions)$2,946 $2,177 
Supplementary leverage ratio6.4 %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 0. 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.
161Bank of America 2017146




            
Regulatory Capital under Basel 3 – Transition (1)
        
  
 Bank of America Corporation Bank of America, N.A.

Standardized Approach Advanced Approaches 
Regulatory Minimum (2)
 Standardized Approach Advanced Approaches 
Regulatory Minimum (3)
(Dollars in millions, except as noted)December 31, 2017
Risk-based capital metrics: 
  
    
  
  
Common equity tier 1 capital$171,063
 $171,063
   $150,552
 $150,552
  
Tier 1 capital191,496
 191,496
   150,552
 150,552
  
Total capital (4)
227,427
 218,529
   163,243
 154,675
  
Risk-weighted assets (in billions) (5)
1,434
 1,449
   1,201
 1,007
  
Common equity tier 1 capital ratio11.9% 11.8% 7.25% 12.5% 14.9% 6.5%
Tier 1 capital ratio13.4
 13.2
 8.75
 12.5
 14.9
 8.0
Total capital ratio15.9
 15.1
 10.75
 13.6
 15.4
 10.0
            
Leverage-based metrics:           
Adjusted quarterly average assets (in billions) (6)
$2,224
 $2,224
   $1,672
 $1,672
  
Tier 1 leverage ratio8.6% 8.6% 4.0
 9.0% 9.0% 5.0
            
 December 31, 2016
Risk-based capital metrics: 
  
    
  
  
Common equity tier 1 capital$168,866
 $168,866
   $149,755
 $149,755
  
Tier 1 capital190,315
 190,315
   149,755
 149,755
  
Total capital (4)
228,187
 218,981
   163,471
 154,697
  
Risk-weighted assets (in billions)1,399
 1,530
   1,176
 1,045
  
Common equity tier 1 capital ratio12.1% 11.0% 5.875% 12.7% 14.3% 6.5%
Tier 1 capital ratio13.6
 12.4
 7.375
 12.7
 14.3
 8.0
Total capital ratio16.3
 14.3
 9.375
 13.9
 14.8
 10.0
            
Leverage-based metrics:           
Adjusted quarterly average assets (in billions) (6)
$2,131
 $2,131
   $1,611
 $1,611
  
Tier 1 leverage ratio8.9% 8.9% 4.0
 9.3% 9.3% 5.0
(1)
Under the applicable bank regulatory rules, the Corporation is not required to and, accordingly, will not restate previously-filed regulatory capital metrics and ratios in connection with the change in accounting method as described in Note 1 – Summary of Significant Accounting Principles . Therefore, the December 31, 2016 amounts in the table are as originally reported. The cumulative impact of the change in accounting method resulted in an insignificant pro forma change to the Corporation’s capital metrics and ratios.
(2)
The December 31, 2017 and 2016 amounts include a transition capital conservation buffer of 1.25 percent and 0.625 percent and a transition global systemically important bank surcharge of 1.5 percent and 0.75 percent. The countercyclical capital buffer for both periods is zero.
(3)
Percentage required to meet guidelines to be considered “well capitalized” under the PCA framework.
(4)
Total capital under the Advanced approaches differs from the Standardized approach due to differences in the amount permitted in Tier 2 capital related to the qualifying allowance for credit losses.
(5)
During the fourth quarter of 2017, the Corporation obtained approval from U.S. banking regulators to use its Internal Models Methodology to calculate counterparty credit risk-weighted assets for derivatives under the Advanced approaches.
(6)
Reflects adjusted average total assets for the three months ended December 31, 2017 and 2016.

The capital adequacy rules issued by the U.S. banking regulators require institutions to meet the established minimums outlined in the table above. Failure to meet the minimum requirements can lead to certain mandatory and discretionary actions by regulators that could have a material adverse impact on the Corporation’s financial position. At December 31, 20172020 and 2016,2019, the Corporation and its banking entity affiliates were “wellwell 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.
Other Regulatory Matters
The Federal Reserve requires the Corporation’s bank subsidiaries to maintain reserve requirements based on a percentage of certain deposit liabilities. The average daily reserve balance requirements, in excess of vault cash, maintained by the Corporation with the Federal Reserve Bank were $8.9 billion and $7.7$3.8 billion for 20172020, reflecting the Federal Reserve's reduction of the reserve requirement to zero in the first quarter due to COVID-19, and 2016.$14.6 billion for 2019. At December 31, 20172020 and 2016,2019, the Corporation had cash and cash equivalents in the amount of $4.1$4.9 billion and $4.8$6.3 billion, and securities with a fair value of $17.3$16.8 billion and $14.6$14.7 billion that were segregated in compliance with securities regulations. Cash held on deposit with the Federal Reserve Bank to meet reserve requirements and cash and cash equivalents segregated in compliance with securities regulations are components of restricted cash. For more information, see Note 10 – Federal Funds Sold or Purchased, Securities Financing Agreements, Short-term Borrowings and Restricted Cash. In addition, at December 31, 20172020 and 2016,2019, the Corporation had
cash deposited with clearing organizations of $11.9$10.9 billion and $10.2$7.6 billion primarily recorded in other assets on the Consolidated Balance Sheet.
Bank Subsidiary Distributions
The primary sources of funds for cash distributions by the Corporation to its shareholders are capital distributions received from its bank subsidiaries, BANA and Bank of America California, N.A. In 2017,2020, the Corporation received dividends of $22.2$10.3 billion from BANA and $275$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 2018,2021, BANA can declare and pay dividends of approximately $6.0$10.3 billion to the Corporation plus an additional amount equal to its retained net profits for 20182021 up to the date
of any such dividend declaration. Bank of America California, N.A. can pay dividends of $195$198 million in 20182021 plus an additional amount equal to its retained net profits for 20182021 up to the date of any such dividend declaration.


Bank of America 2017162


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 no0 contribution under this agreement in 20172020 or 2016.2019. 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. During 2017, the Corporation established and funded a Voluntary Employees’ Beneficiary Association trust in the amount of $300 million for the Postretirement Health and Life Plans.
The Pension and Postretirement Plans table summarizes the changes in the fair value of plan assets, changes in the projected benefit obligation (PBO), the funded status of both the accumulated benefit obligation (ABO) and the PBO, and the weighted-average assumptions used to determine benefit obligations for the pension plans and postretirement plans at December 31, 20172020 and 2016.2019. The estimate of the Corporation’s PBO associated with these plans considers various actuarial assumptions, including assumptions for mortality rates and discount rates. The discount rate assumptions are derived from a cash flow matching technique that utilizes rates that are based on Aa-rated corporate bonds with cash flows that match estimated benefit payments of each of the plans. The decreases in the weighted-average discount raterates in 20172020 and 20162019 resulted in increases to the PBO of approximately $1.1$1.9 billion and $1.3$2.2 billionatDecember 31, 20172020 and 2016.2019. Significant gains and losses related to changes in the PBO for 2020 and 2019 primarily resulted from changes in the discount rate.
        
Pension and Postretirement Plans (1)
       
        
 
Qualified
Pension Plan
 
Non-U.S.
Pension Plans
 
Nonqualified and Other
Pension Plans
 
Postretirement
Health and Life Plans
(Dollars in millions)2017 2016 2017 2016 2017 2016 2017 2016
Change in fair value of plan assets 
  
  
  
  
  
  
  
Fair value, January 1$18,239
 $17,962
 $2,789
 $2,738
 $2,744
 $2,805
 $
 $
Actual return on plan assets2,285
 1,075
 118
 541
 128
 74
 
 
Company contributions
 
 23
 48
 98
 104
 393
 104
Plan participant contributions
 
 1
 1
 
 
 125
 125
Settlements and curtailments
 
 (190) (20) 
 (6) 
 
Benefits paid(816) (798) (54) (118) (246) (233) (230) (242)
Federal subsidy on benefits paid n/a
  n/a
  n/a
  n/a
  n/a
 n/a
 12
 13
Foreign currency exchange rate changes n/a
  n/a
 256
 (401)  n/a
 n/a
  n/a
  n/a
Fair value, December 31$19,708
 $18,239
 $2,943
 $2,789
 $2,724
 $2,744
 $300
 $
Change in projected benefit obligation 
  
  
  
  
  
  
  
Projected benefit obligation, January 1$14,982
 $14,461
 $2,763
 $2,580
 $3,047
 $3,053
 $1,125
 $1,152
Service cost
 
 24
 25
 1
 
 6
 7
Interest cost606
 634
 72
 86
 117
 127
 43
 47
Plan participant contributions
 
 1
 1
 
 
 125
 125
Plan amendments
 
 
 
 
 
 (19) 
Settlements and curtailments
 
 (200) (31) 
 (6) 
 
Actuarial loss (gain)934
 685
 (26) 535
 128
 106
 (7) 25
Benefits paid(816) (798) (54) (118) (246) (233) (230) (242)
Federal subsidy on benefits paid n/a
 n/a
  n/a
  n/a
  n/a
  n/a
 12
 13
Foreign currency exchange rate changes n/a
 n/a
 234
 (315)  n/a
  n/a
 1
 (2)
Projected benefit obligation, December 31$15,706
 $14,982
 $2,814
 $2,763
 $3,047
 $3,047
 $1,056
 $1,125
Amounts recognized on Consolidated Balance Sheet               
Other assets$4,002
 $3,257
 $610
 $475
 $730
 $760
 $
 $
Accrued expenses and other liabilities
 
 (481) (449) (1,053) (1,063) (756) (1,125)
Net amount recognized, December 31$4,002
 $3,257
 $129
 $26
 $(323) $(303) $(756) $(1,125)
Funded status, December 31 
  
  
  
  
  
  
  
Accumulated benefit obligation$15,706
 $14,982
 $2,731
 $2,645
 $3,046
 $3,046
 n/a
 n/a
Overfunded (unfunded) status of ABO4,002
 3,257
 212
 144
 (322) (302) n/a
 n/a
Provision for future salaries
 
 83
 118
 1
 1
 n/a
 n/a
Projected benefit obligation15,706
 14,982
 2,814
 2,763
 3,047
 3,047
 $1,056
 $1,125
Weighted-average assumptions, December 31 
  
  
  
  
  
  
  
Discount rate3.68% 4.16% 2.39% 2.56% 3.58% 4.01% 3.58% 3.99%
Rate of compensation increase n/a
 n/a
 4.31
 4.51
 4.00
 4.00
 n/a
 n/a
(1)
The measurement date for the Qualified Pension Plan, Non-U.S. Pension Plans, Nonqualified and Other Pension Plans, and Postretirement Health and Life Plans was December 31 of each year reported.
n/a = not applicable

163147Bank of America 2017



Pension and Postretirement Plans (1)
Qualified
Pension Plan
Non-U.S.
Pension Plans
Nonqualified and Other
Pension Plans
Postretirement
Health and Life Plans
(Dollars in millions)20202019202020192020201920202019
Fair value, January 1$20,275 $18,178 $2,696 $2,461 $2,666 $2,584 $199 $252 
Actual return on plan assets2,468 3,187 379 273 285 228 1 
Company contributions0 23 20 86 91 6 24 
Plan participant contributions0 1 0 110 103 
Settlements and curtailments0 (61)(42)0 0 
Benefits paid(967)(1,090)(57)(108)(248)(237)(174)(185)
Federal subsidy on benefits paid n/an/a n/an/a n/an/a1 
Foreign currency exchange rate changes n/an/a97 91  n/an/a n/an/a
Fair value, December 31$21,776 $20,275 $3,078 $2,696 $2,789 $2,666 $143 $199 
Change in projected benefit obligation        
Projected benefit obligation, January 1$15,361 $14,144 $2,887 $2,589 $2,919 $2,779 $989 $928 
Service cost0 20 17 1 5 
Interest cost500 593 49 65 90 113 32 38 
Plan participant contributions0 1 0 110 103 
Plan amendments0 3 0 0 
Settlements and curtailments0 (61)(42)0 0 
Actuarial loss1,533 1,714 396 288 243 263 43 99 
Benefits paid(967)(1,090)(57)(108)(248)(237)(173)(185)
Federal subsidy on benefits paid n/an/a n/an/a n/an/a1 
Foreign currency exchange rate changes n/an/a102 75  n/an/a0 
Projected benefit obligation, December 31$16,427 $15,361 $3,340 $2,887 $3,005 $2,919 $1,007 $989 
Amounts recognized on Consolidated Balance Sheet
Other assets$5,349 $4,914 $428 $364 $812 $733 $0 $
Accrued expenses and other liabilities0 (690)(555)(1,028)(986)(864)(790)
Net amount recognized, December 31$5,349 $4,914 $(262)$(191)$(216)$(253)$(864)$(790)
Funded status, December 31        
Accumulated benefit obligation$16,427 $15,361 $3,253 $2,841 $3,005 $2,919  n/an/a
Overfunded (unfunded) status of ABO5,349 4,914 (175)(145)(216)(253) n/an/a
Provision for future salaries0 87 46 0  n/an/a
Projected benefit obligation16,427 15,361 3,340 2,887 3,005 2,919 $1,007 $989 
Weighted-average assumptions, December 31        
Discount rate2.57 %3.32 %1.37 %1.81 %2.33 %3.20 %2.48 %3.27 %
Rate of compensation increasen/an/a4.11 4.10 4.00 4.00  n/an/a
Interest-crediting rate5.02 %5.06 %1.58 1.53 4.49 4.52  n/an/a
(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 20182021 is $17$29 million, $92$93 million and $19$14 million, respectively. The Corporation does not expect to make a contribution to the Qualified Pension Plan in 2018.2021. It is the policy of the Corporation to fund no less than the
minimum funding amount
required by the Employee Retirement Income Security Act of 1974 (ERISA).
Pension Plans with ABO and PBO in excess of plan assets as of December 31, 20172020 and 20162019 are presented in the table below. For these plans, funding strategies vary due to legal requirements and local practices.
Plans with ABO and PBO in Excess of Plan Assets
Non-U.S.
Pension Plans
Nonqualified
and Other
Pension Plans
(Dollars in millions)2020201920202019
PBO$900 $744 $1,028 $988 
ABO841 720 1,028 988 
Fair value of plan assets211 191 1 
        
Plans with PBO and ABO in Excess of Plan Assets       
        
 
Non-U.S.
Pension Plans
 
Nonqualified
and Other
Pension Plans
(Dollars in millions)2017 2016 2017 2016
PBO$671
 $626
 $1,054
 $1,065
ABO644
 594
 1,053
 1,064
Fair value of plan assets191
 179
 1
 1
            
Components of Net Periodic Benefit Cost           
            
 Qualified Pension Plan Non-U.S. Pension Plans
(Dollars in millions)2017 2016 2015 2017 2016 2015
Components of net periodic benefit cost (income)           
Service cost$
 $
 $
 $24
 $25
 $27
Interest cost606
 634
 621
 72
 86
 93
Expected return on plan assets(1,068) (1,038) (1,045) (136) (123) (133)
Amortization of net actuarial loss154
 139
 170
 8
 6
 6
Other
 
 
 (7) 2
 1
Net periodic benefit cost (income)$(308) $(265) $(254) $(39) $(4) $(6)
Weighted-average assumptions used to determine net cost for years ended December 31 
  
  
  
  
  
Discount rate4.16% 4.51% 4.12% 2.56% 3.59% 3.56%
Expected return on plan assets6.00
 6.00
 6.00
 4.73
 4.84
 5.27
Rate of compensation increasen/a
 n/a
 n/a
 4.51
 4.67
 4.70
            
 Nonqualified and
Other Pension Plans
 Postretirement Health
and Life Plans
(Dollars in millions)2017 2016 2015 2017 2016 2015
Components of net periodic benefit cost (income)           
Service cost$1
 $
 $
 $6
 $7
 $8
Interest cost117
 127
 122
 43
 47
 48
Expected return on plan assets(95) (101) (92) 
 
 (1)
Amortization of net actuarial loss (gain)34
 25
 34
 (21) (81) (46)
Other
 3
 
 4
 4
 4
Net periodic benefit cost (income)$57
 $54
 $64
 $32
 $(23) $13
Weighted-average assumptions used to determine net cost for years ended December 31 
  
  
  
  
  
Discount rate4.01% 4.34% 3.80% 3.99% 4.32% 3.75%
Expected return on plan assets3.50
 3.66
 3.26
  n/a
  n/a
 6.00
Rate of compensation increase4.00
 4.00
 4.00
  n/a
  n/a
 n/a
Bank of America 148


Components of Net Periodic Benefit Cost
 Qualified Pension PlanNon-U.S. Pension Plans
(Dollars in millions)202020192018202020192018
Components of net periodic benefit cost (income)
Service cost$0 $$$20 $17 $19 
Interest cost500 593 563 49 65 65 
Expected return on plan assets(1,154)(1,088)(1,136)(66)(99)(126)
Amortization of net actuarial loss173 135 147 9 10 
Other0 8 12 
Net periodic benefit cost (income)$(481)$(360)$(426)$20 $(7)$(20)
Weighted-average assumptions used to determine net cost for years ended December 31      
Discount rate3.32 %4.32 %3.68 %1.81 %2.60 %2.39 %
Expected return on plan assets6.00 6.00 6.00 2.57 4.13 4.37 
Rate of compensation increase n/an/an/a4.10 4.49 4.31 
Nonqualified and
Other Pension Plans
Postretirement Health
and Life Plans
(Dollars in millions)202020192018202020192018
Components of net periodic benefit cost (income)
Service cost$1 $$$5 $$
Interest cost90 113 105 32 38 36 
Expected return on plan assets(71)(95)(84)(4)(5)(6)
Amortization of net actuarial loss (gain)50 34 43 29 (24)(27)
Other0 (2)(2)(3)
Net periodic benefit cost (income)$70 $53 $65 $60 $12 $
Weighted-average assumptions used to determine net cost for years ended December 31      
Discount rate3.20 %4.26 %3.58 %3.27 %4.25 %3.58 %
Expected return on plan assets2.77 3.73 3.19 2.00 2.00 2.00 
Rate of compensation increase4.00 4.00 4.00   n/an/an/a
n/a = not applicable
The asset valuation method used to calculate the expected return on plan assets component of net periodic benefit cost for the Qualified Pension Plan recognizes 60 percent of the prior year’s market gains or losses at the next measurement date with the remaining 40 percent spread equally over the subsequent four years.
Gains and losses for all benefit plans except postretirement health care are recognized in accordance with the standard amortization provisions of the applicable accounting guidance. Net periodic postretirement health and life expense was determined using the “projected unit credit” actuarial method. For the Postretirement Health and Life Plans, 50 percent of the unrecognized gain or loss at the beginning of the fiscal year (or at
subsequent remeasurement) is recognized on a level basis during the year.
Assumed health care cost trend rates affect the postretirement benefit obligation and benefit cost reported for the Postretirement Health and Life Plans. The assumed health care cost trend rate used to measure the expected cost of benefits covered by the Postretirement Health and Life Plans is 7.006.25 percent for 2018,2021, reducing in steps to 5.00 percent in 20232026 and later years. A one-percentage-point increase in assumed health care cost trend rates would have increased the service and interest costs, and the benefit obligation by $1 million and $26 million in 2017. A one-percentage-point decrease in assumed health care cost trend rates would have lowered the service and interest costs, and the benefit obligation by $1 million and $23 million in 2017.

Bank of America 2017164


The Corporation’s net periodic benefit cost (income) recognized for the plans is sensitive to the discount rate and expected return on plan assets. With all other assumptions held constant, a 25 bp decline in the discount rate and expected return on plan assets assumptions would have resulted in an increase in the net periodic benefit cost forFor the Qualified Pension Plan, of approximately $6
million and $45 million in 2017, and approximately $6 million and $47 million to be recognized in 2018. For the 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 2017 and 2018.2020.
Pretax Amounts included in Accumulated OCI and OCI
 Qualified
Pension Plan
Non-U.S.
Pension Plans
Nonqualified
and Other
Pension Plans
Postretirement
Health and
Life Plans
Total
(Dollars in millions)2020201920202019202020192020201920202019
Net actuarial loss (gain)$3,912 $3,865 $628 $559 $987 $1,008 $66 $48 $5,593 $5,480 
Prior service cost (credits)0 18 18 0 (4)(6)14 12 
Amounts recognized in accumulated OCI$3,912 $3,865 $646 $577 $987 $1,008 $62 $42 $5,607 $5,492 
Current year actuarial loss (gain)$219 $(385)$79 $110 $29 $130 $47 $99 $374 $(46)
Amortization of actuarial gain (loss) and
prior service cost
(173)(135)(12)(7)(50)(34)(27)26 (262)(150)
Current year prior service cost (credit)0 3 0 0 3 
Amounts recognized in OCI$46 $(520)$70 $105 $(21)$96 $20 $125 $115 $(194)
                    
Pretax Amounts Included in Accumulated OCI                
                    
 
Qualified
Pension Plan
 
Non-U.S.
Pension Plans
 
Nonqualified
and Other
Pension Plans
 
Postretirement
Health and
Life Plans
 Total
(Dollars in millions)2017 2016 2017 2016 2017 2016 2017 2016 2017 2016
Net actuarial loss (gain)$3,992
 $4,429
 $196
 $216
 $1,014
 $953
 $(30) $(44) $5,172
 $5,554
Prior service cost (credits)
 
 4
 4
 
 
 (11) 12
 (7) 16
Amounts recognized in accumulated OCI$3,992
 $4,429
 $200
 $220
 $1,014
 $953
 $(41) $(32) $5,165
 $5,570
149 Bank of America

                    
Pretax Amounts Recognized in OCI              
                    
 
Qualified
Pension Plan
 
Non-U.S.
Pension Plans
 
Nonqualified
and Other
Pension Plans
 
Postretirement
Health and
Life Plans
 
Total (1)
(Dollars in millions)2017 2016 2017 2016 2017 2016 2017 2016 2017 2016
Current year actuarial loss (gain)$(283) $648
 $(12) $100
 $95
 $133
 $(7) $25
 $(207) $906
Amortization of actuarial gain (loss)(154) (139) (8) (6) (34) (28) 21
 81
 (175) (92)
Current year prior service cost (credit)
 
 
 
 
 
 (19) 
 (19) 
Amortization of prior service cost
 
 
 (1) 
 
 (4) (4) (4) (5)
Amounts recognized in OCI$(437) $509
 $(20) $93
 $61
 $105
 $(9) $102
 $(405) $809

(1) Pretax amounts to be amortized from accumulated OCI as period cost during 2018 are estimated to be $176 million.
Plan Assets
The Qualified Pension Plan has been established as a retirement vehicle for participants, and trusts have been established to secure benefits promised under the Qualified Pension Plan. The Corporation’s policy is to invest the trust assets in a prudent manner for the exclusive purpose of providing benefits to participants and defraying reasonable expenses of administration. The Corporation’s investment strategy is designed to provide a total return that, over the long term, increases the ratio of assets to liabilities. The strategy attempts to maximize the investment return on assets at a level of risk deemed appropriate by the Corporation while complying with ERISA and any applicable regulations and laws. The investment strategy utilizes asset allocation as a principal determinant for establishing the risk/return profile of the assets. Asset allocation ranges are established, periodically reviewed and adjusted as funding levels and liability characteristics change. Active and passive investment managers are employed to help enhance the risk/return profile of the assets. An additional aspect of the investment strategy used to minimize risk (part of the asset allocation plan) includes matching the exposure of participant-selected investment measures. No plan assets are expected to be returned to the Corporation during 2018.
The assets of the Non-U.S. Pension Plans are primarily attributable to a U.K. pension plan. This U.K. pension plan’s assets are invested prudently so that the benefits promised to members are provided with consideration given to the nature and the duration
of the plan’splans' liabilities. The selected asset
allocation strategy is designed to achieve a higher return than the lowest risk strategy.
The expected rate of return on plan assets assumption was developed through analysis of historical market returns, historical asset class volatility and correlations, current market conditions, anticipated future asset allocations, the funds’ past experience and expectations on potential future market returns. The expected return on plan assets assumption is determined using the calculated market-related value for the Qualified Pension Plan and the Other Pension Plan and the fair value for the Non-U.S. Pension Plans and Postretirement Health and Life Plans. The expected return on plan assets assumption represents a long-term average view of the performance of the assets in the Qualified Pension Plan, the Non-U.S. Pension Plans, the Other Pension Plan, and Postretirement Health and Life Plans, a return that may or may not be achieved during any one calendar year. The Other Pension Plan is invested solely in an annuity contract, which is primarily invested in fixed-income securities structured such that asset maturities match the duration of the plan’s obligations.
The target allocations for 20182021 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 $261$274 million (1.33(1.26 percent of total plan assets) and $203$315 million (1.11(1.55 percent of total plan assets) at December 31, 20172020 and 2016.2019.

165Bank of America 2017



2021 Target Allocation
2018 Target Allocation
Percentage
Asset CategoryPercentageQualified
Pension Plan
Non-U.S.
Pension Plans
Nonqualified
and Other
Pension Plans
Asset CategoryEquity securities
Qualified
Pension Plan
15 - 50%
Non-U.S.
Pension Plans
0 - 25%
Nonqualified
and Other
Pension Plans
0 - 5%
EquityDebt securities30-6045 - 80%5-3540 - 70%0-595 - 100%
Debt securitiesReal estate40-700 - 10%40-800 - 15%95-1000 - 5%
Real estateOther0-100 - 5%0-1510 - 40%0-5
Other0-50-250-50 - 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, 20172020 and 20162019 are summarized in the Fair Value Measurements table.
        
Fair Value Measurements       
        
 Level 1 Level 2 Level 3 Total
(Dollars in millions)December 31, 2017
Cash and short-term investments 
  
  
  
Money market and interest-bearing cash$2,190
 $
 $
 $2,190
Cash and cash equivalent commingled/mutual funds
 1,004
 
 1,004
Fixed income 
  
  
  
U.S. government and agency securities3,331
 854
 9
 4,194
Corporate debt securities
 2,417
 
 2,417
Asset-backed securities
 1,832
 
 1,832
Non-U.S. debt securities693
 898
 
 1,591
Fixed income commingled/mutual funds775
 1,676
 
 2,451
Equity 
  
  
  
Common and preferred equity securities5,833
 
 
 5,833
Equity commingled/mutual funds271
 1,753
 
 2,024
Public real estate investment trusts138
 
 
 138
Real estate 
  
  
  
Private real estate
 
 93
 93
Real estate commingled/mutual funds
 13
 831
 844
Limited partnerships
 155
 85
 240
Other investments (1)
101
 649
 74
 824
Total plan investment assets, at fair value$13,332
 $11,251
 $1,092
 $25,675
        
 December 31, 2016
Cash and short-term investments 
  
  
  
Money market and interest-bearing cash$776
 $
 $
 $776
Cash and cash equivalent commingled/mutual funds
 997
 
 997
Fixed income 
  
  
  
U.S. government and agency securities3,125
 816
 10
 3,951
Corporate debt securities
 1,892
 
 1,892
Asset-backed securities
 2,246
 
 2,246
Non-U.S. debt securities789
 705
 
 1,494
Fixed income commingled/mutual funds778
 1,503
 
 2,281
Equity 
  
  
  
Common and preferred equity securities6,120
 
 
 6,120
Equity commingled/mutual funds735
 1,225
 
 1,960
Public real estate investment trusts145
 
 
 145
Real estate 
  
  
  
Private real estate
 
 150
 150
Real estate commingled/mutual funds
 12
 748
 760
Limited partnerships
 132
 38
 170
Other investments (1)
15
 732
 83
 830
Total plan investment assets, at fair value$12,483
 $10,260
 $1,029
 $23,772
(1)
Other investments include interest rate swaps of $156 million and $257 million, participant loans of $20 million and $36 million, commodity and balanced funds of $451 million and $369 million and other various investments of $197 million and $168 million at December 31, 2017 and 2016.

Bank of America 2017166150



Fair Value Measurements
 Level 1Level 2Level 3TotalLevel 1Level 2Level 3Total
(Dollars in millions)December 31, 2020December 31, 2019
Cash and short-term investments    
Money market and interest-bearing cash$1,380 $0 $0 $1,380 $1,426 $$$1,426 
Cash and cash equivalent commingled/mutual funds0 383 0 383 250 250 
Fixed income       
U.S. government and agency securities4,590 1,238 7 5,835 4,403 890 5,301 
Corporate debt securities0 5,021 0 5,021 3,676 3,676 
Asset-backed securities0 1,967 0 1,967 2,684 2,684 
Non-U.S. debt securities1,021 1,122 0 2,143 748 1,015 1,763 
Fixed income commingled/mutual funds1,224 1,319 0 2,543 804 1,439 2,243 
Equity       
Common and preferred equity securities4,438 0 0 4,438 4,655 4,655 
Equity commingled/mutual funds134 1,542 0 1,676 147 1,355 1,502 
Public real estate investment trusts73 0 0 73 91 91 
Real estate       
Real estate commingled/mutual funds0 20 943 963 18 927 945 
Limited partnerships0 184 83 267 173 90 263 
Other investments (1)
5 401 691 1,097 11 390 636 1,037 
Total plan investment assets, at fair value$12,865 $13,197 $1,724 $27,786 $12,285 $11,890 $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 2017, 20162020, 2019 and 2015.2018.
       
Level 3 Fair Value MeasurementsLevel 3 Fair Value Measurements  Level 3 Fair Value Measurements
       
Balance
January 1
 
Actual Return on
Plan Assets Still
Held at the
Reporting Date
 Purchases, Sales and Settlements 
Balance
December 31
Balance
January 1
Actual Return on
Plan Assets Still
Held at the
Reporting Date
Purchases, Sales and SettlementsBalance
December 31
(Dollars in millions)2017(Dollars in millions)2020
Fixed income 
  
  
  
Fixed income    
U.S. government and agency securities$10
 $
 $(1) $9
U.S. government and agency securities$8 $0 $(1)$7 
Real estateReal estate 
Real estate commingled/mutual fundsReal estate commingled/mutual funds927 (4)20 943 
Limited partnershipsLimited partnerships90 2 (9)83 
Other investmentsOther investments636 6 49 691 
TotalTotal$1,661 $4 $59 $1,724 
2019
Fixed incomeFixed income    
U.S. government and agency securitiesU.S. government and agency securities$$$(1)$
Real estate   
   

Real estate 
Private real estate150
 8
 (65) 93
Private real estate(5)
Real estate commingled/mutual funds748
 63
 20
 831
Real estate commingled/mutual funds885 33 927 
Limited partnerships38
 14
 33
 85
Limited partnerships82 90 
Other investments83
 5
 (14) 74
Other investments588 42 636 
Total$1,029
 $90
 $(27) $1,092
Total$1,569 $39 $53 $1,661 
       
20162018
Fixed income 
  
  
  
Fixed income
U.S. government and agency securities$11
 $
 $(1) $10
U.S. government and agency securities$$$$
Real estate 
  
    Real estate  
Private real estate144
 1
 5
 150
Private real estate93 (7)(81)
Real estate commingled/mutual funds731
 21
 (4) 748
Real estate commingled/mutual funds831 52 885 
Limited partnerships49
 (2) (9) 38
Limited partnerships85 (12)82 
Other investments102
 4
 (23) 83
Other investments74 514 588 
Total$1,037
 $24
 $(32) $1,029
Total$1,092 $33 $444 $1,569 
       
2015
Fixed income       
U.S. government and agency securities$11
 $
 $
 $11
Real estate 
  
    
Private real estate127
 14
 3
 144
Real estate commingled/mutual funds632
 37
 62
 731
Limited partnerships65
 (1) (15) 49
Other investments127
 (5) (20) 102
Total$962
 $45
 $30
 $1,037
Projected Benefit Payments
Benefit payments projected to be made from the Qualified Pension Plan, Non-U.S. Pension Plans, Nonqualified and Other Pension Plans, and Postretirement Health and Life Plans are presented in the table below.
        
Projected Benefit Payments  
        
(Dollars in millions)
Qualified
Pension Plan (1)
 
Non-U.S.
Pension Plans (2)
 
Nonqualified
and Other
Pension Plans (2)
 
Postretirement Health and Life Plans (3)
2018$927
 $90
 $237
 $92
2019912
 98
 239
 87
2020924
 104
 242
 84
2021912
 112
 239
 81
2022919
 121
 232
 78
2023 - 20274,455
 695
 1,073
 343
(1)151 Bank of America
Benefit payments expected to be made from the plan’s assets.
(2)


Projected Benefit Payments
(Dollars in millions)
Qualified
Pension Plan (1)
Non-U.S.
Pension Plans (2)
Nonqualified
and Other
Pension Plans (2)
Postretirement Health and Life Plans (3)
2021$856 $127 $244 $79 
2022943 134 245 76 
2023939 143 229 74 
2024943 135 224 70 
2025934 140 221 67 
2026 - 20304,474 675 977 290 
(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.
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 each of 2017, 20162020, 2019 and 20152018 related to the qualified defined contribution plans. At both December 31, 20172020 and 2016, 218 million and 2242019, 189 million shares of the Corporation’s
common stock were held by these plans. Payments to the plans for dividends on common stock were $86$138 million, $60$133 million and $48$115 million in 2017, 20162020, 2019 and 2015,2018, respectively.
Certain non-U.S. employees are covered under defined contribution pension plans that are separately administered in accordance with local laws.


167Bank of America 2017



NOTE 18Stock-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, 450600 million shares of the Corporation’s common stock are authorized to be used for grants of awards.
During 20172020 and 2016,2019, the Corporation granted 8586 million and 16394 million RSU awards to certain employees under the KEEP. Generally, one-third of theKEEP. These RSUs vest on each of the first three anniversaries of the grant date provided that the employee remains continuously employed with the Corporation during that time. The RSUs arewere authorized to settle predominantly in shares of common stock of the Corporation, and are 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.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. AwardsOf the RSUs granted in 2020 and 2019, 61 million and 71 million will vest predominantly over three years prior to 2016 were predominantly cash settled.
Effective October 1, 2017,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 changed its accounting methodduring that time, and will be expensed ratably over the vesting period, net of estimated forfeitures, for determining when stock-based compensation awardsnon-retirement eligible employees based on the grant-date fair value of the shares. For RSUs granted to retirement-eligible employees who are retirement eligible, the awards are deemed authorized changing from the grant date toas of the beginning of the year preceding the grant date when the incentive award plans are generally approved. As a result, the estimated value of the awards is now expensed ratably over the year preceding the grant date. The compensation cost for all prior periods presented herein has been restated. For more information, see Note 1 – Summary Additionally, 25 million and 23 million of Significant Accounting Principles.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 $2.2$2.1 billion, $2.2$2.1 billion and $2.1$1.8 billion, in 2017, 2016 and 2015 and the related income tax benefit was $829$505 million, $835$511 million and $792$433 million for 2017, 2016
2020, 2019 and 2015,2018, respectively.
Restricted Stock/Units
The table below presents the status at December 31, 2017 of the share-settled restricted stock/units and changes during 2017.
    
Stock-settled Restricted Stock/Units
    
 Shares/Units 
Weighted-
average Grant Date Fair Value
Outstanding at January 1, 2017156,492,946
 $11.99
Granted81,555,447
 24.58
Vested(52,187,746) 12.01
Canceled(6,587,404) 16.93
Outstanding at December 31, 2017179,273,243
 17.53
The table below presents the status at December 31, 2017 of the cash-settled RSUs granted under the KEEP and changes during 2017.
Cash-settled Restricted Units
Units
Outstanding at January 1, 2017121,235,489
Granted3,105,988
Vested(79,525,864)
Canceled(2,605,987)
Outstanding at December 31, 201742,209,626
At December 31, 2017,2020, there was an estimated $1.1$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 1.72.2 years.
Restricted Stock and Restricted Stock Units
The total fair value of restricted stock and restricted stock units vested in 2017, 20162020, 2019 and 20152018 was $1.3$2.3 billion, $358$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
Shares/UnitsWeighted-
average Grant Date Fair Value
Outstanding at January 1, 2020157,909,315 $27.93 
Granted83,604,782 33.01 
Vested(68,578,284)27.38 
Canceled(4,982,584)30.88 
Outstanding at December 31, 2020167,953,229 30.60 
Cash-settled Restricted Units
At December 31, 2020, approximately 2 million cash-settled restricted units remain outstanding. In 2020, 2019 and $145 million, respectively. In 2017, 2016 and 2015,2018, the amount of cash paid to settle equity-based awards for all equity compensation plansthe RSUs that vested was $1.9 billion, $1.7 billion$81 million, $84 million and $3.0$1.3 billion, respectively.
Stock Options
The table below presents the status of all option plans at December 31, 2017 and changes during 2017.
    
Stock Options
    
 Options 
Weighted-
average
Exercise Price
Outstanding at January 1, 201742,357,282
 $50.57
Forfeited(25,769,108) 55.15
Outstanding at December 31, 201716,588,174
 43.44
All options outstanding as of December 31, 2017were vested and exercisable with a weighted-average remaining contractual term of less than one year and have no aggregate intrinsic value. No options have been granted since 2008.

Bank of America 2017168


NOTE 19 Income Taxes
On December 22, 2017, the President signed into law the Tax Act which made significant changes to federal income tax law including, among other things, reducing the statutory corporate income tax rate to 21 percent from 35 percent and changing the taxation of the Corporation’s non-U.S. business activities. The estimated impact on net income was $2.9 billion, driven by $2.3 billion in income tax expense, largely from a lower valuation of certain U.S. deferred tax assets and liabilities. The change in the
statutory tax rate also impacted the Corporation’s tax-advantaged energy investments, resulting in a downward valuation adjustment of $946 million recorded in other income and a related income tax benefit of $347 million, which when netted against the $2.3 billion, resulted in a net impact on income tax expense of $1.9 billion. For more information on the Tax Act, see Note 1 – Summary of Significant Accounting Principles.
The components of income tax expense for 2017, 20162020, 2019 and 20152018 are presented in the table below.
Income Tax Expense
(Dollars in millions)202020192018
Current income tax expense   
U.S. federal$1,092 $1,136 $816 
U.S. state and local1,076 901 1,377 
Non-U.S. 670 852 1,203 
Total current expense2,838 2,889 3,396 
Deferred income tax expense   
U.S. federal(799)2,001 2,579 
U.S. state and local(233)223 240 
Non-U.S. (705)211 222 
Total deferred expense(1,737)2,435 3,041 
Total income tax expense$1,101 $5,324 $6,437 
      
Income Tax Expense    
      
(Dollars in millions)2017 2016 2015
Current income tax expense 
  
  
U.S. federal$1,310
 $302
 $2,539
U.S. state and local557
 120
 210
Non-U.S. 939
 984
 561
Total current expense2,806
 1,406
 3,310
Deferred income tax expense 
  
  
U.S. federal7,238
 5,416
 1,855
U.S. state and local835
 (279) 515
Non-U.S. 102
 656
 597
Total deferred expense8,175
 5,793
 2,967
Total income tax expense$10,981
 $7,199
 $6,277
Total income tax expense does not reflect the tax effects of items that are included in OCI each period. For more
Bank of America 152


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 and $498 million in 2017 and 2016 and an expense of $631 million in 2015. In addition, prior to 2017, total income tax expense does not reflect tax effects associated with the Corporation’s employee stock plans which decreased common
stock and additional paid-in capital $41 million and $44 million in 2016 and 2015.2018.
Income tax expense for 2017, 20162020, 2019 and 20152018 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, of 35 percent, to the Corporation’s actual income tax expense, and the effective tax rates for 2017, 20162020, 2019 and 20152018 are presented in the table below.
Reconciliation of Income Tax Expense
 AmountPercentAmountPercentAmountPercent
(Dollars in millions)202020192018
Expected U.S. federal income tax expense$3,989 21.0 %$6,878 21.0 %$7,263 21.0 %
Increase (decrease) in taxes resulting from:
State tax expense, net of federal benefit728 3.8 1,283 3.9 1,367 4.0 
Affordable housing/energy/other credits(2,869)(15.1)(2,365)(7.2)(1,888)(5.5)
Tax law changes(699)(3.7)
Tax-exempt income, including dividends(346)(1.8)(433)(1.3)(413)(1.2)
Share-based compensation(129)(0.7)(225)(0.7)(257)(0.7)
Changes in prior-period UTBs, including interest(41)(0.2)(613)(1.9)144 0.4 
Nondeductible expenses324 1.7 290 0.9 302 0.9 
Rate differential on non-U.S. earnings218 1.1 504 1.5 98 0.3 
Other(74)(0.3)0.1 (179)(0.6)
Total income tax expense (benefit)$1,101 5.8 %$5,324 16.3 %$6,437 18.6 %
            
Reconciliation of Income Tax Expense          
            
 Amount Percent Amount Percent Amount Percent
(Dollars in millions)2017 2016 2015
Expected U.S. federal income tax expense$10,225
 35.0 % $8,757
 35.0 % $7,765
 35.0 %
Increase (decrease) in taxes resulting from:           
State tax expense, net of federal benefit881
 3.0
 420
 1.7
 438
 2.0
Tax law changes (1)
2,281
 7.8
 348
 1.4
 289
 1.3
Changes in prior-period UTBs, including interest133
 0.5
 (328) (1.3) (52) (0.2)
Nondeductible expenses97
 0.3
 180
 0.7
 40
 0.1
Affordable housing/energy/other credits(1,406) (4.8) (1,203) (4.8) (1,087) (4.9)
Tax-exempt income, including dividends(672) (2.3) (562) (2.2) (539) (2.4)
Non-U.S. tax rate differential(272) (0.9) (307) (1.2) (559) (2.5)
Share-based compensation(236) (0.8) 
 
 
 
Other(50) (0.2) (106) (0.5) (18) (0.1)
Total income tax expense$10,981
 37.6 % $7,199
 28.8 % $6,277
 28.3 %
(1)
Amounts for 2016 and 2015 are for Non-U.S. tax law changes.
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)202020192018
Balance, January 1$1,175 $2,197 $1,773 
Increases related to positions taken during the current year238 238 395 
Increases related to positions taken during prior years (1)
99 401 406 
Decreases related to positions taken during prior years (1)
(172)(1,102)(371)
Settlements0 (541)(6)
Expiration of statute of limitations0 (18)
Balance, December 31$1,340 $1,175 $2,197 
      
Reconciliation of the Change in Unrecognized Tax Benefits
      
(Dollars in millions)2017 2016 2015
Balance, January 1$875
 $1,095
 $1,068
Increases related to positions taken during the current year292
 104
 36
Increases related to positions taken during prior years 
750
 1,318
 187
Decreases related to positions taken during prior years(122) (1,091) (177)
Settlements(17) (503) (1)
Expiration of statute of limitations(5) (48) (18)
Balance, December 31$1,773
 $875
 $1,095
(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.

169Bank of America 2017



At December 31, 2017, 20162020, 2019 and 2015,2018, the balance of the Corporation’s UTBs which would, if recognized, affect the Corporation’s effective tax rate was $1.2 billion, $0.6 billion$976 million, $814 million and $0.7$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.

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, 2017.
2020.
Tax Examination Status
Years under
Examination (1)
Status at December 31 20172020
United States2012 – 20132017-2020IRS AppealsField Examination
United StatesCalifornia2014 – 20162012-2017Field examinationExamination
New York20152016-2018Field examination
United Kingdom2016To begin in 2018
Field Examination
(1)United Kingdom (2)
All tax years subsequent to the years shown remain subject to examination.2018Field Examination
It is reasonably possible that(1)    All tax years subsequent to the UTB balance may decrease by as much as $0.4 billion during the next 12 months, since resolved items will be removed from the balance whether their resolution resultsyears shown remain subject to examination.
(2) Field examination for tax year 2019 to begin in payment or recognition.
The Corporation recognized expense of $1 million and $56 million in 2017 and 2016 and a benefit of $82 million in 2015 for interest and penalties, net-of-tax, in income tax expense. At December 31, 2017 and 2016, the Corporation’s accrual for interest and penalties that related to income taxes, net of taxes and remittances, was $185 million and $167 million.2021.
Significant components of the Corporation’s net deferred tax assets and liabilities at December 31, 20172020 and 20162019 are presented in the following table. Amounts at December 31, 2017 reflect appropriate revaluations as a result of the Tax Act’s new 21 percent federal tax rate.
    
Deferred Tax Assets and Liabilities   
    
 December 31
(Dollars in millions)2017 2016
Deferred tax assets 
  
Net operating loss carryforwards$8,506
 $9,199
Security, loan and debt valuations2,939
 4,726
Allowance for credit losses2,598
 4,362
Accrued expenses2,021
 3,016
Tax credit carryforwards1,793
 3,125
Employee compensation and retirement benefits1,705
 3,042
Available-for-sale securities510
 784
Other1,034
 1,599
Gross deferred tax assets21,106
 29,853
Valuation allowance(1,644) (1,117)
Total deferred tax assets, net of valuation allowance19,462
 28,736
  
  
Deferred tax liabilities   
Equipment lease financing2,492
 3,489
Tax credit partnerships734
 539
Intangibles670
 1,171
Fee income601
 847
Mortgage servicing rights349
 829
Long-term borrowings227
 355
Other1,764
 1,915
Gross deferred tax liabilities6,837
 9,145
Net deferred tax assets, net of valuation allowance$12,625
 $19,591
153 Bank of America


Deferred Tax Assets and Liabilities
 December 31
(Dollars in millions)20202019
Deferred tax assets  
Net operating loss carryforwards$7,717 $7,417 
Allowance for credit losses4,701 2,354 
Security, loan and debt valuations2,571 1,860 
Lease liability2,400 2,321 
Employee compensation and retirement benefits1,582 1,622 
Accrued expenses1,481 1,719 
Credit carryforwards484 183 
Other1,412 1,203 
Gross deferred tax assets22,348 18,679 
Valuation allowance(2,346)(1,989)
Total deferred tax assets, net of valuation
allowance
20,002 16,690 
  
Deferred tax liabilities
Equipment lease financing3,101 2,933 
Right-to-use asset2,296 2,246 
Fixed assets1,957 1,505 
ESG-related tax credit investments1,930 1,577 
Available-for-sale securities
1,701 100 
Other1,570 1,885 
Gross deferred tax liabilities12,555 10,246 
Net deferred tax assets$7,447 $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, 2017.2020.
Net Operating Loss and Tax Credit Carryforward Deferred Tax Assets
(Dollars in millions)Deferred
Tax Asset
Valuation
Allowance
Net
Deferred
Tax Asset
First Year
Expiring
Net operating losses - U.S. $36 $$36 After 2028
Net operating losses - U.K. (1)
5,896 5,896 None
Net operating losses - other non-U.S. 506 (441)65 Various
Net operating losses - U.S. states (2)
1,279 (579)700 Various
Foreign tax credits484 (484)0 After 2028
        
Net Operating Loss and Tax Credit Carryforward Deferred Tax Assets
        
(Dollars in millions)
Deferred
Tax Asset
 
Valuation
Allowance
 
Net
Deferred
Tax Asset
 
First Year
Expiring
Net operating losses - U.S. $868
 $
 $868
 After 2027
Net operating losses - U.K. (1)
5,347
 
 5,347
 None
Net operating losses - other non-U.S. 657
 (578) 79
 Various
Net operating losses - U.S. states (2)
1,634
 (584) 1,050
 Various
General business credits1,721
 
 1,721
 After 2036
Foreign tax credits72
 (72) 
 n/a
(1)
Represents U.K. broker/dealer net operating losses which 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 $2.1 billion and $739 million.
n/a = not applicable
(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.
Bank of America 2017170


Management concluded that no0 valuation allowance was necessary to reduce the deferred tax assets related to the U.K. NOL carryforwards and U.S. NOLfederal and general business creditcertain 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 its U.K.such valuation allowance conclusions.
At December 31, 2017,2020, U.S. federal income taxes had not been provided on approximately $5$5.0 billion of temporary
differences associated with investments in non-U.S. subsidiaries that are essentially permanent in duration. If the Corporation were to record the associated deferred tax liability, the amount would be approximately $1$1.0 billion.
NOTE 20 Fair Value Measurements
Under applicable accounting standards, fair value is defined as the exchange price that would be received for an asset or paid to transfer a liability (an exit price) in the principal or most advantageous market for the asset or liability in an orderly transaction between market participants on the measurement date. The Corporation determines the fair values of its financial instruments under applicable accounting standards that require an entity to maximize the use of observable inputs and minimize the use of unobservable inputs. The Corporation categorizes its financial instruments into three levels based on the established fair value hierarchy. The Corporationhierarchy and conducts a review of its fair value hierarchy classifications on a quarterly basis. Transfers into or out of fair value hierarchy classifications are made if the significant inputs used in the financial models measuring the fair values of the assets and liabilities becamebecome unobservable or observable in the current marketplace. These transfers are considered to be effective as of the beginning of the quarter in which they occur. 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 Processes and Techniques
The Corporation has various processes and controls in place so that fair value is reasonably estimated. A model validation policy governs the use and control of valuation models used to estimate fair value. This policy requires review and approval of models by personnel who are independent of the front office and periodic reassessments of models so that they are continuing to perform as designed. In addition, detailed reviews of trading gains and
losses are conducted on a daily basis by personnel who are independent of the front office. A price verification group, which is also independent of the front office, utilizes available market information including executed trades, market prices and market-observable valuation model inputs so that fair values are reasonably estimated. The Corporation performs due diligence procedures over third-party pricing service providers in order to support their use infollowing sections outline the valuation process. Where market information is not available to support internal valuations, independent reviews ofmethodologies for the valuations are performedCorporation’s assets and any material exposures are escalated through a management review process.
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 2017,2020, 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
Bank of America 154


based on the vintages and ratings. Situations of illiquidity generally are triggered by the market’s perception of credit uncertainty regarding a single company or a specific market sector. In these instances, fair value is determined based on limited available market information and other factors, principally from reviewing the issuer’s financial statements and changes in credit ratings made by one or more rating agencies.


171Bank of America 2017



Derivative Assets and Liabilities
The fair values of derivative assets and liabilities traded in the OTC market are determined using quantitative models that utilize multiple market inputs including interest rates, prices and indices to generate continuous yield or pricing curves and volatility factors to value the position. The majority of market inputs are actively quoted and can be validated through external sources, including brokers, market transactions and third-party pricing services. When third-party pricing services are used, the methods and assumptions are reviewed by the Corporation. Estimation risk is greater for derivative asset and liability positions that are either option-based or have longer maturity dates where observable market inputs are less readily available, or are unobservable, in which case, quantitative-based extrapolations of rate, price or index scenarios are used in determining fair values. The fair values of derivative assets and liabilities include adjustments for market liquidity, counterparty credit quality and other instrument-specific factors, where appropriate. 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 (OAS) valuation approach, which factors in prepayment risk to determine the fair value of MSRs. This approach consists of projecting servicing cash flows under multiple interest rate scenarios and discounting these cash flows using risk-adjusted discount rates.

Loans Held-for-sale
The fair values of LHFS are based on quoted market prices, where available, or are determined by discounting estimated cash flows
using interest rates approximating the Corporation’s current origination rates for similar loans adjusted to reflect the inherent credit risk. The borrower-specific credit risk is embedded within the quoted market prices or is implied by considering loan performance when selecting comparables.
Short-term Borrowings and Long-term Debt
The Corporation issues structured liabilities that have coupons or repayment terms linked to the performance of debt or equity securities, interest rates, indices, currencies or commodities. The fair values of these structured liabilities are estimated using quantitative models for the combined derivative and debt portions of the notes. These models incorporate observable and, in some instances, unobservable inputs including security prices, interest rate yield curves, option volatility, currency, commodity or equity rates and correlations among these inputs. The Corporation also considers the impact of its own credit spread in determining the discount rate used to value these liabilities. The credit spread is determined by reference to observable spreads in the secondary bond market.
Securities Financing Agreements
The fair values of certain reverse repurchase agreements, repurchase agreements and securities borrowed transactions are determined using quantitative models, including discounted cash flow models that require the use of multiple market inputs including interest rates and spreads to generate continuous yield or pricing curves, and volatility factors. The majority of market inputs are actively quoted and can be validated through external sources, including brokers, market transactions and third-party pricing services.
Deposits
The fair values of deposits are determined using quantitative models, including discounted cash flow models that require the use of multiple market inputs including interest rates and spreads to generate continuous yield or pricing curves, and volatility factors. The majority of market inputs are actively quoted and can be validated through external sources, including brokers, market transactions and third-party pricing services. The Corporation considers the impact of its own credit spread in the valuation of these liabilities. The credit risk is determined by reference to observable credit spreads in the secondary cash market.
Asset-backed Secured Financings
The fair values of asset-backed secured financings are based on external broker bids, where available, or are determined by discounting estimated cash flows using interest rates approximating the Corporation’s current origination rates for similar loans adjusted to reflect the inherent credit risk.




155Bank of America 2017172



Recurring Fair Value
Assets and liabilities carried at fair value on a recurring basis at December 31, 20172020 and 2016,2019, including financial instruments whichthat the Corporation accounts for under the fair value option, are summarized in the following tables.
December 31, 2020
 Fair Value Measurements
(Dollars in millions)Level 1Level 2Level 3
Netting Adjustments (1)
Assets/Liabilities at Fair Value
Assets     
Time deposits placed and other short-term investments$1,649 $0 $0 $ $1,649 
Federal funds sold and securities borrowed or purchased under agreements to resell0 108,856 0  108,856 
Trading account assets:     
U.S. Treasury and agency securities45,219 3,051 0  48,270 
Corporate securities, trading loans and other0 22,817 1,359  24,176 
Equity securities36,372 31,372 227  67,971 
Non-U.S. sovereign debt5,753 20,884 354  26,991 
Mortgage trading loans, MBS and ABS:
U.S. government-sponsored agency guaranteed (2)
0 21,566 75  21,641 
Mortgage trading loans, ABS and other MBS0 8,440 1,365  9,805 
Total trading account assets (3)
87,344 108,130 3,380  198,854 
Derivative assets15,624 416,175 2,751 (387,371)47,179 
AFS debt securities:     
U.S. Treasury and agency securities115,266 1,114 0  116,380 
Mortgage-backed securities:     
Agency0 61,849 0  61,849 
Agency-collateralized mortgage obligations0 5,260 0  5,260 
Non-agency residential0 631 378  1,009 
Commercial0 16,491 0  16,491 
Non-U.S. securities0 13,999 18  14,017 
Other taxable securities0 2,640 71  2,711 
Tax-exempt securities0 16,598 176  16,774 
Total AFS debt securities115,266 118,582 643  234,491 
Other debt securities carried at fair value:
U.S. Treasury and agency securities93 0 0  93 
Non-agency residential MBS0 506 267  773 
Non-U.S. and other securities2,619 8,625 0  11,244 
Total other debt securities carried at fair value2,712 9,131 267  12,110 
Loans and leases0 5,964 717  6,681 
Loans held-for-sale0 1,349 236  1,585 
Other assets (4)
9,898 3,850 1,970  15,718 
Total assets (5)
$232,493 $772,037 $9,964 $(387,371)$627,123 
Liabilities     
Interest-bearing deposits in U.S. offices$0 $481 $0 $ $481 
Federal funds purchased and securities loaned or sold under agreements to repurchase0 135,391 0  135,391 
Trading account liabilities:    
U.S. Treasury and agency securities9,425 139 0  9,564 
Equity securities38,189 4,235 0  42,424 
Non-U.S. sovereign debt5,853 8,043 0  13,896 
Corporate securities and other0 5,420 16  5,436 
Total trading account liabilities53,467 17,837 16  71,320 
Derivative liabilities14,907 412,881 6,219 (388,481)45,526 
Short-term borrowings0 5,874 0  5,874 
Accrued expenses and other liabilities12,297 4,014 0  16,311 
Long-term debt0 31,036 1,164  32,200 
Total liabilities (5)
$80,671 $607,514 $7,399 $(388,481)$307,103 
          
 December 31, 2017
 Fair Value Measurements    
(Dollars in millions)Level 1 Level 2 Level 3 
Netting Adjustments (1)
 Assets/Liabilities at Fair Value
Assets 
  
  
  
  
Federal funds sold and securities borrowed or purchased under agreements to resell$
 $52,906
 $
 $
 $52,906
Trading account assets: 
  
  
  
  
U.S. Treasury and agency securities (2, 3)
38,720
 1,922
 
 
 40,642
Corporate securities, trading loans and other
 28,714
 1,864
 
 30,578
Equity securities (3)
60,747
 23,958
 235
 
 84,940
Non-U.S. sovereign debt (3)
6,545
 15,839
 556
 
 22,940
Mortgage trading loans, MBS and ABS:         
U.S. government-sponsored agency guaranteed (2)

 20,586
 
 
 20,586
Mortgage trading loans, ABS and other MBS
 8,174
 1,498
 
 9,672
Total trading account assets (4)
106,012
 99,193
 4,153
 
 209,358
Derivative assets (3, 5)
6,305
 341,178
 4,067
 (313,788) 37,762
AFS debt securities: 
  
  
  
  
U.S. Treasury and agency securities51,915
 1,608
 
 
 53,523
Mortgage-backed securities: 
  
  
  
  
Agency
 192,929
 
 
 192,929
Agency-collateralized mortgage obligations
 6,804
 
 
 6,804
Non-agency residential
 2,669
 
 
 2,669
Commercial
 13,684
 
 
 13,684
Non-U.S. securities772
 5,880
 25
 
 6,677
Other taxable securities
 5,261
 509
 
 5,770
Tax-exempt securities
 20,106
 469
 
 20,575
Total AFS debt securities52,687
 248,941
 1,003
 
 302,631
Other debt securities carried at fair value:         
Mortgage-backed securities:         
Agency-collateralized mortgage obligations
 5
 
 
 5
Non-agency residential
 2,764
 
 
 2,764
Non-U.S. securities8,191
 1,297
 
 
 9,488
Other taxable securities
 229
 
 
 229
Total other debt securities carried at fair value8,191
 4,295
 
 
 12,486
Loans and leases
 5,139
 571
 
 5,710
Mortgage servicing rights (6)

 
 2,302
 
 2,302
Loans held-for-sale
 1,466
 690
 
 2,156
Other assets19,367
 789
 123
 
 20,279
Total assets$192,562
 $753,907
 $12,909
 $(313,788) $645,590
Liabilities 
  
  
  
  
Interest-bearing deposits in U.S. offices$
 $449
 $
 $
 $449
Federal funds purchased and securities loaned or sold under agreements to repurchase
 36,182
 
 
 36,182
Trading account liabilities: 
  
  
  
  
U.S. Treasury and agency securities17,266
 734
 
 
 18,000
Equity securities (3)
33,019
 3,885
 
 
 36,904
Non-U.S. sovereign debt (3)
11,976
 7,382
 
 
 19,358
Corporate securities and other
 6,901
 24
 
 6,925
Total trading account liabilities62,261
 18,902
 24
 
 81,187
Derivative liabilities (3, 5)
6,029
 334,261
 5,781
 (311,771) 34,300
Short-term borrowings
 1,494
 
 
 1,494
Accrued expenses and other liabilities21,887
 945
 8
 
 22,840
Long-term debt
 29,923
 1,863
 
 31,786
Total liabilities$90,177
 $422,156
 $7,676
 $(311,771) $208,238
(1)
Amounts represent the impact of legally enforceable master netting agreements and also cash collateral held or placed with the same counterparties.
(2)
Includes $21.3 billion of GSE obligations.
(3)
During 2017, for trading account assets and liabilities, $1.1 billion of U.S. Treasury and agency securities assets, $5.3 billion of equity securities assets, $3.1 billion of equity securities liabilities, $3.3 billion of non-U.S. sovereign debt assets and $1.5 billion of non-U.S. sovereign debt liabilities were transferred from Level 1 to Level 2 based on the liquidity of the positions. In addition, $14.1 billion of equity securities assets and $4.3 billion of equity securities liabilities were transferred from Level 2 to Level 1. Also in 2017, $4.2 billion of derivative assets and $3.0 billion of derivative liabilities were transferred from Level 1 to Level 2 and $758 million of derivative assets and $608 million of derivative liabilities were transferred from Level 2 to Level 1 based on the observability of inputs used to measure fair value. For further disaggregation of derivative assets and liabilities, see Note 2 – Derivatives.
(4)
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.
(5)
Derivative assets and liabilities reflect the effects of contractual amendments by two central clearing counterparties to legally re-characterize daily cash variation margin from collateral, which secures an outstanding exposure, to settlement, which discharges an outstanding exposure. One of these central clearing counterparties amended its governing documents, which became effective in January 2017. In addition, the Corporation elected to transfer its existing positions to the settlement platform for the other central clearing counterparty in September 2017.
(6)
MSRs include the $1.7 billion core MSR portfolio held in Consumer Banking, the $135 million non-core MSR portfolio held in All Other and the $510 million non-U.S. MSR portfolio held in Global Markets.

(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.
173Bank of America 2017
(3)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.



(4)Includes MSRs of $1.0 billionwhich are classified as Level 3 assets.
          
 December 31, 2016
 Fair Value Measurements    
(Dollars in millions)Level 1 Level 2 Level 3 
Netting Adjustments (1)
 Assets/Liabilities at Fair Value
Assets 
  
  
  
  
Federal funds sold and securities borrowed or purchased under agreements to resell$
 $49,750
 $
 $
 $49,750
Trading account assets: 
  
  
  
  
U.S. Treasury and agency securities (2)
34,587
 1,927
 
 
 36,514
Corporate securities, trading loans and other171
 22,861
 2,777
 
 25,809
Equity securities50,169
 21,601
 281
 
 72,051
Non-U.S. sovereign debt9,578
 9,940
 510
 
 20,028
Mortgage trading loans, MBS and ABS:         
U.S. government-sponsored agency guaranteed (2)

 15,799
 
 
 15,799
Mortgage trading loans, ABS and other MBS
 8,797
 1,211
 
 10,008
Total trading account assets (3)
94,505
 80,925
 4,779
 
 180,209
Derivative assets (4)
7,337
 619,848
 3,931
 (588,604) 42,512
AFS debt securities: 
  
  
  
�� 
U.S. Treasury and agency securities46,787
 1,465
 
 
 48,252
Mortgage-backed securities: 
  
  
  
  
Agency
 189,486
 
 
 189,486
Agency-collateralized mortgage obligations
 8,330
 
 
 8,330
Non-agency residential
 2,013
 
 
 2,013
Commercial
 12,322
 
 
 12,322
Non-U.S. securities1,934
 3,600
 229
 
 5,763
Other taxable securities
 10,020
 594
 
 10,614
Tax-exempt securities
 16,618
 542
 
 17,160
Total AFS debt securities48,721
 243,854
 1,365
 
 293,940
Other debt securities carried at fair value:         
Mortgage-backed securities:         
Agency-collateralized mortgage obligations
 5
 
 
 5
Non-agency residential
 3,114
 25
 
 3,139
Non-U.S. securities15,109
 1,227
 
 
 16,336
Other taxable securities
 240
 
 
 240
Total other debt securities carried at fair value15,109
 4,586
 25
 
 19,720
Loans and leases
 6,365
 720
 
 7,085
Mortgage servicing rights (5)

 
 2,747
 
 2,747
Loans held-for-sale
 3,370
 656
 
 4,026
Debt securities in assets of business held for sale619
 
 
 
 619
Other assets11,824
 1,739
 239
 
 13,802
Total assets$178,115
 $1,010,437
 $14,462
 $(588,604) $614,410
Liabilities 
  
  
  
  
Interest-bearing deposits in U.S. offices$
 $731
 $
 $
 $731
Federal funds purchased and securities loaned or sold under agreements to repurchase
 35,407
 359
 
 35,766
Trading account liabilities: 
  
  
  
  
U.S. Treasury and agency securities15,854
 197
 
 
 16,051
Equity securities25,884
 3,014
 
 
 28,898
Non-U.S. sovereign debt9,409
 2,103
 
 
 11,512
Corporate securities and other163
 6,380
 27
 
 6,570
Total trading account liabilities51,310
 11,694
 27
 
 63,031
Derivative liabilities (4)
7,173
 615,896
 5,244
 (588,833) 39,480
Short-term borrowings
 2,024
 
 
 2,024
Accrued expenses and other liabilities12,978
 1,643
 9
 
 14,630
Long-term debt
 28,523
 1,514
 
 30,037
Total liabilities$71,461
 $695,918
 $7,153
 $(588,833) $185,699
(1)
Amounts represent the impact of legally enforceable master netting agreements and also cash collateral held or placed with the same counterparties.
(2)
Includes $17.5 billion of GSE obligations.
(3)
Includes securities with a fair value of $14.6 billion that were segregated in compliance with securities regulations or deposited with clearing organizations. This amount is included in the parenthetical disclosure on the Consolidated Balance Sheet.
(4)
During 2016, $2.3 billion of derivative assets and $2.4 billion of derivative liabilities were transferred from Level 1 to Level 2 and $2.0 billion of derivative assets and $1.8 billion of derivative liabilities were transferred from Level 2 to Level 1 based on the observability of inputs used to measure fair value. For further disaggregation of derivative assets and liabilities, see Note 2 – Derivatives.
(5)
MSRs include the $2.1 billion core MSR portfolio held in Consumer Banking, the $212 million non-core MSR portfolio held in All Other and the $469 million non-U.S. MSR portfolio held in Global Markets.


(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.
Bank of America 2017174156



December 31, 2019
Fair Value Measurements
(Dollars in millions)Level 1Level 2Level 3
Netting Adjustments (1)
Assets/Liabilities at Fair Value
Assets     
Time deposits placed and other short-term investments$1,000 $$$— $1,000 
Federal funds sold and securities borrowed or purchased under agreements to resell50,364 — 50,364 
Trading account assets:     
U.S. Treasury and agency securities49,517 4,157 — 53,674 
Corporate securities, trading loans and other25,226 1,507 — 26,733 
Equity securities53,597 32,619 239 — 86,455 
Non-U.S. sovereign debt3,965 23,854 482 — 28,301 
Mortgage trading loans, MBS and ABS:
U.S. government-sponsored agency guaranteed (2)
24,324 — 24,324 
Mortgage trading loans, ABS and other MBS8,786 1,553 — 10,339 
Total trading account assets (3)
107,079 118,966 3,781 — 229,826 
Derivative assets14,079 328,442 2,226 (304,262)40,485 
AFS debt securities:     
U.S. Treasury and agency securities67,332 1,196 — 68,528 
Mortgage-backed securities:     
Agency122,528 — 122,528 
Agency-collateralized mortgage obligations4,641 — 4,641 
Non-agency residential653 424 — 1,077 
Commercial15,021 — 15,021 
Non-U.S. securities11,989 — 11,991 
Other taxable securities3,876 65 — 3,941 
Tax-exempt securities17,804 108 — 17,912 
Total AFS debt securities67,332 177,708 599 — 245,639 
Other debt securities carried at fair value:
U.S. Treasury and agency securities— 
Agency MBS3,003 — 3,003 
Non-agency residential MBS1,035 299 — 1,334 
Non-U.S. and other securities400 6,088 — 6,488 
Total other debt securities carried at fair value403 10,126 299 — 10,828 
Loans and leases7,642 693 — 8,335 
Loans held-for-sale3,334 375 — 3,709 
Other assets (4)
11,782 1,376 2,360 — 15,518 
Total assets (5)
$201,675 $697,958 $10,333 $(304,262)$605,704 
Liabilities     
Interest-bearing deposits in U.S. offices$$508 $$— $508 
Federal funds purchased and securities loaned or sold under agreements to repurchase16,008 — 16,008 
Trading account liabilities:    
U.S. Treasury and agency securities13,140 282 — 13,422 
Equity securities38,148 4,144 — 42,294 
Non-U.S. sovereign debt10,751 11,310 — 22,061 
Corporate securities and other5,478 15 — 5,493 
Total trading account liabilities62,039 21,214 17 — 83,270 
Derivative liabilities11,904 320,479 4,764 (298,918)38,229 
Short-term borrowings3,941 — 3,941 
Accrued expenses and other liabilities13,927 1,507 — 15,434 
Long-term debt33,826 1,149 — 34,975 
Total liabilities (5)
$87,870 $397,483 $5,930 $(298,918)$192,365 
(1)Amounts represent the impact of legally enforceable master netting agreements and also cash collateral held or placed with the same counterparties.
(2)Includes $26.7 billion of GSE obligations.
(3)Includes securities with a fair value of $14.7 billion that were segregated in compliance with securities regulations or deposited with clearing organizations. This amount is included in the parenthetical disclosure on the Consolidated Balance Sheet.
(4)Includes MSRs of $1.5 billion which are classified as Level 3 assets.
(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.

157 Bank of America


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 2017, 20162020, 2019 and 2015,2018, including net realized and unrealized gains (losses) included in earnings and accumulated OCI.
            
Level 3 – Fair Value Measurements in 2017 (1)
        
   
(Dollars in millions)
Balance
January 1
2017
Total Realized/Unrealized Gains/(Losses) (2)
Gains/
(Losses)
in OCI
(3)
Gross
Gross
Transfers
into
Level 3 
Gross
Transfers
out of
Level 3 
Balance
December 31
2017
Change in Unrealized Gains/(Losses) Related to Financial Instruments Still Held (2)
PurchasesSalesIssuancesSettlements
Trading account assets: 
 
 
 
    
 
 
 
Corporate securities, trading loans and other$2,777
$229
$
$547
$(702)$5
$(666)$728
$(1,054)$1,864
$2
Equity securities281
18

55
(70)
(10)146
(185)235
(1)
Non-U.S. sovereign debt510
74
(8)53
(59)
(73)72
(13)556
70
Mortgage trading loans, ABS and other MBS1,211
165
(2)1,210
(990)
(233)218
(81)1,498
72
Total trading account assets4,779
486
(10)1,865
(1,821)5
(982)1,164
(1,333)4,153
143
Net derivative assets (4)
(1,313)(984)
664
(979)
949
48
(99)(1,714)(409)
AFS debt securities: 
 
 
 
 
 
 
 
 
 
 
Non-U.S. securities229
2
16
49


(271)

25

Other taxable securities594
4
8
5


(42)34
(94)509

Tax-exempt securities542
1
3
14
(70)
(11)35
(45)469

Total AFS debt securities1,365
7
27
68
(70)
(324)69
(139)1,003

Other debt securities carried at fair value – Non-agency residential MBS25
(1)

(21)
(3)



Loans and leases (5, 6)
720
15

3
(34)
(126)
(7)571
11
Mortgage servicing rights (6, 7)
2,747
70


(25)258
(748)

2,302
(248)
Loans held-for-sale (5)
656
100
(3)3
(189)
(346)501
(32)690
14
Other assets239
74
(57)2
(189)
(10)64

123
22
Federal funds purchased and securities loaned or sold under agreements to repurchase (5)
(359)(5)


(12)171
(58)263


Trading account liabilities – Corporate securities and other(27)14

8
(17)(2)


(24)2
Accrued expenses and other liabilities (5)
(9)




1


(8)
Long-term debt (5)
(1,514)(135)(31)84

(288)514
(711)218
(1,863)(196)
(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 - primarily trading account profits; Net derivative assets - primarily trading account profits and mortgage banking income; MSRs - primarily mortgage banking income; Long-term debt - primarily trading account profits. For MSRs, the amounts reflect the changes in modeled MSR fair value due to observed changes in interest rates, volatility, spreads and the shape of the forward swap curve, and periodic adjustments to the valuation model to reflect changes in the modeled relationships between inputs and projected cash flows, as well as changes in cash flow assumptions including cost to service.
(3)
Includes unrealized gains/losses in OCI on AFS securities, foreign currency translation adjustments and the impact of changes in the Corporation’s credit spreads on long-term debt accounted for under the fair value option. For more information, see Note 1 – Summary of Significant Accounting Principles.
(4)
Net derivatives include derivative assets of $4.1 billion and derivative liabilities of $5.8 billion.
(5)
Amounts represent instruments that are accounted for under the fair value option.
(6)
Issuances represent loan originations and MSRs recognized following securitizations or whole-loan sales.
(7)
Settlements represent the net change in fair value of the MSR asset due to the recognition of modeled cash flows and the passage of time.
Significant transfers Transfers into Level 3 occur primarily due to decreased price observability, during 2017 included $1.2 billionand
transfers out of trading account assets, $501 million of LHFS and $711 million of long-term debt.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)
Balance
January 1
Total Realized/Unrealized Gains (Losses) in Net
Income (2)
Gains
(Losses)
in OCI
(3)
GrossGross
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)
PurchasesSalesIssuancesSettlements
Year Ended December 31, 2020
Trading account assets:       
Corporate securities, trading loans and other$1,507 $(138)$(1)$430 $(242)$10 $(282)$639 $(564)$1,359 $(102)
Equity securities239 (43)0 78 (53)0 (3)58 (49)227 (31)
Non-U.S. sovereign debt482 45 (46)76 (61)0 (39)150 (253)354 47 
Mortgage trading loans, ABS and other MBS1,553 (120)(3)577 (746)11 (96)757 (493)1,440 (92)
Total trading account assets3,781 (256)(50)1,161 (1,102)21 (420)1,604 (1,359)3,380 (178)
Net derivative assets (liabilities) (4)
(2,538)(235)0 120 (646)0 (112)(235)178 (3,468)(953)
AFS debt securities:          
Non-agency residential MBS424 (2)3 23 (54)0 (44)158 (130)378 (2)
Non-U.S. securities2 1 0 0 (1)0 (1)17 0 18 1 
Other taxable securities65 0 0 9 (4)0 0 1 0 71 0 
Tax-exempt securities108 (21)3 0 0 0 (169)265 (10)176 (20)
Total AFS debt securities599 (22)6 32 (59)0 (214)441 (140)643 (21)
Other debt securities carried at fair value – Non-agency residential MBS299 26 0 0 (180)0 (24)190 (44)267 3 
Loans and leases (5,6)
693 (4)0 145 (76)22 (161)98 0 717 9 
Loans held-for-sale (5,6)
375 26 (28)0 (489)691 (119)93 (313)236 (5)
Other assets (6,7)
2,360 (288)3 178 (4)224 (506)5 (2)1,970 (374)
Trading account liabilities – Equity securities(2)1 0 0 0 0 0 0 1 0 0 
Trading account liabilities – Corporate securities
   and other
(15)8 0 (7)(3)0 1 0 0 (16)0 
Long-term debt (5)
(1,149)(46)2 (104)0 (47)218 (52)14 (1,164)(5)
Year Ended December 31, 2019
Trading account assets:     
Corporate securities, trading loans and other$1,558 $105 $$534 $(390)$18 $(578)$699 $(439)$1,507 $29 
Equity securities276 (12)38 (87)(9)79 (46)239 (18)
Non-U.S. sovereign debt465 46 (12)(51)39 (6)482 47 
Mortgage trading loans, ABS and other MBS1,635 99 (2)662 (899)(175)738 (505)1,553 26 
Total trading account assets3,934 238 (14)1,235 (1,376)18 (813)1,555 (996)3,781 84 
Net derivative assets (liabilities) (4,8)
(935)(37)298 (837)(97)147 (1,077)(2,538)228 
AFS debt securities:       
Non-agency residential MBS597 13 64 (73)(40)206 (343)424 
Non-U.S. securities
Other taxable securities(5)61 65 
Tax-exempt securities108 108 
Total AFS debt securities606 15 64 (73)(45)375 (343)599 
Other debt securities carried at fair value – Non-agency residential MBS172 36 (17)155 (47)299 38 
Loans and leases (5,6)
338 230 (35)217 (57)693 (1)
Loans held-for-sale (5,6)
542 48 (6)12 (71)36 (245)59 375 22 
Other assets (6,7)
2,932 (81)19 (10)179 (683)(1)2,360 (267)
Trading account liabilities – Equity securities(2)(2)(2)
Trading account liabilities – Corporate securities
   and other
(18)(1)(3)(1)(15)
Long-term debt (5,8)
(817)(59)(64)(40)180 (350)(1,149)(55)
Significant transfers out(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.
(3)Includes unrealized gains (losses) in OCI on AFS debt securities, foreign currency translation adjustments and the impact of changes in the Corporation’s credit spreads on long-term debt accounted for under the fair value option. Amounts include net unrealized gains (losses) of $(41) million and $3 million related to financial instruments still held at December 31, 2020 and 2019.
(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)Issuances represent loan originations and MSRs recognized following securitizations or whole-loan sales.
(7)Settlements primarily represent the net change in fair value of the MSR asset due to the recognition of modeled cash flows and the passage of time.
(8)Transfers into long-term debt include a $1.4 billion transfer in of Level 3 primarily due to increased price observability, during 2017 included $1.3 billion of trading account assets, $139 million of AFS debt securities, $263 million of federal funds purchased and securities loaned or sold under agreements to repurchase and $218 million of long-term debt.


175Bank of America 2017



            
Level 3 – Fair Value Measurements in 2016 (1)
        
   
 
Balance
January 1
2016
Total Realized/Unrealized Gains/(Losses) (2)
Gains/
(Losses)
in OCI
(3)
Gross
Gross
Transfers
into
Level 3 
Gross
Transfers
out of
Level 3 
Balance
December 31
2016
Change in Unrealized Gains/(Losses) Related to Financial Instruments Still Held (2)
(Dollars in millions)PurchasesSalesIssuancesSettlements
Trading account assets: 
 
 
    
  
 
 
Corporate securities, trading loans and other$2,838
$78
$2
$1,508
$(847)$
$(725)$728
$(805)$2,777
$(82)
Equity securities407
74

73
(169)
(82)70
(92)281
(59)
Non-U.S. sovereign debt521
122
91
12
(146)
(90)

510
120
Mortgage trading loans, ABS and other MBS1,868
188
(2)988
(1,491)
(344)158
(154)1,211
64
Total trading account assets5,634
462
91
2,581
(2,653)
(1,241)956
(1,051)4,779
43
Net derivative assets (4)
(441)285

470
(1,155)
76
(186)(362)(1,313)(376)
AFS debt securities: 
 
 
    
 
 
 
 
Non-agency residential MBS106



(106)





Non-U.S. securities

(6)584
(92)
(263)6

229

Other taxable securities757
4
(2)


(83)
(82)594

Tax-exempt securities569

(1)1


(2)10
(35)542

Total AFS debt securities1,432
4
(9)585
(198)
(348)16
(117)1,365

Other debt securities carried at fair value – Non-agency residential MBS30
(5)






25

Loans and leases (5, 6)
1,620
(44)
69
(553)50
(194)6
(234)720
17
Mortgage servicing rights (6, 7)
3,087
149


(80)411
(820)

2,747
(107)
Loans held-for-sale (5)
787
79
50
22
(256)
(93)173
(106)656
70
Other assets374
(13)
38
(111)
(52)3

239
(36)
Federal funds purchased and securities loaned or sold under agreements to repurchase (5)
(335)(11)


(22)27
(19)1
(359)4
Trading account liabilities – Corporate securities and other(21)5


(11)



(27)4
Short-term borrowings (5)
(30)1




29




Accrued expenses and other liabilities (5)
(9)







(9)
Long-term debt (5)
(1,513)(74)(20)140

(521)948
(939)465
(1,514)(184)
(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 - trading account profits; Net derivative assets - primarily trading account profits and mortgage banking income; MSRs - primarily mortgage banking income; Long-term debt - primarily trading account profits. For MSRs, the amounts reflect the changes in modeled MSR fair value due principally to observed changes in interest rates, volatility, spreads and the shape of the forward swap curve.
(3)
Includes unrealized gains/losses in OCI on AFS securities, foreign currency translation adjustments and the impact of changes in the Corporation’s credit spreads on long-term debt accounted for under the fair value option. For more information, see Note 1 – Summary of Significant Accounting Principles.
(4)
Net derivatives include derivative assets of $3.9 billion and derivative liabilities of $5.2 billion.
(5)
Amounts represent instruments that are accounted for under the fair value option.
(6)
Issuances represent loan originations and MSRs recognized following securitizations or whole-loan sales.
(7)
Settlements represent the net change in fair value of the MSR asset due to the recognition of modeled cash flows and the passage of time.
Significant transfers into Level 3, primarily due to decreased price observability, during 2016 included $956 million of trading account assets, $186 million of net derivative assets $173 million of LHFS and $939 million of long-term debt. Transfers occur on a regular basis for long-term debt instruments due to changes inreflect the impact of unobservable inputs on the value of theCorporation's change to present bifurcated embedded derivative in relation to the instrument as a whole.
derivatives with their respective host instruments.
Significant transfers out of Level 3, primarily due to increased price observability, during 2016 included $1.1 billion of trading account assets, $362 millionof net derivative assets, $117 million of AFS debt securities, $234 million of loans and leases, $106 million of LHFS and $465 million of long-term debt.


Bank of America 2017176158



            
Level 3 – Fair Value Measurements in 2015 (1)
        
            
(Dollars in millions)
Balance
January 1
2015
Total Realized/Unrealized Gains/(Losses) (2)
Gains/
(Losses)
in OCI
(3)
Gross
Gross
Transfers
into
Level 3 
Gross
Transfers
out of
Level 3 
Balance
December 31
2015
Change in Unrealized Gains/(Losses) Related to Financial Instruments Still Held (2)
PurchasesSalesIssuancesSettlements
Trading account assets: 
 
 
    
  
 
 
Corporate securities, trading loans and other$3,270
$(31)$(11)$1,540
$(1,616)$
$(1,122)$1,570
$(762)$2,838
$(123)
Equity securities352
9

49
(11)
(11)41
(22)407
3
Non-U.S. sovereign debt574
114
(179)185
(1)
(145)
(27)521
74
Mortgage trading loans, ABS and other MBS2,063
154
1
1,250
(1,117)
(493)50
(40)1,868
(93)
Total trading account assets6,259
246
(189)3,024
(2,745)
(1,771)1,661
(851)5,634
(139)
Net derivative assets (4)
(920)1,335
(7)273
(863)
(261)(40)42
(441)605
AFS debt securities: 
 
 
    
 
 
 
 
Non-agency residential MBS279
(12)
134


(425)167
(37)106

Non-U.S. securities10





(10)



Other taxable securities1,667


189


(160)
(939)757

Tax-exempt securities599





(30)

569

Total AFS debt securities2,555
(12)
323


(625)167
(976)1,432

Other debt securities carried at fair value – Non-agency residential MBS
(3)
33





30

Loans and leases (5, 6)
1,983
(23)

(4)57
(237)144
(300)1,620
13
Mortgage servicing rights (6, 7)
3,530
187


(393)637
(874)

3,087
(85)
Loans held-for-sale (5)
173
(51)(8)771
(203)61
(61)203
(98)787
(39)
Other assets911
(55)
11
(130)
(51)10
(322)374
(61)
Federal funds purchased and securities loaned or sold under agreements to repurchase (5)

(11)


(131)217
(411)1
(335)
Trading account liabilities – Corporate securities and other(36)19

30
(34)



(21)(3)
Short-term borrowings (5)

17



(52)10
(24)19
(30)1
Accrued expenses and other liabilities (5)
(10)1







(9)1
Long-term debt (5)
(2,362)287
19
616

(188)273
(1,592)1,434
(1,513)255

(1)
Level 3 – Fair Value Measurements (1)
(Dollars in millions)Balance
January 1
Total Realized/Unrealized Gains (Losses) in Net
 Income (2)
Gains
(Losses)
in OCI (3)
GrossGross
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)
PurchasesSalesIssuancesSettlements
Year Ended December 31, 2018
Trading account assets:      
Corporate securities, trading loans and other$1,864 $(32)$(1)$436 $(403)$$(568)$804 $(547)$1,558 $(117)
Equity securities235 (17)44 (11)(4)78 (49)276 (22)
Non-U.S. sovereign debt556 47 (44)13 (57)(30)117 (137)465 48 
Mortgage trading loans, ABS and other MBS1,498 148 585 (910)(158)705 (236)1,635 97 
Total trading account assets4,153 146 (42)1,078 (1,381)(760)1,704 (969)3,934 
Net derivative assets (liabilities) (4)
(1,714)106 531 (1,179)778 39 504 (935)(116)
AFS debt securities:       
Non-agency residential MBS27 (33)(71)(25)774 (75)597 
Non-U.S. securities25 (1)(10)(15)
Other taxable securities509 (3)(23)(11)60 (526)
Tax-exempt securities469 (1)(469)
Total AFS debt securities (5)
1,003 28 (37)(104)(52)838 (1,070)606 
Other debt securities carried at fair value - Non-agency residential MBS(18)(8)(34)365 (133)172 (18)
Loans and leases (6,7)
571 (16)(134)(83)338 (9)
Loans held-for-sale (6)
690 44 (26)71 (201)23 (60)542 31 
Other assets (5,7,8)
2,425 414 (38)(69)96 (792)929 (35)2,932 149 
Trading account liabilities – Corporate securities and other(24)11 (12)(2)(18)(7)
Accrued expenses and other liabilities (6)
(8)
Long-term debt (6)
(1,863)103 (141)486 (262)847 (817)95 
(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 - trading account profits; Net derivative assets - primarily trading account profits and mortgage banking income; MSRs - primarily mortgage banking income; Long-term debt - primarily trading account profits. For MSRs, the amounts reflect the changes in modeled MSR fair value due principally to observed changes in interest rates, volatility, spreads and the shape of the forward swap curve.   
(3)
Includes unrealized gains/losses in OCI on AFS securities, foreign currency translation adjustments and the impact of changes in the Corporation’s credit spreads on long-term debt accounted for under the fair value option. For more information, see Note 1 – Summary of Significant Accounting Principles.
(4)
Net derivatives include derivative assets of $5.1 billion and derivative liabilities of $5.6 billion.
(5)
Amounts represent instruments that are accounted for under the fair value option.
(6)
Issuances represent loan originations and MSRs recognized following securitizations or whole-loan sales.
(7)
Settlements represent the net change in fair value of the MSR asset due to the recognition of modeled cash flows and the passage of time.
Significant transfers into 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 dueother income related to decreased price observability, during 2015 included $1.7MSRs; Long-term debt - primarily market making and similar activities.   
(3)Includes unrealized gains (losses) in OCI on AFS debt securities, foreign currency translation adjustments and the impact of changes in the Corporation’s credit spreads on long-term debt accounted for under the fair value option. Amounts include net unrealized losses of $105 million related to financial instruments still held at December 31, 2018.
(4)Net derivative assets (liabilities) include derivative assets of $3.5 billion and derivative liabilities of trading account assets, $167 million$4.4 billion.
(5)Transfers out of AFS debt securities $144 millionand into other assets primarily relate to the reclassifcation of loanscertain securities.
(6)Amounts represent instruments that are accounted for under the fair value option.
(7)Issuances represent loan originations and leases, $203 million of LHFS, $411 million of federal funds purchased and securities loanedMSRs recognized following securitizations or sold under agreements to repurchase and $1.6 billion of long-term debt. Transfers occur on a regular basis for these long-term debt instruments due to changeswhole-loan sales.
(8)Settlements primarily represent the net change in the impact of unobservable inputs on thefair value of the embedded derivative in relationMSR asset due to the instrument as a whole.
recognition of modeled cash flows and the passage of time.


Significant transfers out of Level 3, primarily due to increased price observability, unless otherwise noted, during 2015 included $851 million of trading account assets, as a result of increased market liquidity, $976 million of AFS debt securities, $300 million of loans and leases, $322 million of other assets and $1.4 billion of long-term debt.


177159Bank of America 2017




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, 20172020 and 2016.2019.
Quantitative Information about Level 3 Fair Value Measurements at December 31, 2020
(Dollars in millions)Inputs
Financial InstrumentFair
Value
Valuation
Technique
Significant Unobservable
Inputs
Ranges of
Inputs
Weighted Average (1)
Loans and Securities (2)
Instruments backed by residential real estate assets$1,543 Discounted cash flow, Market comparablesYield(3)% to 25%%
Trading account assets – Mortgage trading loans, ABS and other MBS467 Prepayment speed1% to 56% CPR20% CPR
Loans and leases431 Default rate0% to 3% CDR1% CDR
AFS debt securities – Non-agency residential378 Price$0 to $168$110
Other debt securities carried at fair value – Non-agency residential267 Loss severity0% to 47%18 %
Instruments backed by commercial real estate assets$407 Discounted cash
flow
Yield0% to 25%%
Trading account assets – Corporate securities, trading loans and other262 Price$0 to $100$52
Trading account assets – Mortgage trading loans, ABS and other MBS43 
AFS debt securities, primarily other taxable securities89 
Loans held-for-sale13 
Commercial loans, debt securities and other$3,066 Discounted cash flow, Market comparablesYield0% to 26%%
Trading account assets – Corporate securities, trading loans and other1,097 Prepayment speed10% to 20%14 %
Trading account assets – Non-U.S. sovereign debt354 Default rate3% to 4%%
Trading account assets – Mortgage trading loans, ABS and other MBS930 Loss severity35% to 40%38 %
AFS debt securities – Tax-exempt securities176 Price$0 to $142$66
Loans and leases286 Long-dated equity volatilities77%n/a
Loans held-for-sale223 
Other assets, primarily auction rate securities$937 Discounted cash flow, Market comparablesPrice$10 to $97$91

Discount rate%n/a
MSRs$1,033 Discounted cash
flow
Weighted-average life, fixed rate (5)
0 to 13 years4 years
Weighted-average life, variable rate (5)
0 to 10 years3 years
Option-adjusted spread, fixed rate7% to 14%%
Option-adjusted spread, variable rate9% to 15%12 %
Structured liabilities
Long-term debt$(1,164)
Discounted cash flow, Market comparables, Industry standard derivative pricing (3)
Yield0% to 11%%
Equity correlation2% to 100%64 %
Long-dated equity volatilities7% to 64%32 %
Price$0 to $124$86
Natural gas forward price$1/MMBtu to $4/MMBtu$3 /MMBtu
Net derivative assets (liabilities)
Credit derivatives$(112)Discounted cash flow, Stochastic recovery correlation modelYield5%n/a
Upfront points0 to 100 points 75 points
Prepayment speed15% to 100% CPR22% CPR
Default rate2% CDRn/a
Credit correlation21% to 64%57 %
Price$0 to $122$69
Equity derivatives$(1,904)
Industry standard derivative pricing (3)
Equity correlation2% to 100%64 %
Long-dated equity volatilities7% to 64%32 %
Commodity derivatives$(1,426)
Discounted cash flow, Industry standard derivative pricing (3)
Natural gas forward price$1/MMBtu to $4/MMBtu$3 /MMBtu
Correlation39% to 85%73 %
Volatilities23% to 70%39 %
Interest rate derivatives$(26)
Industry standard derivative pricing (4)
Correlation (IR/IR)15% to 96%34 %
Correlation (FX/IR)0% to 46%%
Long-dated inflation rates
 (7)% to 84%
14 %
Long-dated inflation volatilities0% to 1%%
Interest rate volatilities0% to 2%%
Total net derivative assets (liabilities)$(3,468)
      
Quantitative Information about Level 3 Fair Value Measurements at December 31, 2017 
     
(Dollars in millions)  Inputs
Financial Instrument
Fair
Value
Valuation
Technique
Significant Unobservable
Inputs
Ranges of
Inputs
Weighted Average
Loans and Securities (1)
     
Instruments backed by residential real estate assets$871
Discounted cash flowYield0% to 25%
6%
Trading account assets – Mortgage trading loans, ABS and other MBS298
Prepayment speed0% to 22% CPR
12%
Loans and leases570
Default rate0% to 3% CDR
1%
Loans held-for-sale3
Loss severity0% to 53%
17%
Instruments backed by commercial real estate assets$286
Discounted cash flowYield0% to 25%
9%
Trading account assets – Corporate securities, trading loans and other244
Price$0 to $100
$67
Trading account assets – Mortgage trading loans, ABS and other MBS42
   
Commercial loans, debt securities and other$4,023
Discounted cash flow, Market comparablesYield0% to 12%
5%
Trading account assets – Corporate securities, trading loans and other1,613
Prepayment speed10% to 20%
16%
Trading account assets – Non-U.S. sovereign debt556
Default rate3% to 4%
4%
Trading account assets – Mortgage trading loans, ABS and other MBS1,158
Loss severity35% to 40%
37%
AFS debt securities – Other taxable securities8
Price$0 to $145
$63
Loans and leases


1
   
Loans held-for-sale

687
   
Auction rate securities$977
Discounted cash flow, Market comparablesPrice$10 to $100
$94
Trading account assets – Corporate securities, trading loans and other7
   
AFS debt securities – Other taxable securities501
   
AFS debt securities – Tax-exempt securities469
   
MSRs$2,302
Discounted cash flow
Weighted-average life, fixed rate (4)
0 to 14 years
5 years
  
Weighted-average life, variable rate (4)
0 to 10 years
3 years
  Option Adjusted Spread, fixed rate9% to 14%
10%
  Option Adjusted Spread, variable rate9% to 15%
12%
Structured liabilities     
Long-term debt$(1,863)
Discounted cash flow, Market comparables, Industry standard derivative pricing (2)
Equity correlation15% to 100%
63%
  Long-dated equity volatilities4% to 84%
22%
  Yield7.5%n/a
  Price$0 to $100
$66
Net derivative assets     
Credit derivatives$(282)Discounted cash flow, Stochastic recovery correlation modelYield1% to 5%
3%
  Upfront points0 points to 100 points
71 points
  Credit correlation35% to 83%
42%
  Prepayment speed15% to 20% CPR
16%
  Default rate1% to 4% CDR
2%
  Loss severity35%n/a
  Price$0 to $102
$82
Equity derivatives$(2,059)
Industry standard derivative pricing (2)
Equity correlation15% to 100%
63%
  Long-dated equity volatilities4% to 84%
22%
Commodity derivatives$(3)
Discounted cash flow, Industry standard derivative pricing (2)
Natural gas forward price$1/MMBtu to $5/MMBtu
$3/MMBtu
  Correlation71% to 87%
81%
  Volatilities26% to 132%
57%
Interest rate derivatives$630
Industry standard derivative pricing (3)
Correlation (IR/IR)15% to 92%
50%
  Correlation (FX/IR)0% to 46%
1%
  Long-dated inflation rates-14% to 38%
4%
  Long-dated inflation volatilities0% to 1%
1%
Total net derivative assets$(1,714)    
(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.
(1)
(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 156: 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.
(3)Includes models such as Monte Carlo simulation and Black-Scholes.
(4)Includes models such as Monte Carlo simulation, Black-Scholes and other methods that model the joint dynamics of interest, inflation and foreign exchange rates.
(5)The weighted-average life is a product of changes in market rates of interest, prepayment rates and other model and cash flow assumptions.
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 173: Trading account assets – Corporate securities, trading loans and other of $1.9 billion, Trading account assets – Non-U.S. sovereign debt of $556 million, Trading account assets – Mortgage trading loans, ABS and other MBS of $1.5 billion, AFS debt securities – Other taxable securities of $509 million, AFS debt securities – Tax-exempt securities of $469 million, Loans and leases of $571 million and LHFS of $690 million.
(2)
Includes models such as Monte Carlo simulation and Black-Scholes.
(3)
Includes models such as Monte Carlo simulation, Black-Scholes and other methods that model the joint dynamics of interest, inflation and foreign exchange rates.
(4)
The weighted-average life is a product of changes in market rates of interest, prepayment rates and other model and cash flow assumptions.
CPR = Constant Prepayment Rate
CDR = Constant Default Rate
MMBtu = Million British thermal units
IR = Interest Rate
FX = Foreign Exchange
n/a = not applicable

Bank of America 2017178160



   
Quantitative Information about Level 3 Fair Value Measurements at December 31, 2016
Quantitative Information about Level 3 Fair Value Measurements at December 31, 2019Quantitative Information about Level 3 Fair Value Measurements at December 31, 2019
    
(Dollars in millions)  Inputs(Dollars in millions)Inputs
Financial InstrumentFair
Value
Valuation
Technique
Significant Unobservable
Inputs
Ranges of
Inputs
Weighted AverageFinancial InstrumentFair
Value
Valuation
Technique
Significant Unobservable
Inputs
Ranges of
Inputs
Weighted Average (1)
Loans and Securities (1)
     
Loans and Securities (2)
Loans and Securities (2)
Instruments backed by residential real estate assets$1,066
Discounted cash flow, Market comparablesYield0% to 50%
7%Instruments backed by residential real estate assets$1,407 Discounted cash flow, Market comparablesYield0% to 25%%
Trading account assets – Mortgage trading loans, ABS and other MBS337
Prepayment speed0% to 27% CPR
14%Trading account assets – Mortgage trading loans, ABS and other MBS332 Prepayment speed1% to 27% CPR17% CPR
Loans and leases718
Default rate0% to 3% CDR
2%Loans and leases281 Default rate0% to 3% CDR1% CDR
Loans held-for-sale11
Loss severity0% to 54%
18%Loans held-for-saleLoss severity0% to 47%14 %
AFS debt securities, primarily non-agency residentialAFS debt securities, primarily non-agency residential491 Price$0 to td60$94
Other debt securities carried at fair value - Non-agency residentialOther debt securities carried at fair value - Non-agency residential299 
Instruments backed by commercial real estate assets$317
Discounted cash flow, Market comparablesYield0% to 39%
11%Instruments backed by commercial real estate assets$303 Discounted cash flowYield0% to 30%14 %
Trading account assets – Corporate securities, trading loans and other178
Price$0 to td00
$65Trading account assets – Corporate securities, trading loans and other201 Price$0 to td00$55
Trading account assets – Mortgage trading loans, ABS and other MBS53
  Trading account assets – Mortgage trading loans, ABS and other MBS85 
Loans held-for-sale86
  Loans held-for-sale17 
Commercial loans, debt securities and other$4,486
Discounted cash flow, Market comparablesYield1% to 37%
14%Commercial loans, debt securities and other$3,798 Discounted cash flow, Market comparablesYield1% to 20%%
Trading account assets – Corporate securities, trading loans and other2,565
Prepayment speed5% to 20%
19%Trading account assets – Corporate securities, trading loans and other1,306 Prepayment speed10% to 20%13 %
Trading account assets – Non-U.S. sovereign debt510
Default rate3% to 4%
4%Trading account assets – Non-U.S. sovereign debt482 Default rate3% to 4%%
Trading account assets – Mortgage trading loans, ABS and other MBS821
Loss severity0% to 50%
19%Trading account assets – Mortgage trading loans, ABS and other MBS1,136 Loss severity35% to 40%38 %
AFS debt securities – Other taxable securities29
Price$0 to td92
$68
AFS debt securities – Tax-exempt securitiesAFS debt securities – Tax-exempt securities108 Price $0 to td42$72
Loans and leases2
Discounted cash flow, Market comparablesDuration0 to 5 years
3 yearsLoans and leases412 Long-dated equity volatilities35%n/a
Loans held-for-sale559
Enterprise value/EBITDA multiple34x
n/aLoans held-for-sale354 Discounted cash flow, Market comparables
Auction rate securities$1,141
Pricetd0 to td00
$94
Trading account assets – Corporate securities, trading loans and other34
 
AFS debt securities – Other taxable securities565
  
AFS debt securities – Tax-exempt securities542
  
Other assets, primarily auction rate securitiesOther assets, primarily auction rate securities$815 Pricetd0 to td00$96


Discounted cash flow, Market comparables
MSRs$2,747
Discounted cash flow
Weighted-average life, fixed rate (4)
0 to 15 years
6 years
MSRs$1,545 
Weighted-average life, fixed rate (5)
0 to 14 years5 years
 
Weighted-average life, variable rate (4)
0 to 14 years
4 years
Weighted-average life, variable rate (5)
0 to 9 years3 years
 Option Adjusted Spread, fixed rate9% to 14%
10%Discounted cash flowOption-adjusted spread, fixed rate7% to 14%%
 Option Adjusted Spread, variable rate9% to 15%
12%Option-adjusted spread, variable rate9% to 15%11 %
Structured liabilities     Structured liabilities
Long-term debt$(1,514)
Discounted cash flow, Market comparables, Industry standard derivative pricing (2)
Equity correlation13% to 100%
68%Long-term debt$(1,149)Yield2% to 6%%
 Long-dated equity volatilities4% to 76%
26%
Discounted cash flow, Market comparables, Industry standard derivative pricing (3)
Equity correlation 9% to 100%63 %
 Yield6% to 37%
20%Long-dated equity volatilities4% to 101%32 %
 Pricetd2 to $87
$73Price$0 to td16$74
 Duration0 to 5 years
3 years
Natural gas forward pricetd/MMBtu to $5/MMBtu$3/MMBtu
Net derivative assets     
Net derivative assets (liabilities)Net derivative assets (liabilities)
Credit derivatives$(129)Discounted cash flow, Stochastic recovery correlation modelYield0% to 24%
13%Credit derivatives$13 Discounted cash flow, Stochastic recovery correlation modelYield5%n/a
 Upfront points0 to 100 points
72 points
Upfront points0 to 100 points 63 points
 Credit spreads17 bps to 814 bps
248 bps
 Credit correlation21% to 80%
44%Prepayment speed15% to 100% CPR22% CPR
 Prepayment speed10% to 20% CPR
18%Default rate1% to 4% CDR2% CDR
 Default rate1% to 4% CDR
3%Loss severity35%n/a
 Loss severity35%n/a
Price$0 to td04$73
Equity derivatives$(1,690)
Industry standard derivative pricing (2)
Equity correlation13% to 100%
68%Equity derivatives$(1,081)
Industry standard derivative pricing (3)
Equity correlation9% to 100%63 %
 Long-dated equity volatilities4% to 76%
26%Long-dated equity volatilities4% to 101%32 %
Commodity derivatives$6
Discounted cash flow, Industry standard derivative pricing (2)
Natural gas forward pricetd/MMBtu to $6/MMBtu
$4/MMBtu
Commodity derivatives$(1,357)
Discounted cash flow, Industry standard derivative pricing (3)
Natural gas forward pricetd/MMBtu to $5/MMBtu$3/MMBtu
 Correlation66% to 95%
85%Correlation30% to 69%68 %
 Volatilities23% to 96%
36%Volatilities14% to 54%27 %
   
Interest rate derivatives$500
Industry standard derivative pricing (3)
Correlation (IR/IR)15% to 99%
56%Interest rate derivatives$(113)
Industry standard derivative pricing (4)
Correlation (IR/IR)15% to 94%52 %
 Correlation (FX/IR)0% to 40%
2%Correlation (FX/IR)0% to 46%%
 Illiquid IR and long-dated inflation rates-12% to 35%
5%Long-dated inflation rates
G(23)% to 56%
16 %
 Long-dated inflation volatilities0% to 2%
1%Long-dated inflation volatilities0% to 1%%
Total net derivative assets$(1,313)    
Total net derivative assets (liabilities)Total net derivative assets (liabilities)$(2,538)
(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 157: 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.
(3)Includes models such as Monte Carlo simulation and Black-Scholes.
(4)Includes models such as Monte Carlo simulation, Black-Scholes and other methods that model the joint dynamics of interest, inflation and foreign exchange rates.
(5)The weighted-average life is a product of changes in market rates of interest, prepayment rates and other model and cash flow assumptions.
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 174: Trading account assets – Corporate securities, trading loans and other of $2.8 billion, Trading account assets – Non-U.S. sovereign debt of $510 million, Trading account assets – Mortgage trading loans, ABS and other MBS of $1.2 billion, AFS debt securities – Other taxable securities of $594 million, AFS debt securities – Tax-exempt securities of $542 million, Loans and leases of $720 million and LHFS of $656 million.
(2)
Includes models such as Monte Carlo simulation and Black-Scholes.
(3)
Includes models such as Monte Carlo simulation, Black-Scholes and other methods that model the joint dynamics of interest, inflation and foreign exchange rates.
(4)
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
EBITDA = Earnings before interest, taxes, depreciation and amortization
MMBtu = Million British thermal units
IR = Interest Rate
FX = Foreign Exchange
n/a = not applicable


179161Bank of America 2017




In the previous tables, instruments backed by residential and commercial real estate assets include RMBS, commercial MBS, whole loans and mortgage CDOs. Commercial loans, debt securities and other include corporate CLOs and CDOs, commercial loans and bonds, and securities backed by non-real estate assets. Structured liabilities primarily include equity-linked notes that are accounted for under the fair value option.
The Corporation uses multiple market approaches in valuing certain of its Level 3 financial instruments. For example, market comparables and discounted cash flows are used together. For a given product, such as corporate debt securities, market comparables may be used to estimate some of the unobservable inputs and then these inputs are incorporated into a discounted cash flow model. Therefore, the balances disclosed encompass both of these techniques.
The level of aggregation and diversity within the products disclosed in the tables resultsresult in certain ranges of inputs being wide and unevenly distributed across asset and liability categories.
SensitivityUncertainty of Fair Value Measurements to Changes infrom Unobservable Inputs
Loans and Securities
A significant increase in market yields, default rates, loss severities or duration would resulthave resulted in a significantly lower fair value for long positions. Short positions would behave 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 resulthave resulted in a significantly higher fair value for long positions, and short positions would behave been impacted in a directionally opposite way.
Mortgage Servicing Rights
The weighted-average lives and fair value of MSRs are sensitive to changes in modeled assumptions. The weighted-average life is a product of changes in market rates of interest, prepayment rates and other model and cash flow assumptions. The weighted-average life represents the average period of time that the MSRs’ cash flows are expected to be received. Absent other changes, an increase (decrease) to the weighted-average life would generally result in an increase (decrease) in the fair value of the MSRs. For example, a 10 percent or 20 percent decrease in prepayment rates, which impacts the weighted-average life, could result in an increase in fair value of $83 million or $172 million, while a 10 percent or 20 percent increase in prepayment rates could result in a decrease in fair value of $76 million or $147 million. A 100 bp or 200 bp decrease in OAS levels could result in an increase in fair value of $69 million or $143 million, while a 100 bp or 200 bp increase in OAS levels could result in a decrease in fair value of $65 million
or $125 million. These sensitivities are hypothetical and actual amounts may vary materially. As the amounts indicate, changes in fair value based on variations in assumptions generally cannot be extrapolated because the relationship of the change in assumption to the change in fair value may not be linear. Also, the effect of a variation in a particular assumption on the fair value of MSRs that continue to be held by the Corporation is calculated without changing any other assumption. In reality, changes in one factor may result in changes in another, which might magnify or counteract the sensitivities. In addition, these sensitivities do not reflect any hedge strategies that may be undertaken to mitigate such risk. The Corporation manages the risk in MSRs with derivatives such as options and interest rate swaps, which are not designated as accounting hedges, as well as securities including MBS and U.S. Treasury securities. The securities used to manage the risk in the MSRs are classified in other assets on the Consolidated Balance Sheet.
Structured Liabilities and Derivatives
For credit derivatives, a significant increase in market yield, upfront points (i.e., a single upfront payment made by a
protection buyer at inception), credit spreads, default rates or loss severities would resulthave 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 resulthave resulted in a significantly higher fair value. Net short protection positions would behave 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 resulthave 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 resulthave resulted in a significantly lower fair value. A significant decrease in duration may result in a significantly higher fair value.


Bank of America 2017180


Nonrecurring Fair Value
The Corporation holds certain assets that are measured at fair value but only in certain situations (e.g., impairment)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 2017, 20162020, 2019 and 2015.2018.
Assets Measured at Fair Value on a Nonrecurring Basis
December 31, 2020December 31, 2019
(Dollars in millions)
 
Level 2Level 3Level 2Level 3
Assets   
Loans held-for-sale$1,020 $792 $53 $102 
Loans and leases (1)
0 301 257 
Foreclosed properties (2, 3)
0 17 17 
Other assets323 576 178 646 
Gains (Losses)
202020192018
Assets   
Loans held-for-sale$(79)$(14)$(18)
Loans and leases (1)
(73)(81)(202)
Foreclosed properties(6)(9)(24)
Other assets(98)(2,145)(64)
(1)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.
(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.
        
Assets Measured at Fair Value on a Nonrecurring Basis
  
 December 31, 2017 December 31, 2016
(Dollars in millions)
 
Level 2 Level 3 Level 2 Level 3
Assets 
  
    
Loans held-for-sale$
 $2
 $193
 $44
Loans and leases (1)

 894
 
 1,416
Foreclosed properties (2, 3)

 83
 
 77
Other assets425
 
 358
 
        
   Gains (Losses)
   2017 2016 2015
Assets   
  
  
Loans held-for-sale  $(6) $(54) $(8)
Loans and leases (1)
  (336) (458) (993)
Foreclosed properties  (41) (41) (57)
Other assets  (124) (74) (28)
(1)
Includes $135 millionBank of losses on loans that were written down to a collateral value of zero during 2017 compared to losses of $150 million and $174 million for 2016 and 2015.America 162
(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 $801 million and $1.2 billion of properties acquired upon foreclosure of certain government-guaranteed loans (principally FHA-insured loans) at December 31, 2017 and 2016.
The table below presents information about significant unobservable inputs related toutilized in the Corporation’sCorporation's nonrecurring Level 3 financial assetsfair value measurements during 2020 and liabilities at December 31, 2017 and 2016. Loans and leases backed by residential real estate assets represent2019.
Quantitative Information about Nonrecurring Level 3 Fair Value Measurements
Inputs
Financial InstrumentFair ValueValuation
Technique
Significant Unobservable
Inputs
Ranges of
Inputs
Weighted
Average (1)
(Dollars in millions)2020
Loans held-for-sale$792 Discounted cash flowPrice$8 to $99$95
Loans and leases (2)
301 Market comparablesOREO discount13% to 59%24 %
Costs to sell8% to 26%%
Other assets (3)
576 Discounted cash flowRevenue attrition2% to 19%%
Discount rate11% to 14%12 %
2019
Loans held-for-sale$102 Discounted cash flowPrice$85 to $97$88
Loans and leases (2)
257 Market comparablesOREO discount13% to 59%24 %
Costs to sell8% to 26%%
Other assets (4)
640 Discounted cash flowCustomer attrition0% to 19%%
Cost to service11% to 19%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.
          
Quantitative Information about Nonrecurring Level 3 Fair Value Measurements
          
(Dollars in millions)    Inputs
Financial InstrumentFair Value 
Valuation
Technique
 
Significant Unobservable
Inputs
 
Ranges of
Inputs
 Weighted Average
 December 31, 2017
Loans and leases backed by residential real estate assets$894
 Market comparables OREO discount 15% to 58% 23%
     Costs to sell 5% to 49% 7%
(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.
 December 31, 2016
Loans and leases backed by residential real estate assets$1,416
 Market comparables OREO discount 8% to 56% 21%
     Costs to sell 7% to 45% 9%
(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 consumer and commercial loans and loan commitments that exceed the Corporation’s 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 the Corporation’s public side credit view and market perspectives determining the size and timing of the hedging activity. These credit derivatives do not meet the requirements for designation as accounting hedges and therefore are carried at fair value with changes in fair value recorded in other income. Electing thevalue. 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, 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
credit derivatives at fair value. The Corporation also elected the fair value option for certain loans held in consolidated VIEs.
Loans Held-for-sale
The Corporation elects to account for residential mortgage LHFS, commercial mortgage LHFS and certain other LHFS under the fair value option with interest income on these LHFS recorded in other interest income.option. These loans are actively managed and monitored and, as appropriate, certain market risks of the loans may be mitigated through the use of derivatives. The Corporation has elected not to designate the derivatives as qualifying accounting hedges, and therefore, they are carried at fair value with changes in fair value recorded in other income.value. The changes in fair value of the loans are largely
offset by changes in the fair value of the derivatives. Election of theThe 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.

181Bank of America 2017



Loans Reported as Trading Account Assets
The Corporation elects to account for certain loans that are held for the purpose of trading and are risk-managed on a fair value basis under the fair value option.
Other Assets
The Corporation elects to account for certain long-term fixed-rate margin loans that are hedged with derivatives under the fair value option. Election of the fair value option allows the Corporation to reduce the accounting volatility that would otherwise result from the asymmetry created by accounting for the financial instruments at historical cost and the derivatives at fair value.
Securities Financing Agreements
The Corporation elects to account for certain securities financing agreements, including resale and repurchase agreements, under the fair value option based on the tenor of the agreements, which reflects the magnitude of the interest rate risk. The majority of securities financingoption. These elections include certain agreements collateralized by the U.S. government securities are not accounted for under the fair value option as these contractsand its agencies, which are generally short-dated and therefore thehave minimal interest rate risk is not significant.risk.

163 Bank of America


Long-term Deposits
The Corporation elects to account for certain long-term fixed-rate and rate-linked deposits that are hedged with derivatives that do not qualify for hedge accounting under the fair value option.accounting. Election of the fair value option allows the Corporation to reduce the accounting volatility that would otherwise result from the asymmetry created by accounting for the financial instruments at
historical cost and the derivatives at fair value. The Corporation has not elected to carry other long-term deposits at fair value because they are not hedged using derivatives.
Short-term Borrowings
The Corporation elects to account for certain short-term borrowings, primarily short-term structured liabilities, under the fair value option because this debt is risk-managed on a fair value basis.
The Corporation elects to account for certain asset-backed secured financings, which are also classified in short-term borrowings, under the fair value option. Election of the fair value option allows the Corporation to reduce the accounting volatility
that would otherwise result from the asymmetry created by accounting for the asset-backed secured financings at historical cost and the corresponding mortgage LHFS securing these financings at fair value.
Long-term Debt
The Corporation elects to account for certain long-term debt, primarily structured liabilities, under the fair value option. This long-term debt is either risk-managed on a fair value basis or the related hedges do not qualify for hedge accounting.
Fair Value Option Elections
The table below providesfollowing 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, 20172020 and 2016.
            
Fair Value Option Elections           
            
 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
 December 31, 2017 December 31, 2016
(Dollars in millions)           
Federal funds sold and securities borrowed or purchased under agreements to resell$52,906
 $52,907
 $(1) $49,750
 $49,615
 $135
Loans reported as trading account assets (1)
5,735
 11,804
 (6,069) 6,215
 11,557
 (5,342)
Trading inventory – other12,027
 n/a
 n/a
 8,206
 n/a
 n/a
Consumer and commercial loans5,710
 5,744
 (34) 7,085
 7,190
 (105)
Loans held-for-sale2,156
 3,717
 (1,561) 4,026
 5,595
 (1,569)
Customer receivables and other assets3
 n/a
 n/a
 253
 250
 3
Long-term deposits449
 421
 28
 731
 672
 59
Federal funds purchased and securities loaned or sold under agreements to repurchase36,182
 36,187
 (5) 35,766
 35,929
 (163)
Short-term borrowings1,494
 1,494
 
 2,024
 2,024
 
Unfunded loan commitments120
 n/a
 n/a
 173
 n/a
 n/a
Long-term debt (2)
31,786
 31,512
 274
 30,037
 29,862
 175
(1)
A significant portion of the loans reported as trading account assets are distressed loans that trade2019, and were purchased at a deep discount to par, and the remainder are loans with a fair value near contractual principal outstanding.
(2)
Includes structured liabilities with a fair value of $31.4 billion and $29.7 billion, and contractual principal outstanding of $31.1 billion and $29.5 billion at December 31, 2017 and 2016.
n/a = not applicable

Bank of America 2017182


The following tables provide information about where changes in the fair value of assets and liabilities accounted for under the fair value option are included in the Consolidated Statement of Income for 2017, 20162020, 2019 and 2015.2018.
Fair Value Option Elections
December 31, 2020December 31, 2019
(Dollars in millions)Fair Value Carrying AmountContractual Principal OutstandingFair Value Carrying Amount Less Unpaid PrincipalFair Value
Carrying
Amount
Contractual Principal OutstandingFair Value Carrying
Amount Less Unpaid Principal
Federal funds sold and securities borrowed or purchased under agreements to resell$108,856 $108,811 $45 $50,364 $50,318 $46 
Loans reported as trading account assets (1)
7,967 17,372 (9,405)6,989 14,703 (7,714)
Trading inventory – other22,790 n/an/a19,574 n/an/a
Consumer and commercial loans6,681 6,778 (97)8,335 8,372 (37)
Loans held-for-sale (1)
1,585 2,521 (936)3,709 4,879 (1,170)
Other assets200 n/an/an/an/a
Long-term deposits481 448 33 508 496 12 
Federal funds purchased and securities loaned or sold under agreements to repurchase135,391 135,390 1 16,008 16,029 (21)
Short-term borrowings5,874 5,178 696 3,941 3,930 11 
Unfunded loan commitments99 n/an/a90 n/an/a
Long-term debt32,200 33,470 (1,270)34,975 35,730 (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 near contractual principal outstanding.
n/a = not applicable
        
Gains (Losses) Relating to Assets and Liabilities Accounted for Under the Fair Value Option
        
 
Trading
Account
Profits
 Mortgage Banking Income 
Other
Income
 Total
(Dollars in millions)2017
Federal funds sold and securities borrowed or purchased under agreements to resell$(57) $
 $
 $(57)
Loans reported as trading account assets318
 
 
 318
Trading inventory – other (1)
3,821
 
 
 3,821
Consumer and commercial loans(9) 
 35
 26
Loans held-for-sale (2)

 211
 87
 298
Unfunded loan commitments
 
 36
 36
Long-term debt (3, 4)
(1,044) 
 (146) (1,190)
Other (5)
(36) 
 13
 (23)
Total$2,993
 $211
 $25
 $3,229
        
 2016
Federal funds sold and securities borrowed or purchased under agreements to resell$(64) $
 $1
 $(63)
Loans reported as trading account assets301
 
 
 301
Trading inventory – other (1)
57
 
 
 57
Consumer and commercial loans49
 
 (37) 12
Loans held-for-sale (2)
11
 518
 6
 535
Unfunded loan commitments
 
 487
 487
Long-term debt (3, 4)
(489) 
 (97) (586)
Other (5)
(21) 
 52
 31
Total$(156) $518
 $412
 $774
        
 2015
Federal funds sold and securities borrowed or purchased under agreements to resell$(195) $
 $
 $(195)
Loans reported as trading account assets(199) 
 
 (199)
Trading inventory – other (1)
1,284
 
 
 1,284
Consumer and commercial loans52
 
 (295) (243)
Loans held-for-sale (2)
(36) 673
 63
 700
Unfunded loan commitments
 
 (210) (210)
Long-term debt (3, 4)
2,107
 
 (633) 1,474
Other (5)
37
 
 23
 60
Total$3,050
 $673
 $(1,052) $2,671
(1)
The gains in trading account profits are primarily offset by losses on trading liabilities that hedge these assets.
(2)
Includes the value of IRLCs on funded loans, including those sold during the period.
(3)
The majority of the net gains (losses) in trading account profits relate to the embedded derivative in structured liabilities and are offset by gains (losses) on derivatives and securities that hedge these liabilities.
(4)
For the cumulative impact of changes in the Corporation’s own credit spreads and the amount recognized in 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.
(5)
Includes gains (losses) on other assets, long-term deposits, federal funds purchased and securities loaned or sold under agreements to repurchase and short-term borrowings.
      
Gains (Losses) Related to Borrower-specific Credit Risk for Assets Accounted for Under the Fair Value Option
      
(Dollars in millions)2017 2016 2015
Loans reported as trading account assets$24
 $7
 $37
Consumer and commercial loans36
 (53) (200)
Loans held-for-sale(22) (34) 37

183Bank of America 2017164




Gains (Losses) Relating to Assets and Liabilities Accounted for Under the Fair Value Option
Market making and similar activitiesOther
Income
Total
(Dollars in millions)2020
Loans reported as trading account assets$107 $0 $107 
Trading inventory – other (1)
3,216 0 3,216 
Consumer and commercial loans22 (3)19 
Loans held-for-sale (2)
0 103 103 
Short-term borrowings(170)0 (170)
Unfunded loan commitments0 (65)(65)
Long-term debt (3)
(2,175)(53)(2,228)
Other (4)
35 (22)13 
Total$1,035 $(40)$995 
2019
Loans reported as trading account assets$203 $$203 
Trading inventory – other (1)
5,795 5,795 
Consumer and commercial loans92 12 104 
Loans held-for-sale (2)
98 98 
Short-term borrowings(24)(24)
Unfunded loan commitments79 79 
Long-term debt (3)
(1,098)(78)(1,176)
Other (4)
(27)(18)
Total$4,977 $84 $5,061 
2018
Loans reported as trading account assets$$$
Trading inventory – other (1)
1,750 1,750 
Consumer and commercial loans(422)(53)(475)
Loans held-for-sale (2)
24 25 
Short-term borrowings
Unfunded loan commitments(49)(49)
Long-term debt (3)
2,157 (93)2,064 
Other (4)
18 24 
Total$3,502 $(153)$3,349 

(1)    The gains in market making and similar activities are primarily offset by losses on trading liabilities that hedge these assets.
(2)    Includes the value of IRLCs on funded loans, including those sold during the period.
(3)    The net gains (losses) in market making and similar activities relate to the embedded derivatives in structured liabilities and are typically offset by (losses) gains on derivatives and securities that hedge these liabilities. For the cumulative impact of changes in the Corporation’s own credit spreads and the amount recognized in accumulated OCI, see Note 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.
(4)    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.
Gains (Losses) Related to Borrower-specific Credit Risk for Assets and Liabilities Accounted for Under the Fair Value Option
(Dollars in millions)202020192018
Loans reported as trading account assets$(172)$43 $
Consumer and commercial loans(19)15 (56)
Loans held-for-sale(105)57 (4)
Unfunded loan commitments(65)79 (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 customer and other receivables, customer payables (within accrued expenses and other liabilities on the Consolidated Balance Sheet), 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. Customer and other receivables primarily consist of margin loans, servicing advances and other accounts receivable and are classified as Level 2 or Level 3. Customer payables and short-termShort-term borrowings are classified as Level 2.
Held-to-maturity Debt Securities
HTM debt securities, which consist primarily of U.S. agency debt securities, are classified as Level 2 using the same methodologies as AFS U.S. agency debt securities. For more information on HTM debt securities, see Note 3 – Securities.
Loans
The fair values for commercial and consumer loans are generally determined by discounting both principal and interest cash flows expected to be collected using a discount rate for similar instruments with adjustments that the Corporation believes a market participant would consider in determining fair value. The Corporation estimates the cash flows expected to be collected using internal credit risk, interest rate and prepayment risk models that incorporate the Corporation’s best estimate of current key assumptions, such as default rates, loss severity and prepayment speeds for the life of the loan. The carrying value of loans is presented net of the applicable allowance for loan losses and excludes leases. The Corporation accounts for certain commercial loans and residential mortgage loans under the fair value option.
Deposits
The fair value for certain deposits with stated maturities is determined by discounting contractual cash flows using current market rates for instruments with similar maturities. The carrying value of non-U.S. time deposits approximates fair value. For
165 Bank of America


deposits with no stated maturities, the carrying value is considered to approximate fair value and does not take into account the significant value of the cost advantage and stability of the Corporation’s long-term relationships with depositors. The Corporation accounts for certain long-term fixed-rate deposits under the fair value option.
Long-term Debt
The Corporation uses quoted market prices, when available, to estimate fair value for its long-term debt. When quoted market prices are not available, fair value is estimated based on current market interest rates and credit spreads for debt with similar terms and maturities. The Corporation accounts for certain structured liabilities under the fair value option.
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, 20172020 and 20162019 are presented in the following table.
Fair Value of Financial Instruments
Fair Value
Carrying ValueLevel 2Level 3Total
(Dollars in millions)December 31, 2020
Financial assets
Loans$887,289 $49,372 $877,682 $927,054 
Loans held-for-sale9,243 7,864 1,379 9,243 
Financial liabilities
Deposits (1)
1,795,480 1,795,545 0 1,795,545 
Long-term debt262,934 271,315 1,164 272,479 
Commercial unfunded lending commitments (2)
1,977 99 5,159 5,258 
December 31, 2019
Financial assets
Loans$950,093 $63,633 $914,597 $978,230 
Loans held-for-sale9,158 8,439 719 9,158 
Financial liabilities
Deposits (1)
1,434,803 1,434,809 1,434,809 
Long-term debt240,856 247,376 1,149 248,525 
Commercial unfunded lending commitments (2)
903 90 4,777 4,867 
        
Fair Value of Financial Instruments
    
   Fair Value
 Carrying Value Level 2 Level 3 Total
(Dollars in millions)December 31, 2017
Financial assets       
Loans$904,399
 $68,586
 $849,576
 $918,162
Loans held-for-sale11,430
 10,521
 909
 11,430
Financial liabilities       
Deposits1,309,545
 1,309,398
 
 1,309,398
Long-term debt227,402
 235,126
 1,863
 236,989
        
 December 31, 2016
Financial assets       
Loans$873,209
 $71,793
 $815,329
 $887,122
Loans held-for-sale9,066
 8,082
 984
 9,066
Financial liabilities 
      
Deposits1,260,934
 1,261,086
 
 1,261,086
Long-term debt216,823
 220,071
 1,514
 221,585
Commercial Unfunded Lending Commitments
Fair values are generally determined using a discounted cash flow valuation approach which is applied using market-based CDS or internally developed benchmark credit curves. The Corporation accounts for certain loan commitments under the fair value option. The carrying values(1)    Includes demand deposits of $799.0 billion and fair values of the Corporation’s commercial unfunded lending commitments were $897 million and $4.0$545.5 billion with no stated maturities at December 31, 2017,2020 and $937 million and $4.9 billion at December 31, 2016. Substantially all commercial unfunded lending commitments are classified as Level 3.2019.
(2)    The carrying value of thesecommercial unfunded lending commitments is included in accrued expenses and other liabilities on the Consolidated Balance Sheet.
The Corporation does not estimate the fair valuesvalue 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.


Bank of America 2017184


NOTE 23Business Segment Information
The Corporation reports its results of operations through the following four4 business segments: Consumer Banking, GWIMBanking, GWIM, Global Banking and Global Markets, with the remaining operations recorded in All Other.
Consumer Banking
Consumer Banking offers a diversified range of credit, banking and investment products and services to consumers and small businesses. Consumer Banking product offerings include traditional savings accounts, money market savings accounts, CDs and IRAs, checking accounts, and investment accounts and products, as well as credit and debit cards, residential mortgages and home equity loans, and direct and indirect loans to consumers and small businesses in the U.S. ConsumerBanking includes the impact of servicing residential mortgages and home equity loans in the core portfolio.
Global Wealth & Investment Management
GWIM provides a high-touch client experience through a network of financial advisors focused on clients with over $250,000 in total investable assets, including tailored solutions to meet clients’ needs through a full set of investment management, brokerage, banking and retirement products. GWIM also provides comprehensive wealth management solutions targeted to high net worth and ultra high net worth clients, as well as customized solutions to meet clients’ wealth structuring, investment management, trust and banking needs, including specialty asset management services.
Global Banking
Global Banking provides a wide range of lending-related products and services, integrated working capital management and treasury solutions, and underwriting and advisory services through the Corporation’s network of offices and client relationship teams. Global Banking also provides investment banking products to clients. The economics of certain investment banking and underwriting activities are shared primarily between Global Banking andGlobal 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.
Global Markets
Global Markets offers sales and trading services includingand research services to institutional clients across fixed-income, credit, currency, commodity and equity businesses. Global Markets provides market-making, financing, securities clearing, settlement and custody services globally to institutional investor clients in support of their investing and trading activities. Global Markets product coverage includes securities and derivative products in both the primary and secondary markets. Global Markets also works with commercial and corporate clients to provide risk management products. As a result of market-making activities, Global Markets may be required to manage risk in a broad range of financial products. In addition, the economics of certain investment banking and underwriting activities are shared primarily between Global Markets and Global Banking under an internal revenue-sharing arrangement.
All Other
All Other consists of ALM activities, equity investments, non-core mortgage loans and servicing activities, the net impact of periodic revisions to the MSR valuation model for both core and non-core MSRs and the related economic hedge results and ineffectiveness,
liquidating businesses and residual expense allocations.certain expenses not otherwise allocated to business segments. ALM activities encompass certain residential mortgages, debt securities, interest rate and foreign currency risk management activities,activities. Substantially all of the impact of certain allocation methodologies and accounting hedge ineffectiveness. The results of certain ALM activities are allocated to the business segments. Equity investments include the merchant services joint venture as well as a portfolio of equity, real estate and other alternative investments. The initial impact of the Tax Act was recorded in All Other.
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
Bank of America 166


net interest income generated by certain of the Corporation’s ALM activities.
In addition, the business segments are impacted by the migration of customers and clients and their deposit, loan and brokerage balances between businesses. Subsequent to the date of migration, the associated net interest income, noninterest income and noninterest expense are recorded in the business to which the customers or clients migrated.
The Corporation’s ALM activities include an overall interest rate risk management strategy that incorporates the use of various derivatives and cash instruments to manage fluctuations in earnings and capital that are caused by interest rate volatility. The Corporation’s goal is to manage interest rate sensitivity so that movements in interest rates do not significantly adversely affect earnings and capital. The results of a majoritysubstantially all of the Corporation’s ALM activities are allocated to the business segments and fluctuate based on the performance of the ALM activities. ALM activities include external product pricing decisions including deposit pricing
strategies, the effects of the Corporation’s internal funds transfer pricing process and the net effects of other ALM activities.
Certain expenses not directly attributable to a specific business segment are allocated to the segments. The costs of certain centralized or shared functions are allocated based on methodologies that reflect utilization.
The tables below presentfollowing table presents net income (loss) and the components thereto (with net interest income on an FTE basis)basis for 2017, 2016 the business segments, All Other and 2015,the total Corporation) for 2020, 2019 and 2018, and total assets at December 31, 20172020 and 20162019 for each business segment, as well as All Other, including a reconciliationof the four business segments’ total revenue, net of interest expense, on an FTE basis, and net income to the Consolidated Statement of Income, and total assets to the Consolidated Balance Sheet.Other.

Results of Business Segments and All Other
At and for the year ended December 31
Total Corporation (1)
Consumer Banking
(Dollars in millions)202020192018202020192018
Net interest income$43,859 $49,486 $48,772 $24,698 $28,158 $27,025 
Noninterest income42,168 42,353 42,858 8,564 10,429 10,593 
Total revenue, net of interest expense86,027 91,839 91,630 33,262 38,587 37,618 
Provision for credit losses11,320 3,590 3,282 5,765 3,772 3,664 
Noninterest expense55,213 54,900 53,154 18,878 17,646 17,672 
Income before income taxes19,494 33,349 35,194 8,619 17,169 16,282 
Income tax expense1,600 5,919 7,047 2,112 4,207 4,150 
Net income$17,894 $27,430 $28,147 $6,507 $12,962 $12,132 
Period-end total assets$2,819,627 $2,434,079 $988,580 $804,093  
 Global Wealth & Investment ManagementGlobal Banking
 202020192018202020192018
Net interest income$5,468 $6,504 $6,265 $9,013 $10,675 $10,993 
Noninterest income13,116 13,034 13,188 9,974 9,808 9,008 
Total revenue, net of interest expense18,584 19,538 19,453 18,987 20,483 20,001 
Provision for credit losses357 82 86 4,897 414 
Noninterest expense14,154 13,825 14,015 9,337 9,011 8,745 
Income before income taxes4,073 5,631 5,352 4,753 11,058 11,248 
Income tax expense998 1,380 1,364 1,283 2,985 2,923 
Net income$3,075 $4,251 $3,988 $3,470 $8,073 $8,325 
Period-end total assets$369,736 $299,770  $580,561 $464,032  
 Global MarketsAll Other
 202020192018202020192018
Net interest income$4,646 $3,915 $3,857 $34 $234 $632 
Noninterest income14,120 11,699 12,326 (3,606)(2,617)(2,257)
Total revenue, net of interest expense18,766 15,614 16,183 (3,572)(2,383)(1,625)
Provision for credit losses251 (9)50 (669)(476)
Noninterest expense11,422 10,728 10,835 1,422 3,690 1,887 
Income (loss) before income taxes7,093 4,895 5,348 (5,044)(5,404)(3,036)
Income tax expense (benefit)1,844 1,395 1,390 (4,637)(4,048)(2,780)
Net income (loss)$5,249 $3,500 $3,958 $(407)$(1,356)$(256)
Period-end total assets$616,609 $641,809 $264,141 $224,375  
185Bank of America 2017
(1)There were no material intersegment revenues.



            
Results of Business Segments and All Other           
            
At and for the year ended December 31
Total Corporation (1)
 Consumer Banking
(Dollars in millions)2017 2016 2015 2017 2016 2015
Net interest income (FTE basis)$45,592
 $41,996
 $39,847
 $24,307
 $21,290
 $20,428
Noninterest income42,685
 42,605
 44,007
 10,214
 10,441
 11,091
Total revenue, net of interest expense (FTE basis)88,277
 84,601
 83,854
 34,521
 31,731
 31,519
Provision for credit losses3,396
 3,597
 3,161
 3,525
 2,715
 2,346
Noninterest expense54,743
 55,083
 57,617
 17,787
 17,654
 18,710
Income before income taxes (FTE basis)30,138
 25,921
 23,076
 13,209
 11,362
 10,463
Income tax expense (FTE basis)11,906
 8,099
 7,166
 5,002
 4,190
 3,814
Net income$18,232
 $17,822
 $15,910
 $8,207
 $7,172
 $6,649
Period-end total assets$2,281,234
 $2,188,067
  
 $749,325
 $702,333
  
            
 Global Wealth &
Investment Management
 Global Banking
 2017 2016 2015 2017 2016 2015
Net interest income (FTE basis)$6,173
 $5,759
 $5,527
 $10,504
 $9,471
 $9,244
Noninterest income12,417
 11,891
 12,507
 9,495
 8,974
 8,377
Total revenue, net of interest expense (FTE basis)18,590
 17,650
 18,034
 19,999
 18,445
 17,621
Provision for credit losses56
 68
 51
 212
 883
 686
Noninterest expense13,564
 13,175
 13,938
 8,596
 8,486
 8,482
Income before income taxes (FTE basis)4,970
 4,407
 4,045
 11,191
 9,076
 8,453
Income tax expense (FTE basis)1,882
 1,632
 1,475
 4,238
 3,347
 3,114
Net income$3,088
 $2,775
 $2,570
 $6,953
 $5,729
 $5,339
Period-end total assets$284,321
 $298,931
  
 $424,533
 $408,330
  
            
 Global Markets All Other
 2017 2016 2015 2017 2016 2015
Net interest income (FTE basis)$3,744
 $4,558
 $4,191
 $864
 $918
 $457
Noninterest income (loss)12,207
 11,532
 10,822
 (1,648) (233) 1,210
Total revenue, net of interest expense (FTE basis)15,951
 16,090
 15,013
 (784) 685
 1,667
Provision for credit losses164
 31
 99
 (561) (100) (21)
Noninterest expense10,731
 10,169
 11,374
 4,065
 5,599
 5,113
Income (loss) before income taxes (FTE basis)5,056
 5,890
 3,540
 (4,288) (4,814) (3,425)
Income tax expense (benefit) (FTE basis)1,763
 2,072
 1,117
 (979) (3,142) (2,354)
Net income (loss)$3,293
 $3,818
 $2,423
 $(3,309) $(1,672) $(1,071)
Period-end total assets$629,007
 $566,060
   $194,048
 $212,413
  
       
Business Segment Reconciliations      
  2017 2016 2015
Segments’ total revenue, net of interest expense (FTE basis) $89,061
 $83,916
 $82,187
Adjustments (2):
    
  
ALM activities 312
 (300) (208)
Liquidating businesses and other (1,096) 985
 1,875
FTE basis adjustment (925) (900) (889)
Consolidated revenue, net of interest expense $87,352
 $83,701
 $82,965
Segments’ total net income 21,541
 19,494
 16,981
Adjustments, net-of-taxes (2):
    
  
ALM activities (355) (651) (694)
Liquidating businesses and other (2,954) (1,021) (377)
Consolidated net income $18,232
 $17,822
 $15,910
       
    December 31
    2017 2016
Segments’ total assets   $2,087,186
 $1,975,654
Adjustments (2):
    
  
ALM activities, including securities portfolio   625,488
 612,996
Liquidating businesses and other (3)
   89,008
 118,073
Elimination of segment asset allocations to match liabilities   (520,448) (518,656)
Consolidated total assets   $2,281,234
 $2,188,067
(1)
There were no material intersegment revenues.
(2)
Adjustments include consolidated income, expense and asset amounts not specifically allocated to individual business segments.
(3)
At December 31, 2016, includes assets of the non-U.S. consumer credit card business which were included in assets of business held for sale on the Consolidated Balance Sheet.



167 Bank of America


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
Total CorporationConsumer BankingGlobal Wealth &
Investment Management
(Dollars in millions)202020192018202020192018202020192018
Fees and commissions:
Card income
Interchange fees$3,954 $3,834 $3,866 $3,027 $3,174 $3,196 $36 $59 $81 
Other card income1,702 1,963 1,958 1,646 1,910 1,907 42 42 46 
Total card income5,656 5,797 5,824 4,673 5,084 5,103 78 101 127 
Service charges
Deposit-related fees5,991 6,588 6,667 3,417 4,218 4,300 67 68 73 
Lending-related fees1,150 1,086 1,100 0 0 
Total service charges7,141 7,674 7,767 3,417 4,218 4,300 67 68 73 
Investment and brokerage services
Asset management fees10,708 10,241 10,189 146 144 147 10,578 10,130 10,042 
Brokerage fees3,866 3,661 3,971 127 149 172 1,692 1,740 1,917 
Total investment and brokerage services14,574 13,902 14,160 273 293 319 12,270 11,870 11,959 
Investment banking fees
Underwriting income4,698 2,998 2,722 0 391 401 335 
Syndication fees861 1,184 1,347 0 0 
Financial advisory services1,621 1,460 1,258 0 0 
Total investment banking fees7,180 5,642 5,327 0 391 401 337 
Total fees and commissions34,551 33,015 33,078 8,363 9,595 9,722 12,806 12,440 12,496 
Market making and similar activities8,355 9,034 9,008 2 63 113 112 
Other income (loss)(738)304 772 199 828 863 247 481 580 
Total noninterest income$42,168 $42,353 $42,858 $8,564 $10,429 $10,593 $13,116 $13,034 $13,188 
Global BankingGlobal Markets
All Other (1)
202020192018202020192018202020192018
Fees and commissions:
Card income
Interchange fees$499 $519 $503 $391 $81 $86 $1 $$
Other card income14 13 0 (1)(2)0 (1)(1)
Total card income513 532 511 391 80 84 1 (1)
Service charges
Deposit-related fees2,298 2,121 2,111 177 156 161 32 25 22 
Lending-related fees940 894 916 210 192 184 0 
Total service charges3,238 3,015 3,027 387 348 345 32 25 22 
Investment and brokerage services
Asset management fees0 0 (16)(33)
Brokerage fees74 34 94 1,973 1,738 1,780 0 
Total investment and brokerage services74 34 94 1,973 1,738 1,780 (16)(33)
Investment banking fees
Underwriting income2,070 1,227 1,090 2,449 1,555 1,495 (212)(185)(198)
Syndication fees482 574 648 379 610 698 0 
Financial advisory services1,458 1,336 1,153 163 123 103 0 
Total investment banking fees4,010 3,137 2,891 2,991 2,288 2,296 (212)(184)(197)
Total fees and commissions7,835 6,718 6,523 5,742 4,454 4,505 (195)(192)(168)
Market making and similar activities103 235 260 8,471 7,065 7,260 (284)1,615 1,368 
Other income (loss)2,036 2,855 2,225 (93)180 561 (3,127)(4,040)(3,457)
Total noninterest income$9,974 $9,808 $9,008 $14,120 $11,699 $12,326 $(3,606)$(2,617)$(2,257)
(1)All Other includes eliminations of intercompany transactions.

Bank of America 2017186168



Business Segment Reconciliations
(Dollars in millions)202020192018
Segments’ total revenue, net of interest expense$89,599 $94,222 $93,255 
Adjustments (1):
   
ALM activities375 241 (325)
Liquidating businesses, eliminations and other(3,947)(2,624)(1,300)
FTE basis adjustment(499)(595)(610)
Consolidated revenue, net of interest expense$85,528 $91,244 $91,020 
Segments’ total net income18,301 28,786 28,403 
Adjustments, net-of-tax (1):
  
ALM activities279 202 (222)
Liquidating businesses, eliminations and other(686)(1,558)(34)
Consolidated net income$17,894 $27,430 $28,147 
December 31
20202019
Segments’ total assets$2,555,486 $2,209,704 
Adjustments (1):
  
ALM activities, including securities portfolio1,176,071 721,806 
Elimination of segment asset allocations to match liabilities(977,685)(565,378)
Other65,755 67,947 
Consolidated total assets$2,819,627 $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. This financial information is presented in accordance with bank regulatory reporting requirements.
Condensed Statement of Income
(Dollars in millions)202020192018
Income   
Dividends from subsidiaries:   
Bank holding companies and related subsidiaries$10,352 $27,820 $28,575 
Nonbank companies and related subsidiaries0 91 
Interest from subsidiaries8,825 9,502 8,425 
Other income (loss)(138)74 (1,025)
Total income19,039 37,396 36,066 
Expense   
Interest on borrowed funds from related subsidiaries136 451 235 
Other interest expense4,119 5,899 6,425 
Noninterest expense1,651 1,641 1,600 
Total expense5,906 7,991 8,260 
Income before income taxes and equity in undistributed earnings of subsidiaries13,133 29,405 27,806 
Income tax expense (benefit)649 341 (281)
Income before equity in undistributed earnings of subsidiaries12,484 29,064 28,087 
Equity in undistributed earnings (losses) of subsidiaries:   
Bank holding companies and related subsidiaries5,372 (1,717)306 
Nonbank companies and related subsidiaries38 83 (246)
Total equity in undistributed earnings of subsidiaries5,410 (1,634)60 
Net income$17,894 $27,430 $28,147 
      
Condensed Statement of Income     
      
(Dollars in millions)2017 2016 2015
Income 
  
  
Dividends from subsidiaries: 
  
  
Bank holding companies and related subsidiaries$12,088
 $4,127
 $18,970
Nonbank companies and related subsidiaries202
 77
 53
Interest from subsidiaries7,043
 2,996
 2,004
Other income (loss)28
 111
 (623)
Total income19,361
 7,311
 20,404
Expense 
  
  
Interest on borrowed funds from related subsidiaries189
 969
 1,169
Other interest expense5,555
 5,096
 5,098
Noninterest expense1,672
 2,704
 4,631
Total expense7,416
 8,769
 10,898
Income (loss) before income taxes and equity in undistributed earnings of subsidiaries11,945
 (1,458) 9,506
Income tax expense (benefit)950
 (2,311) (3,532)
Income before equity in undistributed earnings of subsidiaries10,995
 853
 13,038
Equity in undistributed earnings (losses) of subsidiaries: 
  
  
Bank holding companies and related subsidiaries8,725
 16,817
 3,068
Nonbank companies and related subsidiaries(1,488) 152
 (196)
Total equity in undistributed earnings (losses) of subsidiaries7,237
 16,969
 2,872
Net income$18,232
 $17,822
 $15,910
    
Condensed Balance Sheet   
    
 December 31
(Dollars in millions)2017 2016
Assets 
  
Cash held at bank subsidiaries (1)
$4,747
 $20,248
Securities596
 909
Receivables from subsidiaries:   
Bank holding companies and related subsidiaries146,566
 117,072
Banks and related subsidiaries146
 171
Nonbank companies and related subsidiaries4,745
 26,500
Investments in subsidiaries:   
Bank holding companies and related subsidiaries296,506
 287,416
Nonbank companies and related subsidiaries5,225
 6,875
Other assets14,554
 11,038
Total assets (2)
$473,085
 $470,229
Liabilities and shareholders’ equity 
  
Accrued expenses and other liabilities$10,286
 $14,284
Payables to subsidiaries:   
Banks and related subsidiaries359
 352
Bank holding companies and related subsidiaries1
 4,013
Nonbank companies and related subsidiaries9,340
 12,010
Long-term debt185,953
 173,375
Total liabilities205,939
 204,034
Shareholders’ equity267,146
 266,195
Total liabilities and shareholders’ equity$473,085
 $470,229
(1)
Balance includes third-party cash held of $193 million and $342 million at December 31, 2017 and 2016.
(2)
During 2016, the Corporation entered into intercompany arrangements with certain key subsidiaries under which the Corporation transferred certain parent company assets to NB Holdings Corporation.

187169 Bank of America


Condensed Balance Sheet
 December 31
(Dollars in millions)20202019
Assets  
Cash held at bank subsidiaries (1)
$5,893 $5,695 
Securities701 656 
Receivables from subsidiaries:
Bank holding companies and related subsidiaries206,566 173,301 
Banks and related subsidiaries213 51 
Nonbank companies and related subsidiaries410 391 
Investments in subsidiaries:
Bank holding companies and related subsidiaries305,818 297,465 
Nonbank companies and related subsidiaries3,715 3,663 
Other assets9,850 9,438 
Total assets$533,166 $490,660 
Liabilities and shareholders’ equity  
Accrued expenses and other liabilities$15,965 $13,381 
Payables to subsidiaries:
Banks and related subsidiaries129 458 
Nonbank companies and related subsidiaries11,067 12,102 
Long-term debt233,081 199,909 
Total liabilities260,242 225,850 
Shareholders’ equity272,924 264,810 
Total liabilities and shareholders’ equity$533,166 $490,660 
(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)202020192018
Operating activities   
Net income$17,894 $27,430 $28,147 
Reconciliation of net income to net cash provided by (used in) operating activities:   
Equity in undistributed (earnings) losses of subsidiaries(5,410)1,634 (60)
Other operating activities, net14,303 16,973 (3,706)
Net cash provided by operating activities26,787 46,037 24,381 
Investing activities   
Net sales (purchases) of securities(4)(17)51 
Net payments to subsidiaries(33,111)(19,121)(2,262)
Other investing activities, net(7)48 
Net cash used in investing activities(33,122)(19,131)(2,163)
Financing activities   
Net increase (decrease) in other advances(422)(1,625)3,867 
Proceeds from issuance of long-term debt43,766 29,315 30,708 
Retirement of long-term debt(23,168)(21,039)(29,413)
Proceeds from issuance of preferred stock2,181 3,643 4,515 
Redemption of preferred stock(1,072)(2,568)(4,512)
Common stock repurchased(7,025)(28,144)(20,094)
Cash dividends paid(7,727)(5,934)(6,895)
Net cash provided by (used in) financing activities6,533 (26,352)(21,824)
Net increase in cash held at bank subsidiaries198 554 394 
Cash held at bank subsidiaries at January 15,695 5,141 4,747 
Cash held at bank subsidiaries at December 31$5,893 $5,695 $5,141 
Bank of America 2017170




      
Condensed Statement of Cash Flows     
      
(Dollars in millions)2017 2016 2015
Operating activities 
  
  
Net income$18,232
 $17,822
 $15,910
Reconciliation of net income to net cash provided by (used in) operating activities: 
  
  
Equity in undistributed (earnings) losses of subsidiaries(7,237) (16,969) (2,872)
Other operating activities, net(2,593) (2,860) (2,583)
Net cash provided by (used in) operating activities8,402
 (2,007) 10,455
Investing activities 
  
  
Net sales of securities312
 
 15
Net payments to subsidiaries(7,087) (65,481) (7,944)
Other investing activities, net(1) (308) 70
Net cash used in investing activities(6,776) (65,789) (7,859)
Financing activities 
  
  
Net decrease in short-term borrowings
 (136) (221)
Net decrease in other advances(6,672) (44) (770)
Proceeds from issuance of long-term debt37,704
 27,363
 26,492
Retirement of long-term debt(29,645) (30,804) (27,393)
Proceeds from issuance of preferred stock
 2,947
 2,964
Common stock repurchased(12,814) (5,112) (2,374)
Cash dividends paid(5,700) (4,194) (3,574)
Net cash used in financing activities(17,127) (9,980) (4,876)
Net decrease in cash held at bank subsidiaries(15,501) (77,776) (2,280)
Cash held at bank subsidiaries at January 120,248
 98,024
 100,304
Cash held at bank subsidiaries at December 31$4,747
 $20,248
 $98,024
NOTE 25 Performance by Geographical Area
Since theThe Corporation’s operations are highly integrated certain asset, liability, incomewith operations in both U.S. and expense amounts must be allocated to arrive at total assets, total revenue, net of interest expense, income before income taxesnon-U.S. markets. The non-U.S. business activities are largely conducted in Europe, the Middle East and net income by geographic area.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)  
Total Assets at Year End (1)
 
Total Revenue, Net of Interest Expense (2)
 Income Before Income Taxes Net Income(Dollars in millions) 
Total Assets at Year End (1)
Total Revenue, Net of Interest Expense (2)
Income Before Income TaxesNet Income
U.S. (3)
2017 $1,965,490
 $74,830
 $25,108
 $15,550
U.S. (3)
2020$2,490,247 $75,576 $18,247 $16,692 
2016 1,901,043
 72,418
 22,282
 16,183
20192,122,734 81,236 30,699 25,937 
2015  
 72,117
 20,181
 14,711
201880,777 31,904 26,407 
Asia2017 103,255
 3,405
 676
 464
Asia202099,283 4,232 1,051 788 
2016 85,410
 3,365
 674
 488
2019102,440 3,491 765 570 
2015  
 3,524
 726
 457
20183,507 865 520 
Europe, Middle East and Africa2017 189,661
 7,907
 2,990
 1,926
Europe, Middle East and Africa2020202,701 4,491 (596)264 
2016 174,934
 6,608
 1,705
 925
2019178,889 5,310 921 672 
2015   6,081
 938
 516
20185,632 1,543 1,126 
Latin America and the Caribbean2017 22,828
 1,210
 439
 292
Latin America and the Caribbean202027,396 1,229 293 150 
2016 26,680
 1,310
 360
 226
201930,016 1,207 369 251 
2015  
 1,243
 342
 226
20181,104 272 94 
Total Non-U.S. 2017 315,744
 12,522
 4,105
 2,682
Total Non-U.S. 2020329,380 9,952 748 1,202 
2016 287,024
 11,283
 2,739
 1,639
2019311,345 10,008 2,055 1,493 
2015  
 10,848
 2,006
 1,199
201810,243 2,680 1,740 
Total Consolidated2017 $2,281,234
 $87,352
 $29,213
 $18,232
Total Consolidated2020$2,819,627 $85,528 $18,995 $17,894 
2016 2,188,067
 83,701
 25,021
 17,822
20192,434,079 91,244 32,754 27,430 
2015  
 82,965
 22,187
 15,910
201891,020 34,584 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.

(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.
171Bank of America 2017188



Glossary
Alt-A Mortgage A type of U.S. mortgage that is considered riskier than A-paper, or “prime,” and less risky than “subprime,” the riskiest category. Typically, Alt-A mortgages are characterized by borrowers with less than full documentation, lower credit scores and higher LTVs.
Assets in Custody – Consist largely of custodial and non-discretionary trust assets excluding brokerage assets administered for clients.
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.
Client Brokerage and Other AssetsClientNon-discretionary client assets which are held in brokerage accounts.accounts or held for safekeeping.
Committed Credit Exposure– Any funded portion of a facility plus the unfunded portion of a facility on which the lender is legally bound to advance funds during a specified period under prescribed conditions.
Credit Derivatives – Contractual agreements that provide protection against a specified credit event on one or more referenced obligations.
Credit Valuation Adjustment (CVA) – A portfolio adjustment required to properly reflect the counterparty credit risk exposure as part of the fair value of derivative instruments.
Debit Valuation Adjustment (DVA)– A portfolio adjustment required to properly reflect the Corporation’s own credit risk exposure as part of the fair value of derivative instruments and/or structured liabilities.
Funding Valuation Adjustment (FVA)– A portfolio adjustment required to include funding costs on uncollateralized derivatives and derivatives where the Corporation is not permitted to use the collateral it receives.
Interest Rate Lock Commitment (IRLC)– Commitment with a loan applicant in which the loan terms are guaranteed for a designated period of time subject to credit approval.
Letter of Credit– A document issued on behalf of a customer to a third party promising to pay the third party upon presentation of specified documents. A letter of credit effectively substitutes the issuer’s credit for that of the customer.
Loan-to-value (LTV)– A commonly used credit quality metric. LTV is calculated as the outstanding carrying value of the loan divided by the estimated value of the property securing the loan.


Margin Receivable An extension of credit secured by eligible securities in certain brokerage accounts.
Matched Book – Repurchase and resale agreements or securities borrowed and loaned transactions where the overall asset and liability position is similar in size and/or maturity. Generally, these are entered into to accommodate customers where the Corporation earns the interest rate spread.
Mortgage Servicing Rights (MSR) – The right to service a mortgage loan when the underlying loan is sold or securitized. Servicing includes collections for principal, interest and escrow payments from borrowers and accounting for and remitting principal and interest payments to investors.
Net Interest Yield– Net interest income divided by average total interest-earning assets.
Nonperforming Loans and Leases– Includes loans and leases that have been placed on nonaccrual status, including nonaccruing loans whose contractual terms have been restructured in a manner that grants a concession to a borrower experiencing financial difficulties.
Operating Margin – Income before income taxes divided by total revenue, net of interest expense.
Prompt Corrective Action (PCA)– A framework established by the U.S. banking regulators requiring banks to maintain certain levels of regulatory capital ratios, comprised of five categories of capitalization: “well capitalized,” “adequately capitalized,” “undercapitalized,” “significantly undercapitalized” and “critically undercapitalized.” Insured depository institutions that fail to meet certain of these capital levels are subject to increasingly strict limits on their activities, including their ability to make capital distributions, pay management compensation, grow assets and take other actions.
Subprime Loans – Although a standard industry definition for subprime loans (including subprime mortgage loans) does not exist, the Corporation defines subprime loans as specific product offerings for higher risk borrowers.
Troubled Debt Restructurings (TDRs)– Loans whose contractual terms have been restructured in a manner that grants a concession to a borrower experiencing financial difficulties. Certain consumer loans for which a binding offer to restructure has been extended are also classified as TDRs.
Value-at-Risk (VaR)– VaR is a model that simulates the value of a portfolio under a range of hypothetical scenarios in order to generate a distribution of potential gains and losses. VaR represents the loss the portfolio is expected to experience with a given confidence level based on historical data. A VaR model is an effective tool in estimating ranges of potential gains and losses on our trading portfolios.




Bank of America 172


Key Metrics
Active Digital Banking Users Mobile and/or online users with activity at period end.
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.

Operating Margin – Income before income taxes divided by total revenue, net of interest expense.
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.
189173Bank of America 2017






Acronyms
ABSAsset-backed securities
AFSAvailable-for-sale
AIArtificial intelligence
ALMAsset and liability management
ARRAlternative reference rates
AUMAssets under management
AVMAutomated valuation model
ABSBANAAsset-backed securities
AFSAvailable-for-sale
ALMAsset and liability management
AUMAssets under management
AVMAutomated valuation model
BANABank of America, National Association
BHCBank holding company
bpsbasis points
CCARBofASBofA Securities, Inc.
BofASEBofA Securities Europe SA
bpsbasis points
CAEChief Audit Executive
CAOChief Administrative Officer
CCARComprehensive Capital Analysis and Review
CDOCollateralized debt obligation
CDSCredit default swap
CGACECLCorporate General AuditorCurrent expected credit losses
CLOCET1Common equity tier 1
CFPBConsumer Financial Protection Bureau
CFTCCommodity Futures Trading Commission
CLOCollateralized loan obligation
CLTVCombined loan-to-value
CVACROChief Risk Officer
CVACredit valuation adjustment
DIFDeposit Insurance Fund
DVADebit valuation adjustment
EADExposure at Default
EPSECLExpected credit losses
EMRCEnterprise Model Risk Committee
EPSEarnings per common share
ERCEnterprise Risk Committee
FASBESGFinancial Accounting Standards BoardEnvironmental, social and governance
FCAEUEuropean Union
FCAFinancial Conduct Authority
FDICFederal Deposit Insurance Corporation
FDICIAFederal Deposit Insurance Corporation Improvement Act of 1991
FHAFederal Housing Administration
FHLB
FHLBFederal Home Loan Bank
FHLMCFreddie Mac
FICCFixed-income,Fixed income, currencies and commodities
FICOFair Isaac Corporation (credit score)
FLUsFront line units
FNMAFannie Mae
FTEFully taxable-equivalent
FVAFunding valuation adjustment
GAAPAccounting principles generally accepted in the United States of America
GDPRGeneral Data Protection Regulation
GLSGlobal Liquidity Sources
GM&CAGlobal Marketing and Corporate Affairs
GNMAGovernment National Mortgage Association
GSEGovernment-sponsored enterprise
G-SIBGlobal systemically important bank
GSEGovernment-sponsored enterprise
GWIMGlobal Wealth & Investment Management
HELOCHome equity line of credit
HQLAHigh Quality Liquid Assets
HTMHeld-to-maturity
IBOR
Interbank Offered Rates
ICAAPInternal Capital Adequacy Assessment Process
IMMInternal models methodology
IRLCInterest rate lock commitment
IRMIndependent risk managementRisk Management
ISDAInternational Swaps and Derivatives Association, Inc.
LCRLiquidity Coverage Ratio
LGDLoss given default
LHFSLoans held-for-sale
LIBORLondon InterBankInterbank Offered Rate
LTVLoan-to-value
MBSMortgage-backed securities
MBSMortgage-backed securities
MD&AManagement’s Discussion and Analysis of Financial Condition and Results of Operations
MLGWMMerrill Lynch Global Wealth Management
MLIMerrill Lynch International
MLPCCMerrill Lynch Professional Clearing Corp
MLPF&SMerrill Lynch, Pierce, Fenner & Smith Incorporated
MRCManagement Risk Committee
MSAMetropolitan Statistical Area
MSRMortgage servicing right
NSFRNOLNet operating loss
NSFRNet Stable Funding Ratio
OASOption-adjusted spread
OCCOffice of the Comptroller of the Currency
OCIOther comprehensive income
OREOOther real estate owned
OTCOver-the-counter
OTTIOther-than-temporary impairment
PCAPrompt Corrective Action
PCIPurchased credit-impaired
PPIPayment protection insurance
RMBS
PPPPaycheck Protection Program
RMBSResidential mortgage-backed securities
RSURestricted stock unit
SBLCRWARisk -weighted assets
SBASmall Business Administration
SBLCStandby letter of credit
SEC
SCBStress capital buffer
SCCLSingle-counterparty credit limits
SECSecurities and Exchange Commission
SLRSupplementary leverage ratio
TDRSOFRSecured Overnight Financing Rate
SONIASterling Overnight Index Average
TDRTroubled debt restructurings
TLACTotal loss-absorbing capacity
TTFTime-to-required funding
VAU.S. Department of Veterans Affairs
VaRValue-at-Risk
VIEVariable interest entity


Bank of America 2017190174



Item 9. Changes in and Disagreements with Accountants on Accounting and Financial Disclosure
None
Item 9A. Controls and Procedures
Disclosure Controls and Procedures
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, in recording, processing, summarizing and reporting information required to be disclosed by the Corporation in reports that it files or submits under the Exchange Act, within the time periods specified in the Securities and Exchange Commission’s rules and forms.report.


Report of Management on Internal Control Over Financial Reporting
The Report of Management on Internal Control over Financial Reporting is set forth on page 9694 and incorporated herein by reference. The Report of Independent Registered Public Accounting Firm with respect to the Corporation’s internal control over financial reporting is set forth on page 97pages 95 and 96 and incorporated herein by reference.
Changes in Internal Control Over Financial Reporting
There have been no changes in our internal control over financial reporting (as defined in Rule 13a-15(f) of the Exchange Act) during the quarter ended December 31, 2017,2020, that materially affected, or are reasonably likely to materially affect, our internal control over financial reporting.
Item 9B. Other Information
None


191Bank of America 2017



Part III
Bank of America Corporation and Subsidiaries
Item 10. Directors, Executive Officers and Corporate Governance
Information about our Executive Officers of The Registrant
The name, age, position and office, and business experience during the last five years of our current executive officers are:
Dean C. Athanasia (51)(54)President, Retail and Preferred & Small Business Banking and since January 2019; Co-Head --- Consumer Banking sincefrom September 2014;2014 to January 2019; and Preferred and Small Business Banking Executive from April 2011 to September 2014.
Catherine P. Bessant (57)(60) Chief Operations and Technology Officer since July 2015; and Global Technology & Operations Executive from JanuaryMarch 2010 to July 2015.
Sheri Bronstein (52) Chief Human Resources Officer since January 2019; Global Human Resources Executive from July
2015 to January 2019; and HR Executive for Global Banking & Markets from March 2010 to July 2015.
Paul M. Donofrio (57)(60) Chief Financial Officer since August 2015; Strategic Finance Executive from April 2015 to August 2015; and Global Head of Global Corporate Credit and Transaction Banking from January 2012 to April 2015.
Geoffrey S. Greener (53)(56) Chief Risk Officersince April 2014; and Head of Enterprise Capital Management from April 2011 to April 2014.
Terrence P. Laughlin (63) Vice Chairman, Global Wealth & Investment Management Kathleen A. Knox (57) President, Private Bank since January 2016; Vice ChairmanNovember 2017; Head of Business Banking from July 2015 to January 2016; President of Strategic Initiatives from AprilOctober 2014 to July 2015;November 2017; and Chief Risk OfficerRetail Banking & Distribution Executive from AugustJune 2011 to AprilOctober 2014.
David G. Leitch (57)(60) Global General Counsel since January 2016; and General Counsel of Ford Motor Company from April 2005 to December 2015.
Thomas K. Montag (61)(64) Chief Operating Officersince September 2014; and Co-Chief Operating OfficerfromSeptember2011to September 2014.
Brian T. Moynihan (58)(61) Chairman of the Boardsince October 2014, and President, and Chief Executive Officer, and member of the Board of Directors since January 2010.
Thong M. Nguyen (59)President, Retail(62)Vice Chairman, Bank of America Corporation since January 2019; Co-Head -- Consumer Banking and Co-Head – Consumer Banking sincefrom September 2014;2014 to January 2019; Retail Banking Executive from April 2014 to September 2014; and Retail Strategy, and Operations & Digital Banking Executive from September 2012 to April 2014.
Andrew M. Sieg (53) President, Merrill Lynch Wealth Management since January 2017; and Head of Global Wealth & Retirement Solutions with Merrill Lynch from October 2011 to January 2017.
Andrea B. Smith (51)(54) Chief Administrative Officer since JulyAugust 2015; and Global Head of Human Resources from January 2010 to JulyAugust 2015.
Information included under the following captions in the Corporation’s proxy statement relating to its 20182021 annual meeting of stockholders scheduled to be held on April 25, 2018 (the 20182021 Proxy Statement), is incorporated herein by reference:
“Proposal 1: Electing Directors – Our Director Nominees;”
“Corporate Governance – Additional Information;”
“Corporate Governance – Board Meetings, Committee Membership and Attendance;” and
“Section 16(a) Beneficial Ownership Reporting Compliance.”
“Proposal 1: Electing directors – Our director nominees;”
“Corporate governance – Additional corporate governance information;”
“Corporate governance – Committees and membership;” and
“Corporate governance – Board meetings and attendance.”
Item 11. Executive Compensation
Information included under the following captions in the 20182021 Proxy Statement is incorporated herein by reference:
“Compensation Discussion and Analysis;”
“Compensation and Benefits Committee Report;”
“Executive Compensation;”
“Corporate Governance;” and
“Director Compensation.”

“Compensation discussion and analysis;”
“Compensation and Human Capital Committee report;”
“Executive compensation;”
“Corporate governance;” and
“Director compensation.”



175Bank of America 2017192



Item 12. Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters
Information included under the following caption in the 20182021 Proxy Statement is incorporated herein by reference:
“Stock Ownership of Directors, Executive Officers, and Certain Beneficial Owners.”
“Stock ownership of directors, executive officers, and certain beneficial owners.”
The table below presents information on equity compensation plans at December 31, 2017:2020:
Plan Category (1)
(a) Number of Shares to
be Issued Under
Outstanding Options, Warrants and Rights
(2)
(b) Weighted-average Exercise Price of Outstanding Options, Warrants and Rights (3)
(c) Number of Shares Remaining for Future Issuance Under Equity Compensation Plans (excluding securities reflected in column (a)) (4)
Plans approved by shareholders170,180,053 — 226,282,786 
Plans not approved by shareholders— — — 
Total170,180,053 — 226,282,786 
(1)This table does not include 692,622 vested restricted stock units and stock option gain deferrals at December 31, 2020 that were assumed by the Corporation in connection with prior acquisitions under whose plans the awards were originally granted.
(2)Consists of outstanding restricted stock units. Includes 2,314,352 vested restricted stock units subject to a required twelve-month holding period.
(3)Restricted stock units do not have an exercise price and are delivered without any payment or consideration.
(4)Amount represents shares of common stock available for future issuance under the Bank of America Corporation Key Employee Equity Plan.
      
Plan Category (1)
Number of Shares to
be Issued Under
Outstanding Options
and Rights
 
Weighted-average
Exercise Price of
Outstanding
Options (2)
 
Number of Shares Remaining for Future Issuance Under Equity Compensation Plans (3)
Plans approved by shareholders (4)
190,865,153
 $42.70
 288,515,217
Plans not approved by shareholders
 
 
Total190,865,153
 $42.70
 288,515,217
(1)
This table does not include outstanding options to purchase 5,610,830 shares of the Corporation’s common stock that were assumed by the Corporation in connection with prior acquisitions, under whose plans the options were originally granted. The weighted-average exercise price of these assumed options was $44.89 at December 31, 2017. Also, at December 31, 2017, there were 984,443 vested restricted stock units and stock option gain deferrals associated with these plans.
(2)
Does not reflect restricted stock units included in the first column, which do not have an exercise price.
(3)
Plans approved by shareholders include 288,394,387 shares of common stock available for future issuance under the Bank of America Corporation Key Employee Equity Plan and 120,830 shares of common stock which are available for future issuance under the Corporations Director Stock Plan.
(4)
Includes 179,887,809 outstanding restricted stock units.
Item 13. Certain Relationships and Related Transactions, and Director Independence
Information included under the following captions in the 20182021 Proxy Statement is incorporated herein by reference:
“Related Person and Certain Other Transactions;” and
“Corporate Governance – Director Independence.”

“Related person and certain other transactions;” and
“Corporate governance – Director independence.”
Item 14.Principal Accounting Fees and Services
Information included under the following caption in the 20182021 Proxy Statement is incorporated herein by reference:
    “Proposal 3: Ratifying the appointment of our independent registered public accounting firm for 2021.”

“Proposal 3: Ratifying the Appointment of our Independent Registered Public Accounting Firm for 2018.”


193Bank of America 2017176




Part IV
Bank of America Corporation and Subsidiaries
Item 15. Exhibits, Financial Statement Schedules
The following documents are filed as part of this report:
(1) Financial Statements:
Report of Independent Registered Public Accounting Firm
Consolidated Statement of Income for the years ended December 31, 2017, 20162020, 2019 and 20152018
Consolidated Statement of Comprehensive Income for the years ended December 31, 2017, 20162020, 2019 and 20152018
Consolidated Balance Sheet at December 31, 20172020 and 20162019
Consolidated Statement of Changes in Shareholders’ Equity for the years ended December 31, 2017, 20162020, 2019 and 20152018
Consolidated Statement of Cash Flows for the years ended December 31, 2017, 20162020, 2019 and 20152018
Notes to Consolidated Financial Statements
(2) Schedules:
None
(3) Index to Exhibits
With the exception of the information expressly incorporated herein by reference, the 20182021 Proxy Statement shall not be deemed filed as part of this Annual Report on Form 10-K.
Incorporated by Reference
Exhibit No.DescriptionNotesFormExhibitFiling DateFile No.
3.11
3.210-Q3(b)10/30/201-6523
4.1S-34.12/1/9533-57533
4.28-K4.311/18/981-6523
4.38-K4.46/14/011-6523
4.48-K4.28/27/041-6523
4.5S-34.65/5/06333-133852
4.68-K4.112/5/081-6523
4.710-K4(ee)2/25/111-6523
4.88-K4.11/13/171-6523
4.910-K4(a)2/23/171-6523
4.10S-34.26/28/96333-07229
4.1110-K4(aaa)2/28/071-6523
4.12S-34.125/1/15333-202354
4.13S-34.135/1/15333-202354
4.14S-34.145/1/15333-202354
4.158-K4.21/13/171-6523
4.168-K4.31/13/171-6523
4.17S-34.52/1/9533-57533
4.188-K4.811/18/981-6523
Incorporated by Reference
Exhibit No.DescriptionNotesFormExhibitFiling DateFile No.
3(a)10-Q3(a)5/2/161-6523
(b)8-K3.13/20/151-6523
4(a)S-34.12/1/9533-57533
8-K4.311/18/981-6523
8-K4.46/14/011-6523
8-K4.28/27/041-6523
S-34.65/5/06333-133852
8-K4.112/5/081-6523
10-K4(ee)2/25/111-6523
8-K4.11/13/171-6523
10-K4(a)2/23/171-6523
(b)S-34.26/28/96333-07229
(c)10-K4(aaa)2/28/071-6523
(d)S-34.125/1/15333-202354
(e)S-34.135/1/15333-202354
(f)S-34.145/1/15333-202354
(g)8-K4.21/13/171-6523
(h)8-K4.31/13/171-6523
(i)S-34.52/1/9533-57533
8-K4.811/18/981-6523
S-44.33/1/07333-141361
10-K4(ff)2/25/111-6523
10-K4(i)2/23/171-6523



Incorporated by Reference
Exhibit No.DescriptionNotesFormExhibitFiling DateFile No.
4.19S-44.33/16/07333-141361
4.2010-K4(ff)2/25/111-6523
4.2110-K4(i)2/23/171-6523
4.22

S-34.36/27/18333-224523
4.23S-34.46/27/18333-224523
4.24S-34.56/27/18333-224523
4.25S-34.66/27/18333-224523
4.26S-34.76/27/18333-224523
Registrant and its subsidiaries have other long-term debt agreements, but these are omitted pursuant to Item 601(b)(4)(iii) of Regulation S-K. Copies of these agreements will be furnished to the Commission on request
4.271
10.1210-K10(c)2/27/091-6523
10.2

210-K10(c)2/26/101-6523
10.3210-K10(a)2/28/131-6523
10.4210-K10.42/19/201-6523
10.5210-K10.52/19/201-6523
10.6

210-K10.62/19/201-6523
10.7

210-K10.72/19/201-6523
10.8NationsBank Corporation Benefit Security Trust dated as of June 27, 1990210-K10(t)3/27/911-6523
10.9First Supplement to NationsBank Corporation Benefit Security Trust dated as of
November 30, 1992
210-K10(v)3/24/931-6523
10.10210-K10(o)3/29/961-6523
10.11210-K10(c)2/25/151-6523
10.12210-K10(vv)2/24/161-6523
10.132S-84(c)11/19/19333-234780
10.14210-K10.142/19/201-6523
10.151,2
10.16210-K10(g)3/3/031-6523
10.17210-K10(d)2/28/131-6523
10.18210-K10(g)2/28/071-6523
10.19210-K10(f)2/26/191-6523
10.2028-K10.25/7/151-6523
10.21210-K10(mm)2/26/191-6523
10.2228-K10.14/24/191-6523
10.23210-Q10(a)5/2/161-6523
10.24210-Q10(c)5/2/161-6523
Bank of America 2017194178



Incorporated by Reference
Exhibit No.DescriptionNotesFormExhibitFiling DateFile No.
10.25

210-Q10(a)5/2/171-6523
10.26210-Q104/30/181-6523
10.27210-K10(h)2/26/191-6523
10.28

210-Q10(a)4/26/191-6523
10.29210-Q10(b)4/26/191-6523
10.30210-Q10.15/1/201-6523
10.31210-Q10.25/1/201-6523
10.32210-Q10(c)4/26/191-6523
10.33210-K10(v)3/1/041-6523
10.34210-K10(r)3/1/051-6523
10.35210-K10(u)3/1/051-6523
10.36210-K10(v)3/1/051-6523
10.37210-K10(p)2/26/101-6523
10.38210-K10(I)2/28/131-6523
10.39210-K10(c)2/25/111-6523
10.40210-K10(x)3/1/051-6523
10.41210-K10(y)3/1/051-6523
10.42210-K10(z)3/1/051-6523
10.43210-K10(aa)3/1/051-6523
10.44210-K10(cc)3/1/051-6523
10.45210-K10(hh)3/1/051-6523
10.46210-K10(ii)3/1/051-6523
10.47210-K10(jj)3/1/051-6523
10.48210-K10(ll)3/1/051-6523
10.49210-K10(oo)3/1/051-6523
10.502S-410(d)12/4/03333-110924
10.5128-K10.110/26/051-6523
10.5228-K10.210/26/051-6523
10.53210-K10(bbb)2/26/101-6523
10.548-K1.18/25/111-6523
10.55210-K10(rr)2/23/171-6523
10.56210-Q107/30/181-6523
10.57210-Q10(b)6/30/191-6523
21

1
221
231
   Incorporated by Reference
Exhibit No.DescriptionNotesFormExhibitFiling DateFile No.
 Registrant and its subsidiaries have other long-term debt agreements, but these are omitted pursuant to Item 601(b)(4)(iii) of Regulation S-K. Copies of these agreements will be furnished to the Commission on request     
10(a)

110-K10(c)2/27/091-6523
 110-K10(c)2/26/101-6523
 110-K10(c)2/25/111-6523
 110-K10(a)2/28/131-6523
(b)NationsBank Corporation Benefit Security Trust dated as of June 27, 1990110-K10(t)3/27/911-6523
 •First Supplement thereto dated as of November 30, 1992110-K10(v)3/24/931-6523
 110-K10(o)3/29/961-6523
(c)110-K10(c)2/25/151-6523
(d)110-K10(d)2/28/131-6523
(e)110-K10(g)2/28/071-6523
(f)18-K10.212/14/051-6523
 110-K10(h)3/1/051-6523
 110-Q10(a)8/4/111-6523
(g)18-K10.25/3/101-6523
 110-K10(i)2/28/081-6523
 110-K10(i)2/26/101-6523
 110-K10(i)2/25/111-6523
 110-Q10(a)5/5/131-6523
 110-Q10(a)5/1/141-6523
 18-K10.25/7/151-6523
 110-Q10(a)5/2/161-6523
 110-Q10(b)5/2/161-6523
 110-Q10(c)5/2/161-6523
 

110-Q10(a)5/2/171-6523
 

110-Q10(b)5/2/171-6523
(h)110-K10(v)3/1/041-6523
(i)110-K10(r)3/1/051-6523
(j)110-K10(u)3/1/051-6523
(k)110-K10(v)3/1/051-6523
(l)110-K10(p)2/26/101-6523
 110-K10(c)2/25/111-6523
 110-K10(l)2/28/131-6523
(m)110-K10(x)3/1/051-6523
(n)110-K10(y)3/1/051-6523
(o)110-K10(z)3/1/051-6523
(p)110-K10(aa)3/1/051-6523
(q)110-K10(cc)3/1/051-6523
(r)110-K10(hh)3/1/051-6523
(s)110-K10(ii)3/1/051-6523

195179Bank of America 2017




   Incorporated by Reference
Exhibit No.DescriptionNotesFormExhibitFiling DateFile No.
(t)110-K10(jj)3/1/051-6523
(u)110-K10(ll)3/1/051-6523
(v)110-K10(oo)3/1/051-6523
(w)1S-410(d)12/4/03333-110924
(x)18-K10.110/26/051-6523
(y)18-K10.210/26/051-6523
(z)110-K10(zz)2/26/101-6523
(aa)110-K10(aaa)2/26/101-6523
(bb)110-K10(bbb)2/26/101-6523
(cc) 8-A4.23/4/101-6523
(dd) 8-A4.23/4/101-6523
(ee)110-K10(jjj)2/25/111-6523
(ff) 8-K1.18/25/111-6523
(gg)110-Q107/29/151-6523
(hh)110-K10(vv)2/24/161-6523
(ii)110-K10(uu)2/24/161-6523
(jj)110-Q108/1/161-6523
(kk) 10-K10(rr)2/23/171-6523
(ll)110-Q107/31/171-6523
122    
 2    
182    
212    
232    
242    
31(a)2    
(b)2    
32(a)2    
(b)2    
101.INSXBRL Instance Document2    
101.SCHXBRL Taxonomy Extension Schema Document2    
101.CALXBRL Taxonomy Extension Calculation Linkbase Document2    
101.LABXBRL Taxonomy Extension Label Linkbase Document2    
101.PREXBRL Taxonomy Extension Presentation Linkbase Document2    
101.DEFXBRL Taxonomy Extension Definitions Linkbase Document2    
Incorporated by Reference
Exhibit No.DescriptionNotesFormExhibitFiling DateFile No.
241
31.11
31.21
32.11
32.21
101.INSInline XBRL Instance Document3
101.SCHInline XBRL Taxonomy Extension Schema Document1
101.CALInline XBRL Taxonomy Extension Calculation Linkbase Document1
101.LABInline XBRL Taxonomy Extension Label Linkbase Document1
101.PREInline XBRL Taxonomy Extension Presentation Linkbase Document1
101.DEFInline XBRL Taxonomy Extension Definitions Linkbase Document1
104Cover Page Interactive Data File (formatted as Inline XBRL and contained in Exhibit 101)
(1) Filed Herewith.
(2) Exhibit is a management contract or compensatory plan or arrangement.
(2) Filed Herewith.(3) The instance document does not appear in the interactive data file because its XBRL tags are embedded within the inline XBRL document.




Bank of America 2017196180





Item 16. Form 10-K Summary
Not applicable.
Signatures
Pursuant to the requirements of Section 13 of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.
Date: February 22, 2018
24, 2021
Bank of America Corporation
Bank of America Corporation
By: 
/s/ Brian T. Moynihan
Brian T. Moynihan
Chief Executive Officer
Pursuant to the requirements of the Securities Exchange Act of 1934, this report has been signed below by the following persons on behalf of the registrant and in the capacities and on the dates indicated.
SignatureTitleDate
/s/ Brian T. Moynihan
Chief Executive Officer, Chairman and Director
(Principal Executive Officer)
February 24, 2021
Brian T. Moynihan
*/s/ Paul M. DonofrioChief Financial Officer
(Principal Financial Officer)
February 24, 2021
Paul M. Donofrio
*/s/ Rudolf A. BlessChief Accounting Officer
(Principal Accounting Officer)
February 24, 2021
Rudolf A. Bless
*/s/ Sharon L. AllenDirectorFebruary 24, 2021
Sharon L. Allen
SignatureTitleDate
/s/ Brian T. Moynihan
Chief Executive Officer, Chairman and Director
(Principal Executive Officer)
February 22, 2018
Brian T. Moynihan
*/s/ Paul M. Donofrio
Chief Financial Officer
(Principal Financial Officer)
February 22, 2018
Paul M. Donofrio
*/s/ Rudolf A. Bless
Chief Accounting Officer
(Principal Accounting Officer)
February 22, 2018
Rudolf A. Bless
*/s/ Sharon L. AllenDirectorFebruary 22, 2018
Sharon L. Allen
*/s/ Susan S. BiesDirectorFebruary 22, 2018
Susan S. Bies
*/s/ Jack O. Bovender, Jr.DirectorFebruary 22, 2018
Jack O. Bovender, Jr.
*/s/ Frank P. Bramble, Sr.
DirectorFebruary 22, 2018
Frank P. Bramble, Sr.
*/s/ Pierre de WeckDirectorFebruary 22, 2018
Pierre de Weck
*/s/ Arnold W. DonaldDirectorFebruary 22, 2018
Arnold W. Donald
*/s/ Linda P. Hudson
DirectorFebruary 22, 2018
Linda P. Hudson
*/s/ Monica C. LozanoDirectorFebruary 22, 2018
Monica C. Lozano

24, 2021
Susan S. Bies
197Bank of America 2017



Signature*/s/ Jack O. Bovender, Jr.TitleDirectorDateFebruary 24, 2021
Jack O. Bovender, Jr.
*/s/ Thomas J. MayFrank P. Bramble, Sr.
DirectorFebruary 22, 201824, 2021
Thomas J. May
Frank P. Bramble, Sr.
*/s/ Lionel L. Nowell, IIIPierre de WeckDirectorFebruary 22, 201824, 2021
Lionel L. Nowell, IIIPierre de Weck
*/s/ Michael D. WhiteArnold W. DonaldDirectorFebruary 22, 201824, 2021
Michael D. WhiteArnold W. Donald
*/s/ Thomas D. WoodsLinda P. Hudson
DirectorFebruary 22, 201824, 2021
Thomas D. Woods
Linda P. Hudson
*/s/ R. David YostMonica C. LozanoDirectorFebruary 22, 201824, 2021
R. David YostMonica C. Lozano
*/s/ Maria T. Zuber
DirectorFebruary 22, 2018
Maria T. Zuber
*By/s/ Ross E. Jeffries, Jr.
Ross E. Jeffries, Jr.
Attorney-in-Fact


181 Bank of America


SignatureTitleDate
*/s/ Thomas J. MayDirectorFebruary 24, 2021
Thomas J. May
*/s/ Lionel L. Nowell, IIIDirectorFebruary 24, 2021
Lionel L. Nowell, III
*/s/ Denise L. RamosDirectorFebruary 24, 2021
Denise L. Ramos
*/s/ Clayton S. RoseDirectorFebruary 24, 2021
Clayton S. Rose
*/s/ Michael D. WhiteDirectorFebruary 24, 2021
Michael D. White
*/s/ Thomas D. WoodsDirectorFebruary 24, 2021
Thomas D. Woods
*/s/ R. David YostDirectorFebruary 24, 2021
R. David Yost
*/s/ Maria T. Zuber
DirectorFebruary 24, 2021
Maria T. Zuber
*By/s/ Ross E. Jeffries, Jr.
Ross E. Jeffries, Jr.
Attorney-in-Fact

Bank of America 2017198182