0000070858 bac:TemporarilyImpairedMember bac:OtherTaxableSecuritiesMember 2019-12-31 0000070858 us-gaap:FairValueMeasurementsRecurringMember us-gaap:ResidentialMortgageBackedSecuritiesMember 2019-12-31 0000070858 us-gaap:OperatingSegmentsMember bac:ServiceChargesLendingRelatedFeesMember bac:GlobalBankingSegmentMember 2017-01-01 2017-12-310000070858us-gaap:ResidentialMortgageMemberus-gaap:ResidentialPortfolioSegmentMember2019-01-012019-12-310000070858bac:TradingAccountLiabilitiesEquitySecuritiesMember2019-01-012019-12-31

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, 20192021

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 Carolina28255
Registrant’s telephone number, including area code:
(704) (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
Depositary Shares, each representing a 1/1,000th interest in a shareBAC PrENew York Stock Exchange
 of Floating Rate Non-Cumulative Preferred Stock, Series E
Depositary Shares, each representing a 1/1,000th interest in a shareBAC PrCPrBNew York Stock Exchange
of 6.200%6.000% Non-Cumulative Preferred Stock, Series CCGG
Depositary Shares, each representing a 1/1,000th interest in a shareBAC PrAPrKNew York Stock Exchange
of 6.000%5.875% Non-Cumulative Preferred Stock, Series EEHH
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



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 shareBAC PrBPrMNew York Stock Exchange
 of 6.000%5.375% Non-Cumulative Preferred Stock, Series GGKK
Depositary Shares, each representing a 1/1,000th interest in a shareBAC PrKPrNNew York Stock Exchange
of 5.875%5.000% Non-Cumulative Preferred Stock, Series HHLL
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

1Bank 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 shareBAC PrMPrONew York Stock Exchange
of 5.375%4.375% Non-Cumulative Preferred Stock, Series KKNN
Depositary Shares, each representing a 1/1,000th interest in a shareBAC PrNPrPNew York Stock Exchange
of 5.000%4.125% Non-Cumulative Preferred Stock, Series LLPP
Depositary Shares, each representing a 1/1,000th interest in a shareBAC PrQNew York Stock Exchange
of 4.250% Non-Cumulative Preferred Stock, Series QQ
Depositary Shares, each representing a 1/1,000th interest in a shareBAC PrSNew York Stock Exchange
of 4.750% Non-Cumulative Preferred Stock, Series SS

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 No No
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 No
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
Indicate by check mark whether the registrant has submitted electronically every Interactive Data File required to be submitted 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 such files).  Yes  No
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.
Large accelerated filerAccelerated filerNon-accelerated filerSmaller 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.
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  No 
As of June 30, 2019,2021, the aggregate market value of the registrant’s common stock (“Common Stock”) held by non-affiliates was approximately $270,935,450,750.$349,925,254,902. At February 18, 2020,2022, there were 8,728,530,3088,069,801,301 shares of Common Stock outstanding.
Documents incorporated by reference: Portions of the definitive proxy statement relating to the registrant’s 20202022 annual meeting of stockholdersshareholders are incorporated by reference in this Form 10-K in response to Items 10, 11, 12, 13 and 14 of Part III.


Bank of America 2





Table of Contents
Bank of America Corporation and Subsidiaries


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,” “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 the Corporation on our website. Accordingly, investorsInvestors should monitor the Investor Relations portion of our website, in addition to our press releases, U.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 Financial Information (accessible by clicking on the SEC Filings link) as soon as reasonably practicable after we electronically file such reports with, or furnish them to, the SEC and at the SEC’s website, www.sec.gov. Notwithstanding the foregoing, the information contained on our website as referenced in this paragraph, or otherwise in this Annual Report on Form 10-K, 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; (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. Our Code of Conduct constitutes a “code of ethics” and a “code of business conduct and ethics” that applies to the committee names underrequired individuals associated with the Committee Composition link).Corporation for purposes of the respective rules of the SEC and the New York Stock Exchange. We also intend to disclose any amendments to our Code of Conduct and waivers of our Code of Conduct required to be disclosed by the rules of 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, Bank of America Corporate Center, 100 North Tryon Street, NC1-007-56-06, Charlotte, North Carolina 28255.

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 3236 through 4146 of Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations (MD&A) and Note 2423 – Business Segment Information to the 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 specificproduct-specific basis.
Competition is based on a number of factors including, among others, customer service, quality and range of products and services offered, technology, price, fees, reputation, interest rates on loans and deposits, lending limits, customer convenience and customer convenience.experience and relationships in relevant markets. Our ability to continue to compete effectively also depends in large part on our ability to attract new employees and retain and 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 Compensation and Human Capital Committee 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, 2019, we had2021 and 2020, the Corporation employed approximately 208,000 employees. and 213,000 employees, of which 80 percent and 82 percent were located in the U.S., respectively. None of our domesticU.S. employees are subject to a collective bargaining agreement. Management considersAdditionally, in 2021 and 2020, the Corporation’s compensation and benefits expense was $36.1 billion and $32.7 billion, or 61 percent and 59 percent, of total noninterest expense.
Diversity and Inclusion
The Corporation’s commitment to diversity and inclusion starts at the top with oversight from our Board and CEO. The Corporation’s senior management sets the diversity and inclusion goals, 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 region, is chaired by our CEO and has
Bank of America 2


been in place for over 20 years. The Council sponsors and supports business, operating unit and regional diversity and inclusion councils to ensure alignment with 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 50 percent and 55 percent racially, ethnically and gender diverse. As of December 31, 2021, of global employees who self-identified, 50 percent of employees were women, and, among U.S.-based employees who self-identified, 49 percent were people of color, including 13 percent who were Asian, 14 percent who were Black/African American and 19 percent who were Hispanic/Latino. As of December 31, 2021, the Corporation’s top three management levels in relation to the CEO were composed of more than 42 percent women globally and 24 percent people of color in the U.S., including eight percent who were Asian, nine percent who were Black/African American and six percent who were Hispanic/Latino. Additionally, as of December 31, 2021, the Corporation’s managers at all levels were composed of 42 percent women globally and 41 percent people of color in the U.S., including 13 percent who were Asian, 10 percent who were Black/African American and 16 percent who were Hispanic/Latino. These workforce diversity metrics are reported regularly to the senior management team and to the Board.
We invest in our talent 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 enterprise-wide learning and conversations about various diversity and inclusion topics and 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 2021, 46 percent of our global campus hires were women, and, in the U.S., 53 percent were people of color.
Employee Engagement and Talent Retention
As part of our ongoing efforts to 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 2021, 89 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 88 percent. Our turnover among employees was 12 percent in 2021 and seven percent in 2020. Our pre-pandemic levels of turnover in 2019 and 2018 were 11 percent and 12 percent.
Additionally, the Corporation provides a variety of resources to help employees grow in their current roles and build new skills, including resources to help employees find new opportunities, re-skill and seek leadership positions. The learning and development strategy is grounded in the development of horizontal skills delivered throughout the organization. Senior leaders, managers and teammates are onboarded and build horizontal skills, as well as role-specific skills, to drive high performance. This approach also facilitates internal mobility and promotion of talent to build a bench of qualified managers and leaders. In 2021, more than 26,000 employees found new roles within the Corporation and we
delivered more than 10 million hours of training and development to our teammates through the Corporation’s training academy.
Fair and Equitable Compensation
The Corporation is committed to racial and gender pay equity by striving to compensate all of our employees fairly and equitably. We maintain robust policies and practices that reinforce our commitment, including reviews conducted by a third-party consultant with oversight from our Board and senior management. In 2021, 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. We regularly benchmark against other companies both within and outside our industry to help ensure our pay is competitive. In the fourth quarter of 2021, we raised our minimum hourly wage for U.S. employees to $21 per hour, which is above all governmental minimum wage levels in all jurisdictions in which we operate in the U.S., and announced plans to increase to $25 per hour by 2025.
Health and Wellness – 2021 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 2021, we continued efforts to support our employees through the ongoing health crisis resulting from the Coronavirus Disease 2019 (COVID-19) pandemic (the pandemic). We continued to monitor guidance from the U.S. Centers for Disease Control and Prevention, medical boards and health authorities and prioritized sharing such guidance with our teammates. Other benefits and resources related to the pandemic included offering no-cost COVID-19 testing, paid time off to allow teammates to get vaccinated for COVID-19, providing teammates with incentives for getting the vaccine and booster, hosting a medical expert education series and providing on-site COVID-19 vaccine and booster clinics.
We continued our efforts around providing affordable access to healthcare, including offering no-cost, 24/7 access to virtual general medical and behavioral health resources to help our enrolled U.S. teammates stay healthy, both physically and emotionally. We kept U.S. health insurance premiums unchanged for teammates earning less than $50,000 for the ninth year in a row, and had nominal premium increases for teammates earning from $50,000 to $100,000 for the fifth year in a row. We also provided preventative care medications at no cost for U.S. teammates enrolled in the Bank’s medical plan.
We have expanded our child and adult care solutions for eligible U.S. teammates to help better support their families and dependents, including providing up to 50 days of backup care for both adults and children and expanding access to our reimbursement program to help employees manage child care expenses. Additional support to working parents includes parental leave and time off from work to care for and bond with a newborn or adopted child (16 weeks paid plus 10 weeks unpaid for a total of up to 26 weeks).
3 Bank of America


For more information about our human capital management, see the Corporation’s website and 2021 Annual Report to shareholders that will be good.available on the Investor Relations portion of our website in March 2022 (the content of which is not incorporated by reference into this Annual Report on Form 10-K).
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.
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. The Corporation's status as a financial holding company is 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 the case of the depository institutions, at least satisfactory Community Reinvestment Act ratings. Failure to be an eligible financial holding company could result in the

Bank of America 2


Federal Reserve limiting Bank of America's activities, including potential acquisitions.
The scope of the laws and regulations and the intensity of the supervision to which we are subject have increased over the past several years, beginning 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 operations andentities, 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, Financial Industry Regulatory Authority and New York Stock Exchange, 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,, National Futures Association, and SEC,the 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 by the Prudential Regulatory Authority and Financial Conduct Authority, (FCA), the European Central Bank and Central Bank of 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 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.depositor, per insured bank for each account ownership category. 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 FDIC adopted regulations that establish a long-term target DIF ratio of greater than two percent. As of the date of this report, the DIF ratio is below this required target, and the FDIC has adopted a restoration plan that may result in increased deposit insurance assessments. 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 14.18.

Bank of America 4


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 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 also issued a final rule, which became effective January 1, 2019, that includes minimum external total loss-absorbing capacity (TLAC) and long-term debt requirements.
For more information on regulatory capital rules, capital composition and pending or proposed regulatory capital changes, see Capital Management – Regulatory Capital in the MD&A on page 46,49, and Note 1716 – 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, in the second half of 2020 the Federal Reserve introduced certain limitations to capital distributions for all large banks, including 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.which were removed effective July 1, 2021.
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

3Bank of America






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 1413 – Shareholders’ Equity and Note 1716 – Regulatory Requirements and Restrictions to 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 are 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 the 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 summary of our plan is available on the Federal Reserve and FDIC websites.
The FDIC also requires the submission of a resolution plan for Bank of America, 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 simplifyingwhich includes continued improvements to our legal entity structure and business operations, and increasing our preparedness capabilities to implement our resolution plan, both from a financial and operational standpoint.
Across international jurisdictions, resolution planning is the responsibility of national resolution authorities (RA). Among those, the jurisdictions of mostwith the greatest impact to the CorporationCorporation’s subsidiaries 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 locally-incorporatedlocally incorporated subsidiaries (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 be material for resolution planning purposes. As a result of the RA'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 7.10.
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.
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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 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 requires that BHCs maintain minimum levels of long-term debt required 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 7.10.
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, 2019,2021, 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, 2019,2021, 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

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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 European Union (EU) Markets in Financial Instruments Directive and Regulation, the European Market Infrastructure Regulation, analogous U.K. regulatory regimes and 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; enforcing existing or 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. Regulations of derivativesThese regulations are already in effect in many markets in which we 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. In addition, the EU has implemented EU-wide resolution stay requirements. Generally, 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 insolvency 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 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 the Equal Credit Opportunity Act, Home Mortgage Disclosure Act, Electronic Fund Transfer Act, Fair Credit Reporting Act, Real Estate Settlement Procedures Act, unfair, deceptive, or abusive acts or practices (UDAAP), 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 regarding 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 contact customers with marketing offers and establish certain rights of consumers in connection with their personal information. For example, California’s Consumer Privacy
Act (CCPA), which went into effect in January 2020, as modified by the California Privacy Rights Act (CPRA), provides consumers with the right to know what personal data is being collected, know whether their personal data is sold or disclosed and to whom and opt out of the sale of their personal data,
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among other rights. In addition, in the EU, the General Data Protection Regulation (GDPR) replaced the Data Protection Directive and related implementing national laws in its member states. The CCPA's, CPRA's and GDPR’s impact on the Corporation was assessed and addressed through comprehensive compliance implementation programs. These existing and evolving legal requirements in the U.S. and abroad, as well as court proceedings and changing 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 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 significantCorporation’s material risk factors of which we are currently aware, thataware. Any risk factor, either by itself or together with other risk factors, could materially and adversely affect our businesses, results of operations, andcash flows and/or financial condition. Additional factorsThe considerations and risks that could affect our businesses, results of operations and financial conditionfollow are discussed in Forward-looking Statements in the MD&A on page 22. However,organized within relevant headings but may be relevant to other headings as well. 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, andcash flows and/or 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 42.46. For more information about the risks contained in the Risk Factors section, see Item 1. Business on page 2, MD&A on page 26 and Notes to Consolidated Financial Statements on page 94.
Any risk factor described in this Annual Report on Form 10-K or in anySummary of our other SEC filings could by itself, or together with other factors, materiallyRisk Factors
Coronavirus Disease
    The impacts of the pandemic have adversely affected, and may continue to adversely affect our liquidity, competitive position, business, reputation, results of operations, capital position or financial condition, including by materially increasing our expenses or decreasing our revenues, which could result in material losses.us, and the pandemic’s duration and future impacts remain uncertain.
Market
Market
Our business and results of operations may be adversely affected by the U.S. and international financial markets, U.S. and non-U.S. fiscal, monetary, and regulatory policies, and economic conditions generally.
General economic, political and social conditions in the U.S. and in one or more countries abroad affect 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 gross domestic product (GDP), economic growth or its sustainability, inflation, consumer spending, employment levels, wage stagnation, federal government shutdowns, 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. Additionally, global markets may be adversely affected by 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 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 revenue and adversely

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affect our results of operations and financial condition, including capital and liquidity levels.
In the U.S. and abroad, uncertainties surrounding fiscal and monetary policies present economic challenges. Actions taken by the Federal Reserve, including changes in its target funds rate and balance sheet management, and other central banks are beyond our control and difficult to predict and can affect interest rates and the value of financial instruments and other assets and liabilities, and impact our borrowers. A continued protracted period of lower interest rates, or a move to negative interest rates in the U.S., could result in lower revenue, and maintain or increase pressure on net-interest income, which may adversely affect our results of operations. Uncertainty or ongoing developments in connection with the future relationship between the U.K. and 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 beyond.
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 U.S. or global economic activity and our customers', counterparties' and the Corporation's earnings and operations. For example, significant fiscal policy initiatives may 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 policies, particularly with important trading partners, including China and the EU, have negatively impacted and may continue to negatively impact financial markets, disrupt world trade and 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, our level of charge-offs and provision for credit losses, the carrying value of our deferred tax assets, our capital levels, liquidity and our results of operations. Additionally, events and ongoing uncertainty related to the U.K.'s exit from the EU and the uncertainty related to the transition from Interbank Offered Rates (IBORs) and other benchmark rates to alternative reference rates (ARRs) could negatively impact markets in the U.S. and abroad and our business and/or magnify any negative impact of the above referenced developments on our business, customers and 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, (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 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. In addition, the low interest rate environment and a flat or inverted yield curve could negatively impact our financial condition or results of operations, including 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 17. 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 assumptions or algorithms 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 71.
We may incur losses if the value of certain assets declines,asset values decline, including due to changes in interest rates and prepayment speeds.
We have a large portfolio of financial instruments, including 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 and marketable equity securities, other debt securities, equity method investments and certain other assets and liabilities that we measure at fair value and other accounting values, subject to impairment assessments. We determine these values 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. Increases 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, may adversely affect accumulated other comprehensive income and, thus, capital levels.
Fair values may be impacted by declining values of the underlying assets or the prices at which observable market transactions occur and the continued availability of these 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.

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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, which requires us to maintain additional capital and increases our funding costs. Asset values also directly impact revenues in our wealth management and related advisory businesses. We receive 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. Declines in asset values can reduce the value of our clients’ portfolios or fund assets, which in turn can result in lower fees earned for managing such assets.
For more information on fair value measurements, see Note 21 – Fair Value Measurements to the Consolidated Financial Statements. For more information on our asset management businesses, see GWIM in the MD&A on page 35. For more information on interest rate risk management, see Interest Rate Risk Management for the Banking Book in the MD&A on page 74.
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, illiquidity or volatility in the capital 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, prolonged federal government shutdowns, or changes in regulations, guidance or GSE status that impact our funding avenues or ability to access certain funding sources. Additionally, the unwillingness or inability of the Federal Reserve to act as lender of last resort, unexpected simultaneous draws on lines of credit, restricted access to the assets of prime brokerage clients, the withdrawal of customer deposits, which could result from customer attrition for higher yields or the desire for more conservative alternatives, increased regulatory liquidity, capital and margin requirements for our U.S. or international banks and their nonbank subsidiaries, changes in patterns of intraday liquidity usage resulting from a counterparty or technology failure or other idiosyncratic event, failure by a significant market participant or third party, such as a clearing agent or custodian, reputational issues, or negative perceptions about our short- or long-term business prospects, including downgrades of our credit ratings may adversely affect our liquidity.
Several of these factors may arise due to circumstances beyond our control, such as general market volatility, disruption, shock or stress, Federal Reserve policy decisions, including fluctuations in interest rates or Federal Reserve balance sheet composition, negative views about the Corporation or financial services industry generally or due to a specific news event, changes in the regulatory environment or governmental fiscal or monetary policies, 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, unforeseen outflows of cash, 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 and the need for additional funding for commitments and contingencies, as well as unexpected collateral calls, among other things, the result of which could be a liquidity shortfall and/or impact on our liquidity coverage ratio.
Our cost of obtaining funding is directly related to prevailing market conditions, including changes in interest and currency exchange rates, and to 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 and result in mark-to-market or credit valuation adjustment exposures. Changes    Reduction 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 Risk in the MD&A on page 50.
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 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 as factors not under our control such as the current economic and geopolitical environment, and to a lesser extent, the likelihood of the U.S. government providing meaningful support to us or our subsidiaries in a crisis.
Rating agencies could make adjustments to our credit ratings at any time, and there can be no assurance as to when and whether downgrades will 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 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, 2019, 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 3 – 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 3 – 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 to other subsidiaries, which could adversely affect our cash flow and financial condition.subsidiaries.
Bank of America Corporation, as the parent company, is a separate and distinct legal entity from our banking 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, which could result in adverse liquidity events. The parent company depends on dividends, distributions, loans, advances and other payments from our banking 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 parent 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 14 – Shareholders’ Equity    to the Consolidated Financial Statements.
In the event of a resolution, whether in a bankruptcy proceeding or under the orderly liquidation authority of the FDIC, such resolution could materially adversely affect ourOur liquidity and financial condition, and the ability to pay dividends to shareholders and to pay obligations.
Bank of America Corporation, our parent holding company, is required to periodically submit a plan to the FDIC and Federal Reserve describing its resolution strategy under the U.S. Bankruptcy Codeobligations could be materially adversely affected in the event of material financial distress or failure. In the current plan, Bank of America Corporation’s preferred resolution strategy is a “single point of entry” 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 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 pay dividends to shareholders and meet our payment obligations.resolution.
If 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, we could 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.Credit
Additionally, 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 point of entry” 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.
For more information about resolution planning, see Item 1. Business – Resolution Planning on page 4. For more information about the FDIC’s orderly liquidation, see Item 1. Business – Insolvency and the Orderly Liquidation Authority on page 4.


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Credit
Economic or market disruptions and insufficient credit loss reserves ormay result in a higher provision for credit losses.
    Our concentrations of credit risk may result in an increase in the provision for credit losses, which could have an adverse effect on our financial condition and results of operations.
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. A deterioration in the financial condition of our consumer and commercial borrowers, counterparties or underlying collateral could adversely affect our financial condition andcredit losses, results of operations.
Global and U.S. economic conditions and macroeconomic or market events and disruptions, including a continuing slowdown in global GDP growth, a decline in consumer spending, a decline in property values or an asset price correction, increasing consumer and corporate leverage, as well as rising unemployment, fluctuations in foreign exchange or interest rates, widespread health emergencies or pandemics and/or natural disasters, may impact our credit portfolios. In addition, significant economic or market stresses and disruptions could have a negative impact on the business environmentoperations and financial markets, increasing the risk that borrowers or counterparties would default or become delinquent in their obligations to us, which could lead to recessionary conditions and/or increase our credit losses and provision for credit losses, which could have a negative impact on our results of operations.condition.
In particular, increases in delinquencies and default rates could adversely affect our consumer credit card, home equity and residential mortgage portfolios through increased charge-offs and provision for credit losses. A deteriorating economic environment in the U.S. or globally could also adversely affect our consumer and commercial loan portfolios with weakened client and collateral positions. Simultaneous drawdowns on lines of credit and/or an increase in a borrower’s leverage in a weakening economic environment could result in deterioration in our credit portfolio, should borrowers be unable to fulfill competing financial obligations. The impact of this could also be magnified by lending to leveraged borrowers, elevated asset prices and/or declining property or collateral values unrelated to macroeconomic stress.
We estimate and establish an allowance for credit losses for losses inherent in our lending activities (including unfunded lending commitments), excluding those measured at fair value, through a charge to earnings. The process for determining the amount of the allowance requires us to make difficult and complex judgments, including forecasting how borrowers will react to changing economic conditions. 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 estimates. There is also the possibility that we will fail to accurately identify the appropriate economic indicators or that we will fail to accurately estimate their impacts to our borrowers and the reserves that we hold.
We may suffer unexpected lossesbe adversely affected if the models and assumptions we use to establish reserves and make judgments in extending credit to our borrowers or counterparties prove inaccurate in predicting future events. In addition, external factors, such as the macroeconomic or market events disclosed above can also negatively impact our recognition of credit losses in our portfolios and impact our allowance for credit losses. As of January 1, 2020, we implemented a new accounting standard to estimate our allowance for credit losses. For more information, see Note 1 – Summary of Significant Accounting Principles to the Consolidated Financial Statements. Although we believe that the allowance for credit losses is in compliance with the new accounting standard
at January 1, 2020, there is no guarantee that it will be sufficient to address credit losses, particularly if economic conditions deteriorate quickly and/or significantly. In such an event, we may increase the size of our allowance which would reduce our earnings.
In the ordinary course of our business, we also may be subject to concentrations of credit risk because of a common characteristic or common sensitivity to economic, financial or business developments. For example, concentrations in credit risk may result in a particular industry, geographic location, product, asset class, counterparty, individual exposure or 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 it is possible our limits and credit monitoring exposure controls will not function as 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 resulted 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, or even 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, 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 or monetary policies could impact the operating budgets or credit ratings of these government entities and expose us to credit risk.
We also 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. Additionally, decreases in home price valuations or commercial real estate valuations in certain markets where we have large concentrations, including as a result of climate change or natural disasters (e.g., rising sea levels, hurricanes and fires), as well as more broadly within the U.S. or globally, could result in increased defaults, delinquencies or credit loss. 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 asset managers and funds, real estate, capital goods and finance companies. For more information, see Commercial Portfolio Credit Risk Management in

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the MD&A on page 60. 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 down the value of certain assets.
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.
For more information on our credit risk and credit risk management policies and procedures, see Credit Risk Management in the MD&A on page 53, Note 1 – Summary of Significant Accounting Principles,Note 5 – Outstanding Loans and Leases and Note 6 – Allowance for Credit Losses to the Consolidated Financial Statements.
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 generally increase in 2019, the rate of increase has slowed compared to recent periods. We remain conscious of geographic markets where housing price growth has slowed or decreased and other geographic markets where housing prices have declined, 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, both of which may be adversely affected by rising interest rates. Conditions in the U.S. housing market during the most recent 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 representations and warranties exposures, which could have an adverse effect on 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 that 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. Certain OTC derivative contracts and other trading agreements provide that upon the occurrence of certain specified events, such as a change in the credit rating of a particular Bank of America entity or entities, we may be required to provide additional collateral or take other 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.
We are also a member of various central counterparties (CCPs) in part due to regulatory requirements for mandatory clearing of derivative transactions, 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 required to post, which could mean unexpected and increased exposure to the CCP. As a clearing member, we are exposed to the risk of non-performance by our clients for which we clear transactions, which may not be covered by available collateral. Additionally, any default by a significant market participant may result in further risk and potential losses.
For more information on our derivatives exposure, see Note 3 – Derivatives to the Consolidated Financial Statements.
Geopolitical
We are subject to numerous political, economic, market, reputational, operational, compliance, legal, regulatory and other risks in the 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, unfavorable political and diplomatic developments, oil price fluctuations and changes in legislation. 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 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. These risks are especially elevated in emerging markets.
A number of non-U.S. jurisdictions in which we do business have been or may be negatively impacted by slowing growth or recessionary conditions, market volatility and/or political unrest. In Europe, the political and economic environment remains challenging due to slowing GDP growth, debt concerns of certain EU countries and elevated recessionary risks, including in Germany and the U.K. The current degree of European political and economic uncertainty could increase and create additional market volatility and negatively impact our business and results of operations. Significant market volatility and geopolitical unrest could also result from ongoing uncertainty related to the U.K.'s exit from the EU and the transition period during which the terms of such exit will be negotiated, which could adversely affect us.
Potential risks of default on or devaluation of sovereign debt in some non-U.S. jurisdictions could expose us to substantial losses. 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 adverse impact on the Corporation.
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

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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 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 result in increased expenses and changes to our organizational structure and have an adverse effect on our businesses and results of operations in that market, as well as our reputation in general.
In addition to non-U.S. legislation, our international operations are also subject to U.S. legal requirements. For example, our operations are subject to U.S. and non-U.S. laws and regulations relating to bribery and corruption, anti-money laundering, and economic sanctions, which can vary by jurisdiction. The increasing speed and novel ways in which funds circulate could make it more challenging to track the movement of funds and heightens financial crimes risk. Our ability to comply with these legal requirements depends on our ability to continually improve detection and reporting and analytic 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 fiscal, monetary or regulatory policy 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 acts or threats of terrorism, actions taken by the U.S. or other governments in response thereto, state-sponsored cyber attacks or campaigns and/or military conflicts, which could adversely affect business and economic conditions abroad, as well as 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 66.
The U.K. Referendum, and the planned exit of the U.K. from the EU, could adversely affect us.
We conduct business in Europe, the Middle East and Africa primarily through our subsidiaries in the U.K. France and Ireland. For the year ended December 31, 2019, our operations in Europe, the Middle East and Africa, including the U.K., represented approximately six percent of our total revenue, net of interest expense.
On January 31, 2020, the U.K. formally exited the EU. Upon exit, a transition period began during which time the U.K. and the EU expect to negotiate a trade agreement and other terms associated with their future relationship. The transition period is scheduled to end on December 31, 2020. The ultimate impact and terms of such negotiation and any trade or other agreements remain unclear, and short- and long-term global economic and market volatility and disruptions to regional and global financial markets may occur, including as a result of currency fluctuations and trade relations. There can be no guarantee that the U.K. and EU will reach an agreement on trade or any other matters during the transition period or that the transition period will be extended if agreements are not reached. Additionally, there may be
heightened geopolitical uncertainty and/or market volatility if a trade and other agreements are not reached by the end of the transition period, including with regard to cross-border conduct of financial services and the treatment of existing financial transactions and contracts. If uncertainty resulting from the U.K.’s exit or the end to the transition period negatively impacts economic conditions, financial markets, including currency markets and consumer confidence, or clients, counterparties, and financial markets are not prepared for the trade and other agreements that are ultimately agreed upon or the transition period ends without a trade or other agreements, our business, results of operations, financial position and/or operational model could be adversely affected.
We are also subject to different laws, regulations and regulatory authorities and may incur additional costs and/or experience negative tax consequences as a result of establishing 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. Additionally, changes to the legal and regulatory framework under which our subsidiaries will continue to provide products and services in the U.K. and in the EU following the transition period may result in additional compliance costs and have negative tax consequences or an adverse impact on our results of operations. For more information on our EU operations outside of the U.K., see Executive Summary – Recent Developments – U.K. Exit from the EU in the MD&A on page 23.
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 critical business operations and customer services, result in additional risk exposures, and adversely impact our results of operations and financial condition, and cause legal or reputational harm.
    A cyberattack, 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, result in the disclosure and/or misuse of information and/or fraudulent activity, and increase our operational and security systems and critical infrastructure costs.
    Failure to satisfy our obligations as servicer for residential mortgage securitizations, loans owned by other entities and other losses we could incur as servicer, could adversely impact our reputation, servicing costs or results of operations.
    Changes in the structure of and relationship among the government-sponsored enterprises (GSEs) could adversely impact our business.
    Our risk management framework may not be effective in mitigating risk and reducing the potential for losses.
Regulatory, Compliance and Legal
    We are subject to comprehensive government legislation and regulations and certain settlements, orders and agreements with government authorities from time to time.
    We are subject to significant financial and reputational risks from potential liability arising from lawsuits and regulatory and government action.
    U.S. federal banking agencies may require us to increase our regulatory capital, total loss-absorbing capacity (TLAC), long-term debt or liquidity requirements.
    Changes in accounting standards or assumptions in applying accounting policies could adversely affect us.
    We may be adversely affected by changes in U.S. and non-U.S. tax laws and regulations.
Reputation
    Damage to our reputation could harm our businesses, including our competitive position and business prospects.
Other
    Reforms to and replacement of Interbank Offered Rates (IBORs) and certain other rates or indices may adversely affect our reputation, business, financial condition and results of operations.
    We face significant and increasing competition in the financial services industry.
    Our inability to adapt our business strategies, products and services could harm our business.
    We could suffer operational, reputational and financial harm if our models and strategies fail to properly anticipate and
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manage risk.
    Failure to properly manage 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, inaccurate reporting and non-compliance with laws, rules and regulations.
    Our operations, businesses and customers could be materially adversely affected by the impacts related to climate change.
    Our ability to attract and retain qualified employees is critical to our success, business prospects and competitive position.
The above summary is qualified in its entirety to the more detailed discussion of the Corporation’s material risk factors set forth below.
Coronavirus Disease
The impacts of the pandemic have adversely affected, and may continue to adversely affect us, and the pandemic’s duration and future impacts remain uncertain.
Since the onset of the pandemic, the negative economic conditions and disruptions arising from it have adversely impacted our financial results to varying degrees and in various respects, including as a result of periods of increased allowance for credit losses followed by subsequent declines, and continued elevated noninterest expense. The pandemic’s impact on economic conditions and activity remains uncertain and will continue to evolve by region, country and state, and it is possible that new or evolving variants of COVID-19 could result in increased business disruptions and contribute to a potential economic downturn. In recent months, the U.S. and other regions of the world have experienced supply chain disruptions and labor shortages, and the global economy and supply chains remain vulnerable. Pandemic developments and certain responses have also resulted in inflationary pressure and ultimately may contribute to the development of a prolonged, disruptive period of high inflation in the U.S. and globally.
The economic impact of the pandemic may continue to adversely affect certain of our businesses and our results of operations, including decreased demand for and use of our products and services; 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 a deterioration in the financial condition of our consumer and commercial borrowers, which could result in their inability to fulfill contractual obligations, may vary by region, sector or industry and could be exacerbated by the expiration of government assistance. Additionally, our liquidity and/or regulatory capital could be adversely impacted by customers’ withdrawal of deposits, inability to repay loans and reduced usage of banking products, volatility and disruptions in the capital and credit markets, changes in the value of securities, derivatives and other financial instruments resulting in increased margin requirements, volatility in foreign exchange rates and customer draws on lines of credit. Adverse macroeconomic conditions could also result in potential downgrades to our credit ratings, negative impacts to regulatory capital and liquidity and reinstated restrictions on dividends and/or common stock repurchases.
We continue to execute business continuity plans in connection with the pandemic. 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, our business continuity plans could be adversely affected and result in disruption to our businesses. Additionally, we continue to rely on third parties who could experience business interruptions as a result of the pandemic, which could increase our risks and adversely impact our businesses.
In connection with the pandemic, various governmental fiscal and monetary relief programs were implemented in an effort to stimulate the global economy and 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, orders, settlements, penalties, and fines. Our participation in such programs has also resulted and will continue to result in losses, including from the Paycheck Protection Program (PPP) and the processing of unemployment benefits for California and certain other states.
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 global health, the global economy and our businesses, results of operations and financial condition are uncertain and depend on future developments that cannot be predicted, including the likelihood of future surges of COVID-19 cases and the spread of more easily communicable and/or dangerous variants of COVID-19, the availability, usage and acceptance of effective medical treatments and vaccines (including additional doses of vaccines) in the U.S. and globally and future public response and government actions, including travel bans and restrictions, limitations on business activity, vaccine mandates and additional stimulus legislation. The pandemic may cause setbacks to the global or national economic recovery or longer lasting effects on economic conditions than are currently anticipated, changes in financial markets, changes in fiscal, monetary and tax regulatory environments, and changes in client preferences and behavior, which could have a material adverse effect on our businesses, results of operations and financial condition.
Market
Our business and results of operations may be adversely affected by the financial markets, fiscal, monetary, and regulatory policies, and economic conditions generally.
General economic, political, social and health conditions in the U.S. and in one or more countries abroad affect 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 gross domestic product (GDP), economic growth or its sustainability, inflation, supply chain disruptions, consumer spending, employment levels, labor shortages, wage stagnation, federal government shutdowns, developments related to the U.S. federal debt ceiling, energy prices, home prices, commercial property values, bankruptcies, a default by a significant market participant or class of counterparties, 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
Bank of America 8


investor sentiment and confidence. Additionally, global markets, including energy and commodity markets, may be adversely affected by the current or anticipated impact of climate change, extreme weather events or natural disasters, the emergence or continuation of widespread health emergencies or pandemics, cyberattacks or campaigns, military conflict, including escalating military tension between Russia and Ukraine, terrorism or other geopolitical events. Market fluctuations may impact our margin requirements and affect our business 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 noninterest income and adversely affect our results of operations and financial condition, including capital and liquidity levels. For example, global developments in connection with the ongoing pandemic, including supply chain disruptions, high inflation, changes to industries such as commercial real estate, the emergence of new variants and significant restrictions on households and businesses in certain countries, have adversely impacted and may continue to adversely impact financial markets and macroeconomic conditions and could result in additional market volatility and disruptions globally.
Actions taken by the Federal Reserve, including changes in its target funds rate, balance sheet management, and lending facilities, and other central banks are beyond our control and difficult to predict. These actions can affect interest rates and the value of financial instruments and other assets and liabilities and can impact our borrowers. Sudden changes in monetary policy, for example in response to high inflation, could lead to financial market volatility, increases in market interest rates, and a flattening or inversion of the yield curve. 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. Continued low U.S. interest rates, potentially resulting from a further extended period of accommodative monetary policy and/or an economic downturn could have a further adverse impact on us, including our net interest income and results of operations.
Changes to existing U.S. laws and regulatory policies and evolving priorities, including those related to financial regulation, taxation, international trade, fiscal policy, climate change (including required reduction of greenhouse gas emissions) and healthcare, may adversely impact U.S. or global economic activity and our customers', our counterparties' and our earnings and operations. For example, the expiration of pandemic-related government assistance in the U.S. could result in a reduction in economic activity and lead to a deterioration in households’ finances, particularly if consumers also continue to face high inflation. A slowdown in consumer demand could limit the ability of firms to pass on fast-rising costs for labor and other inputs, weighing on earnings and potentially leading to an equity market downturn. Significant fiscal policy changes and/or initiatives may also raise the federal debt, affect businesses and household after-tax incomes and increase uncertainty surrounding the formulation and direction of U.S. monetary policy and volatility of interest rates. A rise in U.S. interest rates 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, particularly with important trading partners (including China and the EU) have in recent years negatively impacted financial markets. An escalation of tensions could lead to further measures that adversely affect financial markets, disrupt world trade and 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. Actions taken by other countries, particularly China, to restrict the activities of businesses, could also negatively affect financial markets.
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, our liquidity and our results of operations. Additionally, the transition from IBORs and other benchmark rates to alternative reference rates (ARRs) could negatively impact markets globally and our business, and/or magnify any negative impact of the above referenced factors on our business, customers and results of operations.
Increased market volatility and adverse changes in 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 (significant or otherwise) 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, the value of our securities, trading assets and other financial instruments, the cost of debt capital and our access to credit markets, the value of assets under management (AUM), fee income relating to AUM, customer allocation of capital among investment alternatives, the volume of client activity in our trading operations, investment banking fees, the general profitability and risk level of the transactions in which we engage and 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 Reserve or a non-U.S. central bank changes or signals a change in monetary policy, market interest rates or credit spreads could be affected, which could adversely impact the value of such assets. Changes to fiscal policy, including expansion of U.S. federal deficit spending and resultant debt issuance, could also affect market interest rates. In addition, although some interest rates have begun to rise and elevated inflation could lead to further increases, the continued low interest rate environment has had and could continue to have a negative impact on our results of operations, including on future revenue and earnings growth. A flattening or inversion of the yield curve could also negatively impact our results of operations, including revenue and earnings.
We use various models and strategies to assess and control our market risk exposures, but those are subject to inherent limitations. 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 assumptions or algorithms 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.
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We may incur losses if asset values decline, including due to changes in interest rates and prepayment speeds.
We have a large portfolio of financial instruments, including loans and loan commitments, securities financing agreements, asset-backed secured financings, derivative assets and liabilities, debt securities, marketable equity securities and certain other assets and liabilities that we measure at fair value that are subject to valuation and impairment assessments. We determine these values 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, unless we have effectively hedged our exposures. Increases in interest rates may result in a decrease in residential mortgage loan originations and could impact the origination of corporate debt. In addition, increases in interest rates or changes in spreads may adversely impact the fair value of debt securities and, accordingly, for debt securities classified as available for sale, may adversely affect accumulated other comprehensive income and, thus, capital levels. These market moves also may adversely impact the value of debt securities we hold to meet regulatory liquidity requirements. 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 transactions occur and the continued availability of these 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. Values of AUM also impact revenues in our wealth management and related advisory businesses for asset-based management and performance fees. Declines in values of AUM can result in lower fees earned for managing such assets.
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. We also engage in asset securitization transactions, including with the GSEs, to fund consumer lending activities. Our liquidity could be adversely affected by any inability to access the capital markets, illiquidity or volatility in the capital 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, prolonged federal government shutdowns, or changes in regulations, guidance or GSE status that impact our funding avenues or ability to access certain funding sources. Additionally, our liquidity may be negatively impacted by the unwillingness or inability of the Federal Reserve to act as lender of last 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, changes in customer behavior 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, which could result in the inability to transfer liquidity internally and inefficient funding, 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 (including clearing agents, custodians, central banks or central counterparties (CCPs)). These factors also have the potential to increase our borrowing costs and negatively impact our liquidity.
Several of these factors may arise due to circumstances beyond our control, such as general market volatility, disruption, shock or stress, the emergence or continuation of widespread health emergencies or pandemics, Federal Reserve policy decisions (including fluctuations in interest rates or Federal Reserve balance sheet composition), negative views or loss of confidence 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, 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, unforeseen outflows of cash, 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 and unexpected collateral calls, among other things, the result of which could be increased costs, a liquidity shortfall and/or impact on our liquidity coverage ratio.
Our liquidity and cost of obtaining funding is directly related to prevailing market conditions, including changes in interest and currency exchange rates, significant fluctuations in equity and futures prices, lower trading volumes and prices of securitized products and our credit spreads. Credit spreads reflect the published credit ratings, or other assessments of credit risk and relative value by market participants, of the Corporation and represent the risk premiums that our funding providers demand in excess of a benchmark interest rate, for example, U.S. Treasury securities rates. Increases in interest rates and our credit spreads can increase the cost of our 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, including changes in our credit ratings. 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
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profile, such as maturities, currencies or counterparties, can reduce our funding efficiency.
Reduction in our credit ratings could significantly limit our access to funding or the capital markets, increase 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 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 financial strength, performance, prospects and operations and factors not under our control, such as the macroeconomic and geopolitical environment, including any continued macroeconomic stress caused by the pandemic, or changes the rating agencies may make to the methodologies they use to determine our ratings.
Rating agencies could make adjustments to our credit ratings at any time, and there can be no assurance as to whether or when any downgrades could 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 experience loss of access to short-term funding sources such as repo financing, and/or incur increased cost of 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.
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.
Bank of America Corporation is a holding company, is dependent on its subsidiaries for liquidity and may be restricted from transferring funds from subsidiaries.
Bank of America Corporation, as the parent company, is a separate and distinct legal entity from our bank 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, which could result in adverse liquidity events. The parent company depends on dividends, distributions, loans and other payments from our bank 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, minimum regulatory capital and liquidity requirements and 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 parent 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.
Our liquidity and financial condition, and the ability to pay dividends to shareholders and to pay obligations could be materially adversely affected in the event of a resolution.
Bank of America Corporation, our parent holding company, is required to periodically 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 point of entry” strategy. This strategy provides that only the parent holding company would file for bankruptcy 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 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.
If 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. We could also be required to take certain actions that could impose operating costs and could potentially result in the divestiture of certain assets or restructuring of businesses and subsidiaries.
Additionally, 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
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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 point of entry” 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.
To the extent that the Corporation is resolved under the U.S. Bankruptcy Code or the FDIC’s orderly liquidation authority, third-party creditors of the Corporation’s subsidiaries may receive significant or full recoveries on their claims while security holders of Bank of America Corporation could face significant or complete losses.
Credit
Economic or market disruptions and insufficient credit loss reserves may result in a higher provision for credit 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. Deterioration in the financial condition of our consumer and commercial borrowers, counterparties or underlying collateral could adversely affect our financial condition and results of operations.
Our credit portfolios may be impacted by global and U.S. macroeconomic and market conditions, events and disruptions, including declines in GDP, consumer spending or property values, asset price corrections, increasing consumer and corporate leverage, increases in corporate bond spreads, rising or elevated unemployment levels, rising or elevated inflation, fluctuations in foreign exchange or interest rates, as well as 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 typically have a negative impact on the business environment and financial markets, which could impact the underlying credit quality of our borrowers, counterparties and assets. Property value declines or asset price corrections could increase the risk of borrowers or counterparties defaulting or becoming delinquent in their obligations to us, and could decrease the value of the collateral we hold, which could increase credit losses. Credit risk could also be magnified by lending to leveraged borrowers or declining asset prices, including property or collateral values, unrelated to macroeconomic stress. Simultaneous drawdowns on lines of credit and/or an increase in a borrower’s leverage in a weakening economic environment could result in deterioration in our credit portfolio, should borrowers be unable to fulfill competing financial obligations. Increased delinquency and default rates could adversely affect our credit portfolios, including consumer credit card, home equity and residential mortgage portfolios through increased charge-offs and provisions for credit losses.
Although macroeconomic conditions have improved during 2021 in comparison to 2020, the pandemic and the related impacts of inflationary conditions, high input costs and supply chain disruptions, unemployment or labor shortages and the expiration of pandemic-related government benefits and programs could negatively impact the ability of consumer and
commercial borrowers or counterparties to meet their financial obligations. Additionally, the pandemic continues to impact the economy and certain sectors remain at risk (e.g., travel and entertainment, as well as commercial real estate office exposure). To the extent the pandemic worsens, as a result of new variants or otherwise, resulting in restrictions on economic activity or other negative impacts on the macroeconomic environment, our credit portfolio and allowance for credit losses could be adversely impacted.
We 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 relevant financial assets. The process to determine the allowance for credit losses uses models and assumptions that require us to make difficult and complex judgments that are often interrelated. This includes forecasting how borrowers or counterparties will perform in changing and unprecedented economic conditions, such as predicting developments in public health and fiscal policy related to 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 estimates. There is also the possibility that we have failed or will fail to accurately identify the appropriate economic indicators or accurately estimate their impacts to our borrowers or counterparties, which similarly could impact the accuracy of our loss forecasts and allowance estimates.
If the models, estimates and assumptions we use to establish reserves or the judgments we make in extending credit to our borrowers or counterparties, which are more sensitive due to the current macroeconomic environment, including as a result of the uncertainty regarding the magnitude and duration of the pandemic, prove inaccurate in predicting future events, we may suffer unexpected losses. In addition, changes to external factors can negatively impact our recognition of credit losses in our portfolios and allowance for credit losses.
The allowance for credit losses is our best estimate of expected credit losses; however, there is no guarantee that it will be sufficient to address credit losses, particularly if the economic outlook deteriorates significantly and quickly. In such an event, we may increase 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 increase our provision for credit losses, which could have an 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 may be subject to concentrations of credit risk because of a common characteristic or common sensitivity to economic, financial, public health or business developments. For example, concentrations of credit risk may reside in a particular industry, geography, product, asset class, counterparty or 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 it is possible our limits and credit monitoring exposure controls will not function as anticipated.
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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, predominantly comprised of broker-dealers, commercial banks, investment banks, insurers, mutual funds, hedge funds, central clearing counterparties and other institutional clients, resulting in significant credit concentration with respect to these industries. Financial services institutions and other counterparties are inter-related because of trading, funding, clearing or other relationships. As a result, defaults by one or more 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, which may occur as a result of events that impact the value of the collateral, such as an asset price correction or fraud. 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.
Our commercial portfolios include exposures to certain industries, including asset managers and funds, real estate, finance companies and capital goods. Economic weaknesses, sustained elevated inflation, 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 down the value of certain assets. Additionally, we could experience continued and long-term negative impacts 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 (e.g., travel and entertainment, as well as commercial real estate office exposure) or other industry disruptions.
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. The U.S. has experienced a meaningful increase in property prices over the past year and a decrease in home price valuations or commercial real estate valuations in certain markets where we have large concentrations, as well as more broadly within the U.S. or globally, could result in increased servicing expenses, defaults, delinquencies or credit losses. 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 fees, outstanding loans or afford new products. 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 and liquidity 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 RWA.
We may be adversely affected if the U.S. housing market weakens or home prices decline.
Although the U.S. has experienced a meaningful increase in home prices in 2021, we remain conscious of geographic markets where housing price growth has increased significantly that could be vulnerable to declines in future periods and may negatively impact the demand and underlying collateral 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, both of which may be adversely affected by rising interest rates. Any downturn in the condition of the U.S. housing market, similar to the 2008 financial crisis or otherwise, could result 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, negatively affect our representations and warranties exposures, and adversely 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 that 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. Certain OTC derivative contracts and other trading agreements provide that upon the occurrence of certain specified events, such as a change in the credit rating of the Corporation or one or more of its affiliates, we may be required to provide additional collateral or take other 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.
We are also a member of various central counterparties (CCPs), in part due to regulatory requirements for mandatory clearing of derivative transactions, 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 required to post, which could mean unexpected and increased exposure to the CCP. As a clearing member, we are exposed to the risk of non-performance by our clients for which we clear transactions, which may not be covered by
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available collateral. Additionally, default by a significant market participant may result in further risk and potential losses.
Geopolitical
We are subject to numerous political, economic, market, reputational, operational, compliance, legal, regulatory and other risks in the 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 liquidity and credit risk could be adversely impacted by and our businesses and revenues derived from non-U.S. jurisdictions are subject to risk of loss from 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 or continuation of widespread health emergencies or pandemics, capital controls, currency re-denomination risk from a country exiting the EU or otherwise, currency fluctuations, foreign exchange controls or movements (caused by devaluation or de-pegging), unfavorable political and diplomatic developments, oil price fluctuations and changes in legislation. These risks are especially elevated in emerging markets. Additionally, continued tensions between the U.S. and important trading partners, particularly China, may result in sanctions, further tariff increases or other restrictive actions on cross-border trade, investment, and transfer of information technology that weigh on trade volumes, raise costs for producers, and adversely affect our businesses and revenues, as well as our customers and counterparties.
A number of non-U.S. jurisdictions in which we do business have been or may be negatively impacted by slowing growth or recessionary conditions, market volatility and/or political or civil unrest. The ongoing pandemic had a severe negative impact on global GDP, and despite significant progress in 2021, it appears that the global economy faces an uncertain and uneven recovery ahead. While the U.S. and numerous other countries have recovered to pre-pandemic levels of output, many countries and areas within countries are recovering more slowly. Economic weakness may prove persistent in many countries and regions, including certain regions of Europe, Japan and numerous emerging markets. Moreover, economic activity remains vulnerable to ongoing public health uncertainties with respect to the pandemic, and a number of countries are still imposing significant restrictions on residents and businesses. Global supply chain disruptions, labor shortages, wage pressures and elevated inflation in many countries pose further challenges, especially in the form of volatility in financial markets. Additionally, foreign exchange rates against the U.S. dollar are at risk of significant depreciation as the Federal Reserve raises interest rates.
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. 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 adversely impact us.
As a result of the pandemic and fiscal policy responses to it, including the increased purchase of government bonds and other financial assets by central banks, government debt levels have increased significantly raising the risk of volatility, significant valuation changes, political tensions among EU members regarding fiscal policy or defaults on or devaluation of sovereign debt, which could expose us to substantial losses.
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 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 result in increased expenses and changes to our organizational structure and adversely affect our businesses and results of operations in that market, as well as our reputation in general.
In connection with the U.K.’s exit from the EU, we are now subject to different laws and regulations, which are expected to diverge further over time, and are subject to the oversight of additional regulatory authorities. As political and regulatory environments evolve, 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, which subjects us to operational and compliance costs and risks. For example, our operations are subject to U.S. and non-U.S. laws and regulations relating to bribery and corruption, anti-money laundering, and economic sanctions, which can vary by jurisdiction. The increasing speed and novel ways in which funds circulate could make it more challenging to track the movement of funds and heighten financial crimes risk. Our ability to comply with these legal requirements depends on our ability to continually improve surveillance, detection and reporting and analytic 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 weaken the U.S. dollar, cause market volatility, negatively impact the global economy and banking system and adversely affect our financial condition, including our liquidity. Additionally, changes in fiscal, monetary or regulatory policy, including as a result of labor shortages, wage pressures, supply chain disruptions and higher inflation, 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, actions taken by the U.S. or other governments in response thereto, state-sponsored cyberattacks or campaigns, civil unrest and/or military conflicts, which could adversely affect business and economic conditions abroad and in the U.S. For example, escalating military tensions between Russia and Ukraine could result in regional instability and adversely impact
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commodity and other financial markets as well as economic conditions, especially in Europe. Additionally, this could magnify inflationary pressure resulting from the pandemic and extend any prolonged period of higher inflation.
Business Operations
A failure in or breach of our operational or security systems or infrastructure or business continuity plans, or those of third parties including their downstream service providers andor the financial services industry, could disrupt our critical business operations and customer services, result in regulatory, market, privacy, liquidity and operationaladditional risk exposures, and adversely impact our results of operations 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 including(including their downstream service providers,providers) and the financial services industry infrastructure. Our operational and security systems infrastructure, 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 errors in judgment, malice, fraudulent activity and/or engaging in violations of applicable policies, laws, rules or procedures), malfeasance or a failure or breach of systems or infrastructure cause disruptions to our organization and expose us to operational losses, regulatory risk and reputational harm. The Corporation’s and third parties’ inability to properly introduce, deploy and manage changes to internal financial and governance processes, existing products, services and technology, as well as new product innovations and technology could also result in additional operational and regulatory risk.
Additionally, 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 be ineffective or 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. We could also 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 or electrical, telecommunications or other major physical infrastructure outages, newly identified vulnerabilities in key hardware or software, failure of aging infrastructure and technology project implementation challenges, natural disasters such as earthquakes, tornadoes, hurricanes and floods, widespread health emergencies or pandemics and events arising from local or larger

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scale political or social matters, including terrorist acts, 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, 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, could result in operational disruptions and prolonged operational outages.
We continue to execute our business continuity plans due to the pandemic and will likely continue to be subject to heightened operational risks to the extent that the pandemic persists. We also continue to have greater reliance on remote access tools and technology and employees’ personal systems and increased data utilization and be increasingly dependent upon our information technology infrastructure to operate our
businesses remotely due to the increased number of employees who work from home and evolving customer preferences, including increased reliance on digital banking and other digital
services provided by our businesses. Effective management of our business continuity depends on the security, reliability and adequacy of such systems. We also continue to be at risk of business disruptions due to illness and unavailability as the pandemic persists, including from the emergence of new variants, particularly if they are more transmissible and/or severe.
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(including their downstream service providers,providers) with whom we interact or upon whom we rely, including a systematicsystemic cyber campaignevents that resultsresult in system outages and unavailability of part or all of the internet, cloud services and/or the financial services industry infrastructure.infrastructure (including critical banking activities). 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.
InFurthermore, to the eventextent 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.
A 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 and/or failure to identify and effectively respond to operational risks in a timely manner could expose us to market abuse, regulatory, market, privacy and liquidity risk, and adversely impact our results of operations and financial condition, as well as cause legal or reputational harm.
A cyber attack,cyberattack, 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 and/or misuse of confidential information and/or proprietary information,fraudulent activity and increase our costs to maintain and update our operational and security systems and critical infrastructure and adversely impact our results of operations, liquidity and financial condition, as well as cause legal or reputational harm.costs.
Our business 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(including their downstream service providers,providers) the financial services industry and financial data aggregators, with whom we interact, on whom we rely or who have access to our customers' personal or account information. Our business relies on effective access management and the secure collection, processing, transmission, storage and retrieval of confidential, proprietary, personalpersonally identifiable 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 remotely access our network, products and services, our employees, customers, suppliers, counterparties and other third parties increasingly use personal mobile devices or computing devices that are outside of our
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network and control environments and are subject to their own cybersecurity risks.
We, our employees, and customers, regulators and other third parties (including providers of products and services) are regularly the target of an increasing number of cyber threats and attacks and are likely towill continue to be the target of cyber attacks. These cyber attacksbe. Cyber threats and techniques used in cyberattacks are pervasive, andsophisticated, rapidly evolving, difficult to prevent and include computer viruses, malicious or destructive code (such as ransomware), social engineering (including phishing, attacks,vishing and smishing), denial of service or information or other security breach tactics that could result in disruptions to our businesses and operations, the loss of funds of the Corporation and/or its clients and 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. Cybersecurity risks have also significantly increased in recent years in part due to the growing number and increasingly sophisticated activities of malicious cyber actors, including organized crime groups, hackers, terrorist organizations, extremist parties, damageshostile foreign governments and state-sponsored actors, in some instances acting to promote political ends responding to policies and/or actions of the U.S. government. We are also subject to cyberattacks by disgruntled employees, activists and other third parties, including those involved in corporate espionage.
Our cybersecurity risk and exposure remains heightened because of, among other things, the evolving nature and pervasiveness of cyber threats, our prominent size and scale, our high-profile brand, our geographic footprint and international presence and our role in the financial services industry and the broader economy. The financial services industry, including the Corporation, is particularly at risk because of the use of and reliance on digital banking and other digital services, including mobile banking products, such as mobile payments, and other web- and cloud-based products and applications and the development of additional remote connectivity solutions, which increase cybersecurity risks and exposure. Acceptance and use of such digital banking products and services has substantially increased since the onset of the pandemic. Additionally, the proliferation of third-party financial data aggregators and emerging technologies, including our use of automation, artificial intelligence (AI) and robotics, increase our cybersecurity risks and exposure.
We continue to execute our business continuity plans due to the pandemic. Accordingly, our risk and exposure to cyberattacks and security breaches remain magnified due to our continued reliance on remote access tools and technology, resulting in increased reliance on virtual/digital interactions and 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, including from employees’ personal devices over which we do not have the same controls as we do when a larger employee population is working from our offices. Greater demand on our information technology infrastructure and security tools and processes will likely continue as the pandemic persists and may be experienced permanently.
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 whom we do business, upon whom we rely to facilitate or enable our business activities or upon whom our customers rely. Other indirect risks relate to providers of products and/or services, financial counterparties,
financial data aggregators, financial intermediaries, such as clearing agents, exchanges and clearing houses, regulators, providers of critical infrastructure, such as internet access and electrical power, and retailers for whom we process transactions. We are also at additional risk resulting from critical third-party information security and open-source software vulnerabilities.
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 providers of products and/or services, and regulators, the outsourcing of some of our business operations, and system and customer account updates and conversions. Further, any such event may not be disclosed to us in a timely manner. Similarly, any failure, cyberattack or other information or security breach that significantly degrades, deletes or compromises our systems or otherwise material disruption to our or our customers’data could adversely impact third parties, counterparties and the critical infrastructure of the financial services industry.
As a result of increasing consolidation, interdependence and complexity of financial entities and technology systems, a technology failure, cyberattack or other information or security vulnerability, failure or breach that significantly exposes, degrades, deletes or compromises the systems or data of one or more financial entities or third parties’ network accessparties (or their downstream service providers) could have a material impact on us, our counterparties or business
other market participants and ultimately have an adverse impact on financial stability in the U.S. and/or globally. 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.
operations, both domestically and internationally. 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. Cyber threats are rapidly changing, and despitethe techniques used in cyberattacks change rapidly. 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 cyber attacksor detect cyberattacks or information or security breaches nor may we be able toand implement effective preventive or defensive measures to address or mitigate such attacks or breaches. Even the most advanced internal control environment is vulnerable to compromise. Internal access management failures could result in the compromise or unauthorized exposure of confidential data. Targeted social engineering attacks are becoming more sophisticated and are extremely difficult to prevent.
Our cybersecurity risk and exposure remains heightened because of, among other things, the evolving nature and pervasiveness of cyber threats, our prominent size and scale, our role in the financial services industry and the broader economy. 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. For example, our plans to continue our use of automation, artificial intelligence and robotics, increase our internet and mobile banking products, including mobile payment and other web- and cloud-based products and applications, and develop additional remote connectivity solutions to serve our customers when and how they want to be served, increase our cybersecurity risks and exposure.
Additionally, 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 state-sponsored actors, in some circumstances as a means to promote political ends, and system and customer account updates and conversions result in heightened risk exposure. As a result, cybersecurity and the continued development and enhancement of our controls, processes and practices designed to protect our systems, computers, intellectual property and proprietary information, software, data and networks from attack, damageCyberattacks or unauthorized access remain a critical priority. Cybersecurity risks have also significantly increased in recent years in part due to the increasingly sophisticated 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. The techniques used in cyber attacks change frequently, and these attacks or ensuing 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 usualbusiness-as-usual state may be difficult to assess. As cyber threats continue to evolve, we may be required to expend significant additional money and resources to modify or enhance our protective measures, investigate and remediate any information security, software or network vulnerabilities or incidents whether specific to us, a third party, the industry or businesses in general, 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 risksAlthough to date we have not experienced any material losses or other material consequences relating to the customers, clients andtechnology failure, cyberattacks or other information or security breaches, whether directed at us or third parties, including their downstream service providersthere can be no assurance that our controls and the financial services industry, with whom we do business, upon whom we relyprocedures in place 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 clearingmonitor

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houses, vendors, regulators,and mitigate the risks of cyber threats, including the remediation of critical information security and software vulnerabilities, will be sufficient and/or timely and that we will not suffer material losses or consequences in the future. Successful penetration or circumvention of system security could result in negative consequences, including loss of customers and business opportunities, the withdrawal of customer deposits, misappropriation or destruction of our intellectual property, proprietary information or confidential information and/or the confidential, proprietary or personally identifiable information of certain parties, such as our employees, customers, providers of critical infrastructure, such as internet accessproducts and electrical power,services, counterparties and retailers for whom we process transactions. As a result of increasing consolidation, interdependence and complexity of financial entities and technology systems, aother third parties, or damage to their computers or systems. Also, any technology failure, cyber attackcyberattack, successful penetration or other information or security breach that significantly degrades, deletes or compromises thecircumvention of our networks and systems or data of one or more financial entities or third-party or their downstream service providers 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 technology failure, cyber attack or other information or security breach, termination or constraint of any third party including(including their downstream service providers,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 disclosedtransactions or cause prolonged computer and network outages resulting in material disruptions to us in a timely manner.
Although to date we have not experienced any material lossesour or our customers’ or other material consequences relating to technology failure, cyber attacksthird parties’ network access or other information or security breaches, whether directed at us or third parties, there can be no assurance that our controlscritical business operations and procedures in place to monitor and mitigate the risks of cyber threats will be sufficient and that we will not suffer material losses or consequencescustomer services, in the future. Cyber attacksU.S. and/or globally.
Cyberattacks or other information or security breaches, whether directed at us or third parties, may result in significant lost revenue, give rise to losses and claims brought by third parties, litigation exposure, government fines, penalties or haveintervention and other negative consequences. Furthermore, the public perception that a cyber attackcyberattack 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.business and/or result in the loss of confidence in our security measures. Additionally, our failure to communicate cyber incidents appropriately to relevant parties could result in regulatory, privacy, operational and reputational risk. Although 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 Cyberattacks or circumvention of system security could result in negative consequences, including loss of customers and business opportunities, the withdrawal of customer deposits, prolonged computer and network outages resulting in disruptions to our critical business operations and customer services, misappropriation or destruction of our intellectual property, proprietaryother information or confidential information and/or the confidential, proprietary or personal information of certain parties, such as our employees, customers, suppliers, counterparties and other third parties, or damage to their computers or systems. Thissecurity breaches could also result in a violation of applicable privacy 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, 2019, we had $10.7 billion of unresolved repurchase claims, net of duplicate claims and excluding claims where the statute of limitations has expired without litigation being commenced.
At December 31, 2019, our liability for obligations under representations and warranties exposures was $1.8 billion. We also have an estimated range of possible loss (RPL) for representations and warranties exposures that is combined with the litigation RPL, which we disclose in Note 13 – Commitments and Contingencies to the Consolidated Financial Statements. The recorded liability and estimated RPL are based on currently available information, significant judgment and a number of assumptions that are subject to change. 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. Future representations and warranties losses may occur in excess of our recorded liability and estimated RPL, and such losses could have a material adverse effect on our results of operations.
Additionally, our recorded liability for representations and warranties exposures and the corresponding estimated RPL 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.
For more information about our representations and warranties exposure, see Off-Balance Sheet Arrangements and Contractual Obligations – Representations and Warranties in the MD&A on page 42 and Note 13 – Commitments and Contingencies to the Consolidated Financial Statements.
Failure to satisfy our obligations as servicer for residential mortgage securitizations, and residential mortgage loans owned by other entities along withand other losses we could incur in our capacity as servicer, could harmadversely impact our reputation, increase servicing costs or adversely impact our results of operations.
We and our legacy companies service mortgage 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, 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 was 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 could result in changes to our business operations and may adversely impact our business.
During 2019,2021, we sold approximately $3.5$3.2 billion of loans to Fannie Mae (FNMA) andGSEs, primarily Freddie Mac (FHLMC). Each isFHLMC and Fannie Mae (FNMA) are currently in a conservatorship with itstheir primary regulator, the Federal Housing

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Finance Agency (FHFA), acting as conservator. In September 2019, the Treasury Department published a proposal to recapitalize FNMAFHLMC and FHLMCFNMA and remove them from conservatorship as well as reduce GSEs'their role in the marketplace. There can be no assuranceConsistent with this proposal, in January 2021, the Treasury Department further amended the agreement that thesegoverns the conservatorship of FHLMC and FNMA and delineated the continued objective to remove the GSEs from conservatorship. However, we cannot predict the future prospects of the GSEs, timing of the recapitalization or release from conservatorship, or content of legislative or rulemaking proposals will be fully adopted, and it is not possible to predict whenregarding the conservatorships will end. Iffuture status of the GSEs in the housing market. Additionally, if the GSEs were to take a reduced role in 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. Although the Treasury Department has released an administrative proposal and the FHFA has taken steps to unify underwriting parameters and create a common securitization platform, we cannot predict the prospects for the enactment, timing of the recapitalization or release from conservatorship or content of legislative or rulemaking proposals regarding the future status of the GSEs in the housing market. Accordingly, uncertainty regarding their future and the mortgage-backed securities they guarantee continues to exist.exist for the foreseeable future.
Any of these developments could adversely affect the value of our securities portfolios, capital levels, and liquidity and 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 the types of risk to which we are subject, including strategic, credit, legal, climate, market, liquidity, compliance, operational and reputational risks. While we employ a broad and diversified set of controls and risk 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, 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 correctly and efficiently, and develop risk management models to assess and control risk.
Our ability to manage risk is limited bydependent on our ability to consistently execute all elements of our risk management program and develop and maintain a culture of managing risk well throughout the Corporation and manage risks associated with third parties (including their downstream service providers), including providers and vendors,of products and/or services, to enable effective risk management and ensure that risks are appropriately considered, evaluated and responded to in a timely manner. Uncertain economic conditions, heightened
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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 our policies values and our risk frameworkRisk Framework and the overall complexity of our operations, among other developments, may result in a heightened level of risk for us. Accordingly, we could suffer lossesWe have experienced increased operational, reputational and compliance risk as a result of the need to rapidly implement multiple and varying pandemic relief programs, such as PPP and the processing of unemployment benefits for California and certain other states, which have resulted and will continue to result in losses, in addition to the continued execution of our business continuity plans due to the pandemic. Our failure to manage changeevolving risks or properly anticipate, manage, control or mitigate risks.
For more information about our risk management policies and procedures, see Managing Riskrisks could result in the MD&A on page 42.additional losses.
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. Additionally, we are subject to certain settlements, orders and agreements with government authorities from time to
time, which could 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, 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 clientsour clients. Additionally, we are required to file various financial and customers.non-financial regulatory reports to comply with laws and rules in the jurisdictions in which we operate.
We continue to make adjustments toadjust our business and operations, legal entity structure and our policies, processes, procedures and controls, including with regard to capital and liquidity management, policies, proceduresrisk management and controlsdata management, to comply with currently effective laws and regulations, as well as final rulemaking, guidance and interpretation by regulatory authorities, including the Department of Treasury (including the Internal Revenue Service (IRS)), 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 in the U.S. or abroad, including policies and rulemaking related to the Financial Reform Act, the pandemic, emerging technologies and the U.K.'s exit from the EU.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 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. However, regulatoryRegulatory 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. Additionally, we
We are also subject to laws, rules and regulations in the U.S. and abroad, including GDPR, CCPA and CCPA,CPRA, and a number of additional jurisdictions enacting or considering similar laws, regarding compliance with our privacy policies and the disclosure, collection, use, sharing and safeguarding of personalpersonally identifiable information of certain parties, such as our employees, customers, suppliers, counterparties and other third parties, the violation of which could result in litigation, regulatory fines and enforcement actions. The complexity and risk of compliance has been magnified by the collection of employee health information in response to the pandemic. Additionally, we will likely be subject to new and evolving data privacy laws in the U.S. and 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 published new standards of personal data transfer, and China and the U.K. have commenced consultation efforts to establish standards for personal data transfers. If cross-border personal data transfers are suspended or restricted or we are required to implement distinct processes for each jurisdiction’s 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, conduct investigations and assess significant civil or criminal monetary penalties or restitution and issue cease and desist or removal orders and 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 increase. In some cases, governmental authorities have required criminal pleas or other extraordinary terms as part of such resolutions, which could have significant consequences, including reputational harm, loss of customers, restrictions on the ability to access capital markets, and the

Bank of America 14


inability to operate certain businesses or offer certain products for a period of time.
The Corporation and the conduct of its employees and representatives, including conduct that could harm clients, customers, employees or the integrity of the markets, are subject to regulatory scrutiny across jurisdictions. Additionally, theThe 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 significant 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
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outcome of such proceedings, which may last a number of years, may be difficult to predict or estimate until late in the proceedings.estimate.
We are currentlyand may become subject to the terms of settlements, orders and agreements that we have entered into with government entities and regulatory authorities, and may become subject to additional settlements, orderswhich impose, or agreements in the future. Such settlements, orders or agreements cancould 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, 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 authorities, we could be required to enter into further settlements, orders or agreements and 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 employees conduct, 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 potential changes to the U.S. presidential administration and Congressevolving priorities, may 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(including their downstream providers,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, investigations, 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 against us and other financial institutions. The amount of damages, penalties and fines claimed in litigationthat litigants and other disputes, and regulatory and government proceedings againstregulators seek from us and other financial institutions continuecontinues to be high. Greater than expected 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. We continue to experience a significant volume of litigationThis includes disputes with consumers, customers and other disputes, including claims for contractual indemnification with counterparties regarding relative rights and responsibilities. Consumers, clients and other counterparties continue to be litigious. Among 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 customer complaints, alleged violations of law and customer harm. For example, U.S. regulators and government agencies have pursued claims against financial institutions under the Financial Institutions Reform, Recovery, and Enforcement Act, the False Claims Act, fair lending laws and regulations (including the Equal Credit Opportunity Act and the Fair Housing Act), antitrust laws, and consumer protection laws and regulations, including prohibitions on unfair, deceptive, and/or abusive acts and practices under the Consumer Financial Protection Act and antitrust laws.the Federal Trade Commission Act. Such claims may carry significant and, in certain cases, treble damages. TheThere is also an increased focus on compliance with global environment of extensive regulation, regulatory compliance burdens, litigationlaws, rules and regulatory and government enforcement, combined with uncertaintyregulations related to the continually evolving regulatory environment, may affect operationalcollection, use, sharing and compliance costssafeguarding of personally identifiable information and risks, which may limit or cease our ability to continue providing certain products and services.corporate data.
Additionally, misconduct by the Corporation’s employees and representatives, 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. There is also increased scrutiny of climate change-related policies, goals and disclosure, which could result in litigation and regulatory investigations and actions.
The global environment of extensive investigations, regulation, regulatory compliance burdens, litigation and regulatory enforcement, combined with uncertainty related to the continually evolving regulatory environment, have affected and will likely continue to affect operational and compliance costs and risks, including the limitation or cessation of our ability or feasibility to continue providing certain products and services. Lawsuits and regulatory actions have resulted in and will likely continue to result in judgments, orders settlements, penalties and fines adverse to us. Further, the Corporation's participation in implementing government relief measures related to the pandemic and other federal and state government assistance programs, including the processing of unemployment benefits for California and certain other states, may lead to additional such judgments, orders, settlements, penalties and fines. Litigation and investigation costs, substantial legal liability or significant regulatory or government action against us could have material adverse effects on our business, financial condition, including liquidity, and results of operations, and/or cause significant reputational harm as well as litigation and regulatory government enforcement action.
For more information on litigation and regulatory matters, see Note 13 – Commitments and Contingenciesto the Consolidated Financial Statements.us.
U.S. federal banking agencies may require us to increase our regulatory capital, TLAC,total loss-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 institution. If any of our subsidiary insured depository institutions fails to maintain its status as 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 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
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requiring us to cease and desist activities permitted under the Bank Holding Company Act of 1956.
Capital 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

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increase liquidity requirements. Our ability 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 may increase from current estimates, and we are also subject to aor countercyclical capital buffer, which, while currently set at zero, may be increasedour returns of capital to shareholders could decrease. For example, our G-SIB surcharge is expected to increase by regulators. In 2018,50 basis points to 3.0 percent on January 1, 2024.
As part of its CCAR, the Federal Reserve issued a proposal to implement aconducts stress capital buffer into its capital requirements,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 increaseimpact the level of our regulatorySCB requiring us to hold additional capital. Additionally, the Federal Reserve could reinstitute limitations or prohibitions on taking capital requirements, if adopted. actions, such as paying or increasing dividends or repurchasing common stock as a result of the economic impact of the ongoing pandemic or otherwise impose such limitations in connection with other economic disruptions or events.
A significant component of regulatory capital ratios is calculating our risk-weighted assetsRWA and our leverage exposure, which may increase. 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.
Additionally, Net Stable Funding Ratio requirements Banks have been proposed, which would applyexperienced an increase in balance sheets, increasing leverage exposures and causing leverage-based ratios to us and our subsidiary depository institutions, and target longer term liquidity risk. While the impact of these proposals remains uncertain, they could have a negative impact on ourovertake risk-based capital and liquidity positions. In 2019, U.S. banking regulators published a final rule outlining a standardized approach for counterparty credit risk, which updates the calculation of the exposure amount for derivative contracts under the regulatory capital rule. The final rule will be effective on April 1, 2020, with a mandatory compliance date of January 1, 2022. This rule could have a negative impact on our capital position upon final implementation.
As part of its annual 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 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. Such ability to return capital to our shareholders substantially depends on the Federal Reserve's response to our annual CCAR submission. To the extent that the Federal Reserve objects to our annual CCAR submission or objects to the amount of dividends or stock repurchases proposed, our shareholder returns could decrease.ratios.
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 46 and Note 17 – Regulatory Requirements and Restrictions to the Consolidated Financial Statements.
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,misapplied, we could be required to correct and restate prior-period financial statements. Accounting standard-setters and those who interpret the accounting standards, including 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. For more information on some of our critical accounting policies and recent accounting changes, see Complex Accounting Estimates in the MD&A on page 77 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.
In DecemberIt 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 materially adversely affect us, including the possibility that aspects of the 2017 the President signed into law the Tax Cuts and Jobs Act (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 materially adversely affect our results of operations. Additionally, U.S. and foreign tax laws are complex and our judgments, interpretations or applications of such tax laws could differ from that of the relevant governmental authority. This could result in additional tax liabilities and interest, penalties, the reduction of certain tax benefits and/or the requirement to make adjustments to amounts recorded, 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.could be material.
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.
It is possible that governmental authorities in the U.S. and/or other countries could further amend tax laws in a way that would adversely affect us, including the possibility that aspects of the Tax Act could be amended in the future.DTA.
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 and/or employee activities, such as fraud, misconduct and unethical behavior (such as employees’ sales practices), security breaches, litigation or regulatory matters and their outcomes, compensation practices, lending practices, the suitability or reasonableness of recommending particular trading or investment strategies, including the reliability of our research and models and prohibiting clients from engaging in certain transactions and sales practices. transactions.
Additionally, our reputation may be harmed by failing to deliver the products subparand standards of service and quality expected by our customers, clients and the community, the failure to recognize and address customer complaints, compliance failures, the inability to manage technology change or maintain effective data management, cyber incidents, prolonged or repeated system outages, internal and external fraud, inadequacy of responsiveness to internal controls, unintended disclosure of personal, proprietary or confidential information, perception of our environmental, social and governance practices and disclosures, conflicts of interest and breach of fiduciary obligations, the handling of health emergencies or pandemics, and the activities of our clients, customers, counterparties and third parties, including vendors. providers of products and/or services. 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 and other federal and state government assistance programs, including the processing of unemployment benefits for California and certain other states, as well as how we handle employee matters related to the pandemic. Our reputation may also be negatively impacted by our ESG practices and disclosures, our businesses
Bank of America 20


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,Also, adverse publicity or negative information posted on social media by employees, the media or otherwise, whether or not factually correct, may adversely impact our business prospects or financial results.
We are subject to complex and evolving laws and regulations regarding privacy, fair lending activity, UDAAP, electronic funds transfers, know-your-customer requirements, data protection, including the GDPR, CCPA and CCPA,CPRA, cross-border data movement and other matters. Principles concerning the appropriate scope of consumer and commercial privacy vary

Bank of America 16


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(including their downstream service providersproviders) or financial data aggregators, is mishandled, misused or 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 use our products and services, or give rise to litigation or enforcement actions, which could adversely affect our 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. For more information on reputational risk, see Reputational Risk Management
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 continues to be a major transition in progress in the MD&Aglobal 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 have been used extensively across the global financial markets and in our business. In particular, LIBOR has historically been 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 referencing LIBOR or other IBORs remains material to our business. At the end of 2021, the global financial markets generally transitioned away
from the use of all LIBOR settings (except for certain U.S. dollar (USD) LIBOR settings). However, there continue to be risks and challenges associated with the transition from IBORs that may result in consequences that cannot be fully anticipated, which expose us to various financial, operational, supervisory, conduct and legal risks, which we continue to monitor closely.
Through a multi-year effort by the industry and regulators, ARRs have been identified and/or developed and are being used to replace LIBOR and other IBORs. However, 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 from the benchmarks they replace, in some cases have limited history, and may demonstrate less predictable performance over time than the benchmarks they replace. For example, certain ARRs are calculated on page 77.a compounded or weighted-average basis and, unlike IBORs, do not reflect bank credit risk and therefore typically require a spread adjustment. 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. Changes resulting from transition to successor or alternative rates 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. There can be no assurance that existing assets and liabilities based on or linked to IBORs that have not already transitioned to ARRs will successfully transition.
OtherGiven the continuation of certain USD LIBOR settings until June 30, 2023, IBOR-based products and contracts (IBOR Products) linked to these LIBOR settings will still have to be transitioned by such time. Although a significant majority of the aggregate notional amount of our IBOR-based products maturing after 2021 include or have been updated to include fallbacks to ARRs, the transitioning of certain IBOR Products that do not include fallback provisions or adequate fallback mechanisms will require additional efforts to modify their terms. Some outstanding IBOR Products are particularly challenging to modify due to the requirement that all impacted parties consent to such modification. To address such challenges in IBOR Products, legislation has been adopted in various jurisdictions, including the EU, U.K. and New York State, and federal legislation is pending in the U.S. Congress. 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 laws in different jurisdictions.
Some of our IBOR Products, in particular LIBOR-based products and contracts, may contain language giving the calculation agent (which may be us) discretion to determine the successor rate (including the ARR and/or the applicable spread adjustment) to the existing benchmark. We may face a risk of litigation, disputes or other actions from clients, counterparties, customers, investors or others based on various claims, for example that the Corporation incorrectly interpreted or enforced IBOR-based contract provisions, failed to appropriately communicate the effect that the transition to ARRs will have on
21 Bank of America


existing and future products, treated affected parties unfairly or made inappropriate product recommendations to or investments on behalf of its clients, or engaged in anti-competitive behavior or unlawfully manipulated markets or benchmarks.
We have launched, and expect to continue to develop, launch and support, ARR-based products and services. There is no guarantee that liquidity in ARR-based products will develop, and it is possible that ARR-based products, including products using credit sensitive rates, 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. New financial products linked to ARRs may have additional legal, financial, tax, operational, market, compliance, reputational, competitive or other risks to us, our clients and other market participants. In particular, banking regulators in the U.S. and globally have increased regulatory scrutiny and intensified supervisory focus of financial institution LIBOR transition plans, preparations and readiness, including the Corporation’s use of credit-sensitive rates like the Bloomberg Short-Term Bank Yield Index, which could result in a regulatory action, litigation and/or the need to change the products offered by our businesses.
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.
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 IBOR Products 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. Continuing reforms to 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 us.
We face significant and increasing competition in the financial services industry.
We operate in a highly competitive environment and experience intense competition from local and global financial institutions as well as new entrants, in both domestic and foreign 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, customer convenience and customer convenience.experience and relationships in relevant markets. Additionally, the changing regulatory environment may create competitive disadvantages for us 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, 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, emerging 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 allowed non-traditional
financial service providers and technology companies to
compete with traditional 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, 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.risky. 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 business strategies, 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',providers of products and services’ ability to adapt and develop our business strategies, products, services and technology to rapidly evolving industry 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 on more attractive terms, including lower fees and higher interest rates on deposits, and offer lower cost investment strategies, which may impact our ability to grow revenue and/or effectively compete. Additionally, legislative and regulatory developments may affect the competitive landscape.landscape and impact the products and services that we can offer. Further, the competitive landscapewe may be impacted by the growth of non-depository institutions that offer traditional banking products at 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, either from a decrease in the volume of transactions or through a compression of spreads.
In addition, theThe 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, Central Bank Digital Currencies (CBDCs) and payment systems, could require substantial expenditures to modify or adapt our existing products and services as we grow and develop our online and mobile banking channel strategies in addition to remote connectivity solutions. WeAs CBDC initiatives evolve and mature, our businesses and results of operations could be adversely impacted, including as a result of the introduction of new competitors to the payment ecosystem and increased volatility in deposits and/or significant long-term reduction in deposits (i.e., financial disintermediation). Also, we may not be as timely or successful in developing or introducing new products and services, integrating new products or services into our existing offerings, responding, managing 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. OurThe Corporation’s or ourits third-party vendors' inability to adaptproviders of products and services’ inability or resistance to timely innovate or adapt its operations, products and services
Bank of America 22


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.
Our ability to attract and retain qualified employees is critical to the 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 may be subject to limitations on compensation practices (which may or may not affect our competitors) by the Federal Reserve, the OCC, the FDIC and other regulators around the world. EU and U.K. rules limit and subject

17Bank of America






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 form of long-term equity-based awards. Therefore, the ultimate value of this compensation depends on the price of our common stock when the awards vest. If we are unable to continue to attract and retain qualified individuals, our business prospects and competitive position could be adversely affected.
We could suffer operational, reputational and financial harm if our models and strategies fail to properly anticipate and manage risk.risk.
We use proprietary models and strategies extensively to forecast losses, project revenue, measure and assess capital and liquidity requirements for credit, country, market, operational and strategic risks, assist in capital planning and assess and control our operations and financial condition. These models requireModel 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 our Enterprise Model Risk Policy, Model Risk Management is required to perform model oversight, including independent validation before initial use, ongoing monitoring reviews 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, andand emerging risks from the use of applications that rely on artificial intelligence. AI.
Our models and strategies may not be sufficiently predictive of future results due to limited historical patterns, extreme or unanticipated market movementsmovements or customer behavior and illiquidity,liquidity, especially during severe market downturns or stress events, which could limit their effectiveness.effectiveness and require timely recalibration. 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 be adversely impacted as a result of human error and may not be effective if we fail to properly oversee and review them at regular intervals 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, inaccurate reporting and inaccurate financial, regulatorynon-compliance with laws, rules and operational reporting.regulations.
WeOur ability to obtain, create, report and maintain information, including the data associated with it, during our normal course of business is a foundational component of our business and of managing relationships with customers. Additionally, we rely on our ability to manage aggregate, interpret and use data in an accurate, timely and complete manner, for effective risk reportingincluding the capture, transport, aggregation, validation, processing, quality, interpretation, protection, maintenance, retention, external transmission and management.use. Our policies, programs, processes and practices govern how data risk is managed aggregated, interpreted and used.globally. While we continuously update our policies, programs, processes and practices and implement emerging technologies, such as automation, artificial intelligenceAI and robotics, our data management processes may not be effective and aggregation processes are subject to failure,weaknesses and failures, including human error, data limitations, process delays, system failure or failed controls.
Failure to maintain andproperly 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, detect or surveil potential misconduct or non-compliance with laws, rules and regulations, 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 have an adverseadversely impact on our ability to develop our products and relationships with our customers, increase regulatory risk and operational losses, and damage our reputation.
ReformsOur 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 uncertainty regarding IBORs,related environmental sustainability matters, which present short-term and an increasing amount of long-term risks to us. 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 London Interbank Offered Rate (LIBOR),operations of customers or third parties on which we rely. Such disasters could result in market volatility or negatively impact our customers’ ability to repay outstanding loans, result in rapid deposit outflows, cause supply chain and/or distribution network disruptions, 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 or technology and additional legislation, regulatory and legal requirements, including those associated with the transition to a low-carbon economy, could restrict the scope of our existing businesses, limit our ability to pursue certain other rates business activities and offer certain products and services, amplify credit and market risks, negatively impact asset values, increase expenses, including as a result of strategic planning and technology and market changes, and/or indices mayotherwise adversely affectimpact us, our business, financial conditionbusinesses or our customers. Our response to climate change, our climate change strategies, policies, goals, commitments and resultsdisclosure, and/or our ability to achieve our climate-related goals and commitments (which are subject to risks and uncertainties, many of operations andwhich are outside of our control) could result in reputational harm as a result of negative public sentiment, regulatory scrutiny, litigation and reduced investor and stakeholder confidence.
Our ability to the Corporation.attract and retain qualified employees is critical to our success, business prospects and competitive position.
In 2017, the U.K. FCA announced that it will no longer persuade or require participating banks to submit rates for LIBOR after 2021. The continuation of LIBOROur performance and competitive position is heavily dependent on the current basis cannot be guaranteed after 2021,talents and there is substantial risk that LIBOR will be modified by 2021 or discontinued thereafter. This announcement, in conjunction with financial benchmark reforms and changes in short-term interbank lending markets more generally, have resulted in significant uncertainty about the potential or actual discontinuationefforts of IBORs, including LIBOR, and certain other rates or indices that serve as “benchmarks.” Such benchmarks are used extensively in the global financial markets and in our business. In particular, LIBOR is used in many of our products and contracts, including mortgages, consumer, commercial and corporate loans, derivatives, floating-rate notes and other adjustable-rate products and financial instruments. The aggregate notional amount of these products and contracts is material to our business. These reforms and actions may result in significant uncertainty as to future rules or methodologies used to calculate benchmarks, cause new or reformed benchmarks to perform differently from the discontinued benchmarks they are replacing, cause existing benchmarks to disappear or become unavailable or unrepresentative, or have other consequences that cannot be fully anticipated, which expose us to various financial, operational and legal risks.
Certain ARRs have been proposed to replace LIBOR and other IBORs. For example, the Alternative Reference Rates Committee, a group of private-market participants and official-sector entities convened by the Federal Reserve Board and the Federal Reserve Bank of New York, has recommended that the Secured Overnight Financing Rate (SOFR) replace U.S. dollar LIBOR. However, the market transition from IBORs to ARRs is complex and pervasive throughout a number of different types of products and global financial markets. There can be no assurance that ARRs will be adequate alternatives to IBORs, 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 such ARRs in the global financial markets, or of the future availability or representativeness of such ARRs. 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. The considerable uncertainty as to howhighly skilled individuals. Competition for qualified personnel within the financial services industry will addressand from businesses outside the discontinuation of IBORs and/or such IBORs ceasingfinancial services industry is intense.
Our competitors include global institutions and institutions subject to be acceptable reference rates in financial instruments could ultimately result in client disputesdifferent compensation and litigation surrounding the proper interpretation of our IBOR-based products and contracts. Accordingly, uncertainty regarding ARRs may continue to impact our business, operationshiring regulations than those imposed on U.S. institutions and financial condition repeatedlyinstitutions. Also, our ability to attract and indefinitely.retain employees could be impacted by the pandemic, including changing workforce concerns, expectations, practices and preferences (including remote work), and increasing labor shortages and competition for labor, which could increase labor costs.
The discontinuation of IBORs, including LIBOR, will require usIn order to remediate IBOR-based productsattract and contracts, including related hedging arrangements, that mature after the discontinuation date of the IBOR. These changesretain qualified personnel, we must provide market-level compensation. As a large financial and banking institution, we are and may adversely affect the yield on loans or securities held by us, amounts paid on securities we havebecome subject to

23Bank of America18


issued, amounts receivedadditional limitations on compensation practices, which may or may not affect our competitors, by the Federal Reserve, the OCC, the FDIC and other regulators around the world. EU and U.K. rules limit and subject to clawback certain forms of variable compensation for senior employees. Furthermore, a substantial portion of our annual incentive compensation paid on derivatives we have entered into,to our senior
employees, as well as certain periodic awards to both senior and broad-based groups of employees, consist of long-term equity-based awards, the value of such loans, securities or derivative instruments,which is based on the trading market for such products and contracts, and our ability to effectively use hedging instruments to manage risk. While some of these outstanding IBOR-based products and contracts include fallback provisions to ARRs, someprice of our outstanding IBOR-based productscommon stock when the awards vest. Our business prospects and contracts do not include fallback provisions or adequate fallback mechanisms requiring remediation to modify their terms. Additionally, some outstanding IBOR-based productscompetitive position could be adversely affected if we cannot attract and contracts are particularly challenging to modify due to the requirement that all impacted parties consent to such modification.retain qualified individuals.
In light of the extensive use of IBOR-based products and contracts by us and other market participants, there can be no assurance that we and other market participants will be able to successfully modify all outstanding IBOR-based products and contracts 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-based products and contracts will include adequate methodologies for adjustments between the applicable IBOR and the corresponding successor rate or that the characteristics of the successor rates will be similar to or produce the economic equivalent of the benchmarks they seek to replace. For example, SOFR and other ARRs have compositions and characteristics that differ significantly from the benchmarks they may replace, have limited history, and may demonstrate less predictable performance over time than the benchmarks they replace.
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-based products and contracts, cause significant market dislocations and
disruptions that are relevant to our business segments, particularly Global Banking and Global Markets, 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-based products and contracts with counterparties, and/or increase expenses related to the transition to ARRs, among other adverse consequences. Additionally, the process of transitioning to ARRs may result in increased costs and may also divert management time and attention from other areas of our business.
The market transition from IBORs to ARRs 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 from current IBORs to ARRs and other factors, including the pace of the transition to ARRs, the specific terms and parameters for market acceptance of any ARRs, prices of and liquidity of trading markets for products based on ARRs, and our ability to transition and develop appropriate systems and analytics for one or more ARRs, 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.
Item 1B. Unresolved Staff Comments
None

Item 2. Properties
As of December 31, 2019,2021, 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 Financial CentreLondon, UK4 Building Campus
Global Banking and Global Markets
Leased562,595566,920
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 76.371.8 million square feet in over 20,000 facilityfacilities and ATM locations globally, including approximately 70.766.8 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 5.65.0 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 1312 – Commitments and Contingencies to the Consolidated Financial Statements, which is incorporated herein by reference.
Item 4. Mine Safety Disclosures
None

19Bank of America






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 under the symbol “BAC.” As of February 18, 2020,2022, there were 161,882148,551 registered shareholders of common stock.
The table below presents share repurchase activity for the three months ended December 31, 2019.2021. 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 Price
Total Shares
Purchased as
Part of Publicly
Announced Programs (2)
Remaining Buyback
Authority Amounts (3)
October 1 - 31, 202161,395 $45.53 61,390 $23,850 
November 1 - 30, 202171,187 47.27 71,186 20,624 
December 1 - 31, 202130,895 44.45 30,894 19,311 
Three months ended December 31, 2021163,477 46.08 163,470 
        
(Dollars in millions, except per share information; shares in thousands)
Total Common Shares Purchased (1)
 Weighted-Average Per Share Price 
Total Shares
Purchased as
Part of Publicly
Announced Programs
 
Remaining Buyback
Authority Amounts (2)
October 1 - 31, 201997,540
 $29.50
 97,538
 $20,442
November 1 - 30, 201974,649
 32.75
 74,649
 17,997
December 1 - 31, 201970,943
 34.19
 70,940
 15,571
Three months ended December 31, 2019243,132
 31.87
 243,127
  
(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 and for potential re-issuance to certain employees under equity incentive plans.
(1)
(2)On October 20, 2021, the Corporation announced its Board of Directors (Board) authorized the repurchase of up to $25 billion of common stock over time (October Authorization). The Board also authorized repurchases to offset shares awarded under equity-based compensation plans. This October Authorization replaced the April 15, 2021 authorization for repurchases of up to $25 billion of common stock (April Authorization, and together with the October Authorization, the Board Authorizations). During the three months ended December 31, 2021, pursuant to the Board Authorizations, the Corporation repurchased approximately 163 million shares, or $7.5 billion, of its common stock, including to offset shares awarded under equity-based compensation plans. For more information, see Capital Management - CCAR and Capital Planning in the MD&A on page 49 and Note 13 – Shareholders’ Equity to the Consolidated Financial Statements.
(3)Remaining Buyback Authority Amounts represents the remaining buyback authority of the October Authorization. At the time the April Authorization was replaced with the October Authorization, the Corporation had $9.4 billion of remaining buyback authority available under the April Authorization. Such remaining buyback authority was canceled in the October Authorization. Excludes repurchases to offset shares awarded under equity-based compensation plans.
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 and for potential re-issuance to certain employees under equity incentive plans.
(2)
On June 27, 2019, following the Board of Governors of the Federal Reserve System's non-objection to the Corporation's 2019 Comprehensive Capital Analysis and Review capital plan, the Corporation's Board of Directors (Board) authorized the repurchase of approximately $30.9 billion in common stock from July 1, 2019 through June 30, 2020, which includes approximately $900 million to offset shares awarded under equity-based compensation plans during the same period. During the three months ended December 31, 2019, pursuant to the Board’s authorization, the Corporation repurchased $7.7 billion of common stock, which included common stock to offset equity-based compensation awards. For more information, see Capital Management - CCAR and Capital Planning in the MD&A on page 45 and Note 14 – Shareholders’ Equity to the Consolidated Financial Statements.
The Corporation did not have any unregistered sales of equity securities during the three months ended December 31, 2019.
Item 6. Selected Financial Data
See Tables 6 and 7 in the MD&A beginning on page 28, which are incorporated herein by reference.


2021.
Bank of America 20


Bank of America 24


Item 6. [Reserved]
Item 7. Bank of America Corporation and Subsidiaries
Management’sManagement's Discussion and Analysis of Financial Condition and Results of Operations
Table of Contents
Table of Contents
Page
Loan and Lease Contractual Maturities

2125 Bank of America






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.” 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: and in any of the Corporation’s subsequent Securities and Exchange Commission Filings: the Corporation’s potential claims, damages,judgments, orders, settlements, penalties, fines and reputational damage resulting from pending or future litigation and regulatory investigations, proceedings and enforcement actions;actions, including as a result of our participation in and execution of government programs related to the Coronavirus Disease 2019 (COVID-19) pandemic, such as the processing of unemployment benefits for California and certain other states; the possibility that the Corporation'sCorporation’s future liabilities may be in excess of its recorded liability and estimated range of possible loss for litigation, and regulatory and representations and warranties exposures;government actions; the possibility that the Corporation could face increased servicing, fraud, indemnity, contribution or other claims from one or more counterparties, including trustees, purchasers of loans, underwriters, issuers, monolines, private-label and other investors, or other parties involved in mortgage securitizations; the Corporation’s ability to resolve representations and warranties repurchase and related claims, including claims brought by investors or trustees seeking to avoid the statute of limitations for repurchase claims; the risks related to the discontinuation of the London Interbank Offered Rate and other reference rates, including increased expenses and litigation and the effectiveness of hedging strategies; uncertainties about the financial stability and growth rates of non-U.S. jurisdictions, the risk that those jurisdictions may face difficulties servicing their sovereign debt, and related stresses on financial markets, currencies and trade, and the Corporation’s exposures to such risks, including direct, indirect and operational; the impact of U.S. and global interest rates, inflation, currency exchange rates, economic conditions, trade policies and tensions, including tariffs, and potential geopolitical instability; the impact of the interest rate and inflationary environment on the Corporation’s business, financial condition and results of operations; the possibility that future credit losses may be higher than currently expected due to changes in economic assumptions, customer behavior, adverse developments with respect to U.S. or global economic conditions and other uncertainties;uncertainties, including the impact of supply chain disruptions, inflationary pressures and labor shortages on the economic recovery and our business; the Corporation's concentration of credit risk; the Corporation’s ability to achieve its expense targets and expectations regarding revenue, net interest income, provision for credit losses, net charge-offs, effective tax
rate, loan growth or other projections; adverse changes to the Corporation’s credit ratings from the major credit rating agencies; an inability to access capital markets or maintain deposits or borrowing costs; estimates of the fair value and other accounting values, subject to impairment assessments, of certain of the Corporation’s assets and liabilities; the estimated or actual impact of changes in accounting standards or assumptions in applying those standards; uncertainty regarding the content, timing and
impact of regulatory capital and liquidity requirements; the impact of adverse changes to total loss-absorbing capacity requirements, stress capital buffer requirements and/or global systemically important bank surcharges; the potential impact of actions of the Board of Governors of the Federal Reserve System on the Corporation’s capital plans; the effect of regulations, other guidancechanges in or additional information on the impact from the Tax Cutsinterpretations of income tax laws and Jobs Act;regulations; the impact of implementation and compliance with U.S. and international laws, regulations and regulatory interpretations, including, but not limited to, recovery and resolution planning requirements, Federal Deposit Insurance Corporation assessments, the Volcker Rule, fiduciary standards, derivatives regulations and 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 attackscyberattacks or campaigns; the transition and physical impacts of climate change; our ability to achieve environmental, social and governance goals and commitments or the impact onof any changes in the Corporation’s business, financial condition and results of operations from the United Kingdom's exit from the European Union;sustainability strategy or commitments generally; the impact of any future federal government shutdown and uncertainty regarding the federal government’s debt limit; the impact of natural disasters,limit or changes in fiscal, monetary or regulatory policy; the emergence of widespread health emergencies or pandemics, including the magnitude and duration of the COVID-19 pandemic and its impact on the U.S. and/or global, financial market conditions and our business, results of operations, financial condition and prospects; the impact of natural disasters, extreme weather events, military conflict, terrorism or other geopolitical events; and other matters.
Forward-looking statements speak only as of the date they are made, and the Corporation undertakes no obligation to update any forward-looking statement to reflect the impact of circumstances or events that arise after the date the forward-looking statement was made.
Notes to the Consolidated Financial Statements referred to in the Management’s Discussion and Analysis of Financial Condition and Results of Operations (MD&A) are incorporated by reference into the MD&A. Certain prior-year amounts have been reclassified to conform to current-year presentation. Throughout the MD&A, the Corporation uses certain acronyms and abbreviations which are defined in the Glossary.
Executive Summary
Business Overview
The Corporation is a Delaware corporation, a bank holding company (BHC) and a financial holding company. When used in this report, “the Corporation,” “we,” “us” and “our” may refer to Bank of America Corporation individually, Bank of America Corporation and its subsidiaries, or certain of Bank of America Corporation’s subsidiaries or affiliates. Our principal executive offices are located in Charlotte, North Carolina. Through our bankingvarious bank and various nonbank subsidiaries throughout the U.S. and in international markets, we provide a diversified range of
Bank of America 26


banking and nonbank financial services and products through four business segments: Consumer Banking, Global Wealth & Investment Management (GWIM), Global Banking and Global Markets, with the remaining operations recorded in All Other. We operate our banking activities primarily under the Bank of America, National Association (Bank of America, N.A. or BANA) charter. At December 31, 2019,2021, the Corporation had $2.4$3.2 trillion in assets and a headcount of approximately 208,000 employees.
As of December 31, 2019,2021, we served clients through operations across the U.S., its territories and approximately 35 countries. Our retail banking footprint covers approximately 90 percent ofall major markets in the U.S. population,, and we serve approximately 6667 million consumer and small business clients with approximately 4,3004,200 retail financial centers, approximately 16,80016,000 ATMs, and leading digital banking platforms (www.bankofamerica.com) with more than 38approximately 41 million active users, including over 29approximately 33 million active mobile users. We offer industry-leading support to approximately

Bank of America 22


three million small business owners.households. Our wealth managementGWIM businesses, with client balances of $3.0$3.8 trillion, provide tailored solutions to meet client needs through a full set of investment management, brokerage, banking, trust and retirement products. We are a global leader in corporate and investment banking and trading across a broad range of asset classes serving corporations, governments, institutions and individuals around the world.
Recent Developments
Capital Management
During 2019, we repurchased $28.1 billionOn February 2, 2022, the Corporation announced that the Board of Directors declared a quarterly cash common stock pursuantdividend of $0.21 per share, payable on March 25, 2022 to the Corporation's Boardshareholders of Directors’ (the Board) repurchase authorizations. record as of March 4, 2022.
For more information on our capital resources and regulatory developments, see Capital Management on page 45.49.
Merchant Services Joint VentureCOVID-19 Pandemic
A significant portion of our merchant processing activity is performed by a joint venture, formed in 2009, in which we own a 49 percent ownership interest. The joint venture is accounted for as an equity method investment. As previously disclosed in the Corporation's Quarterly Report on Form 10-Q for the quarter ended June 30,Coronavirus Disease 2019 we gave notice on July 29, 2019 to the joint venture partner of the termination of the joint venture upon the conclusion of its current term, after which we expect to pursue our own merchant services strategy. In addition,(COVID-19) pandemic (the pandemic) has impacted the Corporation and may continue to do so, as uncertainty remains about the joint venture partner have an agreement to provide uninterrupted delivery of products and services to the joint venture merchants through at least June 2023. As a resultduration of the above actions, we incurred a non-cash, pretax impairment charge of $2.1 billion included in other general operating expense inpandemic and the three months ended September 30, 2019. As stated above, the Corporation expects to pursue its own merchant services strategy, which is expected to begin in the third quarter of 2020. Under this strategy, we will begin to record the revenuestiming and expenses from those operations in the Consolidated Statement of Income instead of recognizing our proportionate sharestrength of the joint venture's incomeglobal economic recovery. As the pandemic continues to evolve, we regularly evaluate protocols and processes in place to execute our business continuity plans. In conjunction with our efforts to support clients affected by the pandemic, we have cumulatively originated $35.4 billion in loans under the equity method.Paycheck Protection Program (PPP) with amounts outstanding of $4.7 billion and $22.7 billion at December 31, 2021 and 2020. For more information on PPP loans, see Note 131Commitments and ContingenciesSummary of Significant Accounting Principles to the Consolidated Financial Statements.
U.K. Exit from the EU
On January 31, 2020, the U.K. formally exited the European Union (EU). Upon exit, a transition period began during which time the U.K.The future direct and the EU expect to negotiate a trade agreement and other terms associated with their future relationship. The transition period is scheduled to end on December 31, 2020.
We conduct business in Europe, the Middle East and Africa primarily through our subsidiaries in the U.K., Ireland and France. For information on the changes we have implemented to enable us to continue to operate in the region, including establishing a bank and broker-dealer in the EU, see the Corporation’s Quarterly Report on Form 10-Q for the quarter ended March 31, 2019. While we have taken measures to minimize operational disruption and prepare for various potential outcomes of the U.K.’s withdrawal from the EU, the preparedness of our counterparties and the relevant financial markets infrastructure remain outside our control. The global economicindirect impact of the U.K.’s withdrawal frompandemic on our businesses, results of operations and financial condition remains uncertain. Should current economic conditions deteriorate or if the pandemic worsens due to various factors,
including through the EU remains uncertainspread of more easily communicable variants of COVID-19, such conditions could have an adverse effect on our businesses and results of operations and could result in regionaladversely affect our financial condition.
For more information on how the risks related to the pandemic adversely affect our businesses, results of operations and global
financial market disruptions. We continue to assess potential risks, including operational, regulatory and legal risks.condition, see Part 1. Item 1A. Risk Factors on page 8.
LIBOR and Other Benchmark Rates
FollowingSubject to the 2017 announcement by the U.K.’s Financial Conduct Authority (FCA) that it will no longer persuade or require participating banks to submit rates for thecontinued publication of certain non-representative London Interbank Offered Rate (LIBOR) benchmark settings based on a modified calculation (i.e., on a “synthetic” basis), British Pound Sterling, Euro, Swiss Franc and Japanese Yen LIBOR settings and one-week and two-month U.S. dollar (USD) LIBOR settings ceased or became no longer representative of the underlying market the rates seek to measure (i.e., non-representative) immediately after December 31, 2021, centraland the remaining USD LIBOR settings (i.e., overnight, one month, three month, six month and 12 month) will cease or become non-representative immediately after June 30, 2023. Separately, the Federal Reserve, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) issued supervisory guidance encouraging banks to cease entering into new contracts that use USD LIBOR as a reference rate by December 31, 2021 subject to certain regulatory-approved exceptions (USD LIBOR Guidance).
As a result, a major transition has been and regulators aroundcontinues to be in progress in the world have commissioned working groupsglobal financial markets with respect to find suitable replacements forthe replacement of Interbank Offered Rates (IBOR), including LIBOR, and other benchmark rates and to implement financial benchmark reforms more generally. The future discontinuance of IBORs(IBORs). This is a complex process that has resulted in significant uncertainty regarding the transition to suitable alternative reference rates (ARRs) and could cause disruptions inimpacting a variety of global financial markets, as well as adversely impact our business, operationsbusinesses and financial results.
operations. IBORs including LIBOR, arehave historically been used in many of the Corporation’s products and contracts, including mortgages,derivatives, consumer and commercial and corporate loans, derivatives,mortgages, floating-rate notes and other adjustable-rate products and financial instruments. In response, the Corporation established an enterprise-wide IBOR transition program, with active involvement of senior management and regular reports to the Management Risk Committee (MRC) and Enterprise Risk Committee (ERC). The aggregate notional amountprogram continues to drive the Corporation's industry and regulatory engagement, client and financial contract changes, internal and external communications, technology and operations modifications, including updates to its operational models, systems and processes, introduction of thesenew products, migration of existing clients, and contracts is material to our business. program strategy and governance.
As previously disclosed, to facilitate an orderly transition from IBORs and other benchmark rates to ARRs,of December 31, 2021, the Corporation has established an enterprise-wide initiative led by senior management. As part of this initiative, the Corporation continues to identify, assess and monitor risks associated with the expected discontinuationtransitioned or unavailability of LIBOR and other benchmarks and evaluate and address documentation and contractual mechanics of outstandingotherwise addressed IBOR-based products and contracts referencing the rates that matureceased or became non-representative after December 31, 2021, including LIBOR-linked commercial loans, LIBOR-based adjustable-rate consumer mortgages, LIBOR-linked derivatives and interdealer trading of certain USD LIBOR and other interest rate swaps, and related hedging
27 Bank of America


arrangements. Additionally, in accordance with the USD LIBOR Guidance, the Corporation has ceased entering into new contracts that use USD LIBOR as a reference rate, subject to certain regulatory-approved exceptions.
The Corporation launched capabilities and potential future ARR-basedservices to support the issuance and trading in products indexed to various alternative reference rates (ARRs) and 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 has presented and continues to present. The Corporation continues to monitor a variety of market scenarios as part of its transition efforts, including risks associated with insufficient preparation by individual market participants or the overall market ecosystem, ability of market participants to meet regulatory and industry-wide recommended milestones and access and demand by clients and market participants to liquidity in certain products, including LIBOR products.
With respect to the transition of LIBOR products referencing USD LIBOR settings ceasing or becoming non-representative as of June 30, 2023, a significant majority of the Corporation’s notional contractual exposure to such LIBOR currencies, of which the significant majority is derivatives contracts, have been remediated (i.e., updated to achieve operational readiness. Additionally,include fallback provisions to ARRs based on market driven protocols, regulatory guidance and industry-recommended fallback provisions and related mechanisms) and the Corporation is continuing to evaluate potentialremediate the remaining USD LIBOR exposure. The remaining exposure, a majority of which is made up of derivatives and commercial loans and which represents a small minority of outstanding USD LIBOR notional contractual exposure of the Corporation, will require active dialogue with clients to modify the contracts. For any residual exposures after June 2023 that continue to have no fallback provisions, the Corporation is assessing and planning to leverage relevant contractual and statutory solutions, including relevant state legislation and any future federal legislation, to transition such exposure to ARRs.
The Corporation has implemented regulatory, tax and accounting changes and continues to monitor current and potential impacts of the transition, including guidance published and/or proposed by the Internal Revenue Service tax regulations and guidance and Financial Accounting Standards Board engageguidance. In addition, the Corporation has engaged impacted clients in connection with the transition toby providing ARRs education and workthe timing of transition events. The Corporation is also working actively with global regulators, industry working groups and trade associations to develop strategies for an effective transition to ARRs.
The Corporation is also modifying its operational models, systems, procedures and internal infrastructure to transition to ARRs. In 2019, the Corporation launched capabilities to support issuance and trading in products indexed to the new Secured Overnight Financing Rate (SOFR), which is the alternative benchmark rate to U.S. dollar LIBOR recommended by the Alternative Reference Rates Committee, a group of private-market participants and official-sector entities convened by the Board of Governors of the Federal Reserve System (Federal Reserve) and the Federal Reserve Bank of New York, and a broad measure of the cost of borrowing cash overnight collateralized by U.S. Treasury securities. Also, in 2019, the Corporation issued debt linked to SOFR, and the Corporation co-arranged one of the first credit facilities linked to SOFR and has implemented fallback provisions into certain new IBOR-based products and contracts. The Corporation continues to monitor the development and usage of ARRs, including SOFR.associations. For more information on the expected replacement of LIBOR and other benchmark rates, see Item 1A. Risk Factors - Other on page 17.21.


23Bank of America






Financial HighlightsChanges to Overdraft Services
In January 2022, the Corporation announced changes to its overdraft services for consumer and small business clients, which include eliminating non-sufficient funds (NSF) fees beginning in February 2022 and reducing overdraft fees from $35 to $10 beginning in May 2022. Fees from overdraft services were approximately $1 billion in 2021 and recorded in Consumer Banking as service charges in the Consolidated Statement of Income, amounts relatedIncome. Due to certain assetthe policy changes, in 2022 the Corporation expects a significant reduction in NSF and liability management (ALM) activities have been reclassified from other income to market making and similar activities, which was previously referred to as trading account income. All prior periods presented reflect this change, which has no impactoverdraft fees.



Financial Highlights
Table 1Summary Income Statement and Selected Financial Data
(Dollars in millions, except per share information)20212020
Income statement
Net interest income$42,934 $43,360 
Noninterest income46,179 42,168 
Total revenue, net of interest expense89,113 85,528 
Provision for credit losses(4,594)11,320 
Noninterest expense59,731 55,213 
Income before income taxes33,976 18,995 
Income tax expense1,998 1,101 
Net income31,978 17,894 
Preferred stock dividends1,421 1,421 
Net income applicable to common shareholders$30,557 $16,473 
Per common share information  
Earnings$3.60 $1.88 
Diluted earnings3.57 1.87 
Dividends paid0.78 0.72 
Performance ratios
Return on average assets (1)
1.05 %0.67 %
Return on average common shareholders’ equity (1)
12.23 6.76 
Return on average tangible common shareholders’ equity (2)
17.02 9.48 
Efficiency ratio (1)
67.03 64.55 
Balance sheet at year end  
Total loans and leases$979,124 $927,861 
Total assets3,169,495 2,819,627 
Total deposits2,064,446 1,795,480 
Total liabilities2,899,429 2,546,703 
Total common shareholders’ equity245,358 248,414 
Total shareholders’ equity270,066 272,924 
(1)For definitions, see Key Metrics on the Corporation's total noninterest income or net income, and has no impactpage 169.
(2)Return on business segment results.average tangible common shareholders’ equity is a non-GAAP financial measure. For more information see Note 1 – Summary of Significant Accounting Principles and a corresponding reconciliation to the Consolidated Financial Statements.most closely related financial measures defined by accounting principles generally accepted in the United States of America (GAAP), see Non-GAAP Reconciliations on page 85.
     
Table 1Summary Income Statement and Selected Financial Data
     
(Dollars in millions, except per share information)2019 2018
Income statement   
Net interest income$48,891
 $48,162
Noninterest income42,353
 42,858
Total revenue, net of interest expense91,244

91,020
Provision for credit losses3,590
 3,282
Noninterest expense54,900
 53,154
Income before income taxes32,754

34,584
Income tax expense5,324
 6,437
Net income27,430

28,147
Preferred stock dividends1,432
 1,451
Net income applicable to common shareholders$25,998

$26,696
     
Per common share information   
Earnings$2.77
 $2.64
Diluted earnings2.75
 2.61
Dividends paid0.66
 0.54
Performance ratios   
Return on average assets1.14% 1.21%
Return on average common shareholders’ equity10.62
 11.04
Return on average tangible common shareholders’ equity (1)
14.86
 15.55
Efficiency ratio60.17
 58.40
Balance sheet at year end 
  
Total loans and leases$983,426
 $946,895
Total assets2,434,079
 2,354,507
Total deposits1,434,803
 1,381,476
Total liabilities2,169,269
 2,089,182
Total common shareholders’ equity241,409
 242,999
Total shareholders’ equity264,810
 265,325
(1)
Return on average tangible common shareholders’ equity is a non-GAAP financial measure. For more information and a corresponding reconciliation to the most closely related financial measures defined by accounting principles generally accepted in the United States of America, see Non-GAAP Reconciliations on page 80.
Net income was $27.4$32.0 billion or $2.75$3.57 per diluted share in 20192021 compared to $28.1$17.9 billion or $2.61$1.87 per diluted share in 2018.2020. The decreaseincrease in net income was primarily driven by an increasedue to improvement in noninterest expense as a result of the $2.1 billion pretax impairment charge related to the notice of termination of the merchant services joint venture at the conclusion of its current term. Also contributing to the decrease in net income were higher provision for credit losses and lower noninterest income,higher revenue, partially offset by an increase in net interest income.higher noninterest expense.
For discussion and analysis of our consolidated and business segment results of operations for 20182020 compared to 2017,2019, see
the Financial Highlights and Business Segment Operations sections in the MD&A of the Corporation's 20182020 Annual Report on Form 10-K.
Net Interest Income
Net interest income increased $729decreased $426 million to $48.9$42.9 billion in 20192021 compared 2018.to 2020. Net interest yield on a fully taxable-equivalent (FTE) basis decreased two24 basis points (bps) to 2.431.66 percent for 2019.2021. The increasedecrease in net interest income was primarily driven by lower interest rates and average loan and deposit growth,balances, partially offset by lower long-end rates. Assuming a stable economic and interest rate environment compared to December 31, 2019, we expect quarterly net interest income for the first two quartershigher average balances of 2020 to be lower compared to the fourth quarter of 2019 driven by the impact of rates and one fewer day of interest accruals. Quarterly net interest income is expected to rise modestly in the second half of 2020 due to one additional day of interest accruals and expected loan and deposit growth.debt securities. For more information on net interest yield and the FTE basis, see Supplemental Financial Data on page 27,31, and for more information on interest rate risk management, see Interest Rate Risk Management for the Banking Book on page 74.79.






Bank of America 28


Noninterest Income
    
Table 2Noninterest Income   Table 2Noninterest Income
    
(Dollars in millions)(Dollars in millions)2019 2018(Dollars in millions)20212020
Fees and commissions:Fees and commissions:   Fees and commissions:
Card incomeCard income$5,797
 $5,824
Card income$6,218 $5,656 
Service chargesService charges7,674
 7,767
Service charges7,504 7,141 
Investment and brokerage servicesInvestment and brokerage services13,902
 14,160
Investment and brokerage services16,690 14,574 
Investment banking feesInvestment banking fees5,642
 5,327
Investment banking fees8,887 7,180 
Total fees and commissionsTotal fees and commissions33,015
 33,078
Total fees and commissions39,299 34,551 
Market making and similar activitiesMarket making and similar activities9,034
 9,008
Market making and similar activities8,691 8,355 
Other incomeOther income304
 772
Other income(1,811)(738)
Total noninterest incomeTotal noninterest income$42,353

$42,858
Total noninterest income$46,179 $42,168 
Noninterest income decreased $505 millionincreased $4.0 billion to $42.4$46.2 billion in 20192021 compared to 2018.2020. The following highlights the significant changes.
Service charges decreased $93 million primarily driven by lower fees due to policy changes in 2018 and lower ATM volume in Consumer Banking.
    Card income increased $562 million primarily driven by increased client activity and merchant services revenue.
    Service charges increased$363 million primarily due to higher treasury and credit service charges and increased client activity.
●    Investment and brokerage services increased $2.1 billion primarily driven by higher market valuations and assets under management (AUM) flows, partially offset by declines in AUM pricing.
    Investment banking fees increased $1.7 billion primarily due to higher advisory fees as well as higher debt and equity issuance fees.
    Market making and similar activities increased $336 million primarily driven by strong sales and trading performance in Equities, partially offset by a weaker performance in Fixed Income, Currencies and Commodities (FICC), which benefited from a more favorable market environment in 2020.
    Other income decreased $1.1 billion primarily due to a $704 million gain on sales of certain mortgage loans in the prior year, as well as higher partnership losses on tax credit investments.
Investment and brokerage services income decreased $258 million primarily due to lower transactional revenue and a decrease in assets under management (AUM) pricing, partially offset by the positive impact of AUM flows and higher market valuations.
Investment banking fees increased $315 million due to increases in advisory fees and equity and debt underwriting fees.
Other income decreased$468 million primarily due to lower gains on sales of non-core consumer loans and higher partnership losses associated with an increase in tax-advantaged investments, partially offset by higher gains on sales of debt securities.


Bank of America 24


Provision for Credit Losses
The provision for credit losses increased $308 millionimproved $15.9 billion to $3.6a benefit of $4.6 billion in 20192021 compared to 2018.2020. The increasebenefit was primarily due to the energy reserve releasesimprovements in the commercial portfolio in 2018, partially offset by the impact of recoveries recorded in connection with sales of previously charged-off non-core consumer real estate loans.macroeconomic outlook and credit quality. For more information on the provision for credit losses, see ProvisionAllowance for Credit Losses on page 68.73.
Noninterest Expense
    
Table 3Noninterest Expense   Table 3Noninterest Expense
    
(Dollars in millions)(Dollars in millions)2019 2018(Dollars in millions)20212020
Compensation and benefitsCompensation and benefits$31,977
 $31,880
Compensation and benefits$36,140 $32,725 
Occupancy and equipmentOccupancy and equipment6,588
 6,380
Occupancy and equipment7,138 7,141 
Information processing and communicationsInformation processing and communications4,646
 4,555
Information processing and communications5,769 5,222 
Product delivery and transaction relatedProduct delivery and transaction related2,762
 2,857
Product delivery and transaction related3,881 3,433 
MarketingMarketing1,934
 1,674
Marketing1,939 1,701 
Professional feesProfessional fees1,597
 1,699
Professional fees1,775 1,694 
Other general operatingOther general operating5,396
 4,109
Other general operating3,089 3,297 
Total noninterest expenseTotal noninterest expense$54,900

$53,154
Total noninterest expense$59,731 $55,213 
Noninterest expense increased$1.7 $4.5 billion to $54.9$59.7 billion in 20192021 compared to 2018.2020. The increase was primarily due to the
aforementioned impairment charge related to our merchant services joint venture of $2.1 billion as well as increasedhigher compensation and benefits expense, higher costs associated with investment inprocessing transactional card claims related to state unemployment benefits, a contribution to the businesses, including brand-related marketing costs,Bank of America Foundation and higher litigation expense. These were partially offset by efficiency savings, lower Federal Deposit Insurance Corporation (FDIC) expense and lower amortization of intangibles expense.an impairment charge for real estate rationalization.
Income Tax Expense
    
Table 4Income Tax Expense   Table 4Income Tax Expense
    
(Dollars in millions)(Dollars in millions)2019 2018(Dollars in millions)20212020
Income before income taxesIncome before income taxes$32,754
 $34,584
Income before income taxes$33,976 $18,995 
Income tax expenseIncome tax expense5,324
 6,437
Income tax expense1,998 1,101 
Effective tax rateEffective tax rate16.3%
18.6%Effective tax rate5.9 %5.8 %
Income tax expense was $2.0 billion for 2021 compared to $1.1 billion in 2020, resulting in an effective tax rate of 5.9 percent compared to 5.8 percent.
The effective tax rates for 20192021 and 2018 reflect2020 were driven by the impact of our recurring tax preference benefits. The 2019 effective rate also included netbenefits and positive income tax adjustments from the impact of U.K. tax law changes discussed below. Our recurring tax preference benefits primarily relatedconsist 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. Absent these tax credits, the resolutionimpact of variousthe U.K. tax controversy matters.
We expectlaw changes and other discrete items, the effective tax rates would have been approximately 25 percent and 26 percent for 2021 and 2020.
In June 2021, the U.K. enacted the 2021 Finance Act, which included an increase in the U.K. corporation income tax rate to 25 percent from 19 percent. This change is effective April 1, 2023 and unfavorably affects income tax expense on future U.K. earnings. In addition, in July 2020, the U.K. enacted a repeal of the final two percent of scheduled decreases in the U.K. corporation income tax rate. As a result, in 2021 and 2020, the Corporation recorded write-ups of U.K. net deferred tax assets of approximately $2.0 billion and $700 million, with corresponding positive income tax adjustments. These write-ups were reversals of previously recorded write-downs of net deferred tax assets for 2020 to be approximately 18 percent, absent unusual items.prior changes in the U.K. corporation income tax rate.

29 Bank of America


Balance Sheet Overview
      
Table 5Selected Balance Sheet Data     Table 5Selected Balance Sheet Data
      
 December 31   December 31
(Dollars in millions)(Dollars in millions)2019 2018 % Change(Dollars in millions)20212020$ Change% Change
AssetsAssets 
  
  Assets  
Cash and cash equivalentsCash and cash equivalents$161,560
 $177,404
 (9)%Cash and cash equivalents$348,221 $380,463 $(32,242)(8)%
Federal funds sold and securities borrowed or purchased under agreements to resellFederal funds sold and securities borrowed or purchased under agreements to resell274,597
 261,131
 5
Federal funds sold and securities borrowed or purchased under agreements to resell250,720 304,058 (53,338)(18)
Trading account assetsTrading account assets229,826
 214,348
 7
Trading account assets247,080 198,854 48,226 24 
Debt securitiesDebt securities472,197
 441,753
 7
Debt securities982,627 684,850 297,777 43 
Loans and leasesLoans and leases983,426
 946,895
 4
Loans and leases979,124 927,861 51,263 
Allowance for loan and lease lossesAllowance for loan and lease losses(9,416) (9,601) (2)Allowance for loan and lease losses(12,387)(18,802)6,415 (34)
All other assetsAll other assets321,889
 322,577
 
All other assets374,110 342,343 31,767 
Total assetsTotal assets$2,434,079
 $2,354,507
 3
Total assets$3,169,495 $2,819,627 $349,868 12 
LiabilitiesLiabilities     Liabilities
DepositsDeposits$1,434,803
 $1,381,476
 4
Deposits$2,064,446 $1,795,480 $268,966 15 
Federal funds purchased and securities loaned or sold under agreements to repurchaseFederal funds purchased and securities loaned or sold under agreements to repurchase165,109
 186,988
 (12)Federal funds purchased and securities loaned or sold under agreements to repurchase192,329 170,323 22,006 13 
Trading account liabilitiesTrading account liabilities83,270
 68,220
 22
Trading account liabilities100,690 71,320 29,370 41 
Short-term borrowingsShort-term borrowings24,204
 20,189
 20
Short-term borrowings23,753 19,321 4,432 23 
Long-term debtLong-term debt240,856
 229,392
 5
Long-term debt280,117 262,934 17,183 
All other liabilitiesAll other liabilities221,027
 202,917
 9
All other liabilities238,094 227,325 10,769 
Total liabilitiesTotal liabilities2,169,269
 2,089,182
 4
Total liabilities2,899,429 2,546,703 352,726 14 
Shareholders’ equityShareholders’ equity264,810
 265,325
 
Shareholders’ equity270,066 272,924 (2,858)(1)
Total liabilities and shareholders’ equityTotal liabilities and shareholders’ equity$2,434,079
 $2,354,507
 3
Total liabilities and shareholders’ equity$3,169,495 $2,819,627 $349,868 12 
Assets
At December 31, 2019,2021, total assets were approximately $2.4$3.2 trillion, up $79.6$349.9 billion from December 31, 2018.2020. The increase in assets was primarily due to higher debt securities that were primarily funded by deposit growth, an increase in loans and leases and debthigher trading account assets, partially offset by lower federal funds sold and securities primarily funded by deposit growth.borrowed or purchased under agreements to resell and cash and cash equivalents.
Cash and Cash Equivalents
Cash and cash equivalents decreased $15.8$32.2 billion primarily driven by investment of short-term excess cash into securities purchased under agreements to resell,higher investments in debt securities and growth in loans and leases.
Federal Funds Sold and Securities Borrowed or Purchased Under Agreements to Resell
Federal funds transactions involve lending reserve balances on a short-term basis. Securities borrowed or purchased under agreements to resell are collateralized lending transactions utilized to accommodate customer transactions, earn interest rate spreads and obtain securities for settlement and for collateral. Federal funds sold and securities borrowed or purchased under agreements to resell increased $13.5decreased $53.3 billion primarily due to the investment of excess cash levels.into debt securities.

25Bank of America






Trading Account Assets
Trading account assets consist primarily of long positions in equity and fixed-income securities including U.S. government and agency securities, corporate securities and non-U.S. sovereign debt. Trading account assets increased $15.5$48.2 billion primarily driven by additionaldue to an increase in inventory inwithin Global Markets to facilitate client demand..
Debt Securities
Debt securities primarily include U.S. Treasury and agency securities, mortgage-backed securities (MBS), principally agency MBS, non-U.S. bonds, corporate bonds and municipal debt. We use the debt securities portfolio primarily to manage interest rate and liquidity risk and to take advantage ofleverage market conditions that create economically attractive returns on these investments. Debt securities increased $30.4$297.8 billion primarily driven by the deployment of deposit inflows. For more information on debt
securities, see Note 4 – Securities to the Consolidated Financial Statements.
Loans and Leases
Loans and leases increased $36.5$51.3 billion primarily due to net loan growth driven by client demand forgrowth in commercial loans and increases in residential mortgage.higher securities-based lending within consumer loans. For more information on the loan portfolio, see Credit Risk Management on page 53.59.
Allowance for Loan and Lease Losses
The allowance for loan and lease losses decreased $185 million$6.4 billion primarily due to the impact of improvements in the macroeconomic outlook and credit quality from a stronger economy and continued runoff and sales in the non-core consumer real estate portfolio.quality. For more information, see Allowance for Credit Losses on page 68.73.
All Other Assets
All other assets increased $31.8 billion primarily driven by higher margin loans and loans held-for-sale (LHFS).
Liabilities
At December 31, 2019,2021, total liabilities were approximately $2.2$2.9 trillion, up $80.1$352.7 billion from December 31, 2018,2020, primarily due to deposit growth.
Deposits
Deposits increased $53.3$269.0 billion primarily due to increasesan increase in both retail and wholesale deposits.
Federal Funds Purchased and Securities Loaned or Sold Under Agreements to Repurchase
Federal funds transactions involve borrowing reserve balances on a short-term basis. Securities loaned or sold under agreements to repurchase are collateralized borrowing transactions utilized to accommodate customer transactions, earn interest rate spreads and finance assets on the balance sheet. Federal funds purchased and securities loaned or sold under agreements to repurchase decreased $21.9increased $22.0 billion primarily driven by balance sheet efficienciesclient 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
Bank of America 30


debt. Trading account liabilities increased $15.1$29.4 billion primarily due to higher levels of short positions in government and corporate bonds driven by client demand within Global Markets.
Short-term Borrowings
Short-term borrowings provide an additional funding source and primarily consist of Federal Home Loan Bank (FHLB) short-term borrowings, notes payable and various other borrowings that generally have maturities of one year or less. Short-term borrowings increased $4.0$4.4 billion primarily due to an increase in short-term FHLB advancescommercial paper issuances to manage liquidity needs. For more information on short-term borrowings, see Note 1110 Federal Funds Sold or Purchased, Securities Financing Agreements, Short-term Borrowings and Restricted Cash to the Consolidated Financial Statements.
Long-term Debt
Long-term debt increased $11.5$17.2 billion primarily driven bydue to debt issuances, and valuation adjustments, partially offset by maturities, redemptions and redemptions.valuation adjustments. For more information on long-term debt, see Note 1211 – Long-term Debt to the Consolidated Financial Statements.
All Other Liabilities
All other liabilities increased $18.1 billion primarily driven by an increase in broker-dealer payables within Global Markets due to timing of unsettled trades and an increase in lease liabilities due to implementation of the new lease accounting standard.
Shareholders’ Equity
Shareholders’ equity decreased $515 million driven by$2.9 billion primarily due to returns of capital to shareholders through sharecommon stock repurchases and common and preferred stock dividends, of $35.7 billion, as well asmarket value decreases on derivatives and debt securities and the redemption of preferred stock, largelypartially offset by earnings, market value increases on debt securities and issuances of preferred stock.net income.
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, long-term debt and long-term debt.common and preferred stock. For more information on liquidity, see Liquidity Risk on page 50.
54.



Bank of America 26


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 accounting principles generally accepted in the United States of America (GAAP).GAAP. Non-GAAP financial measures are provided as additional useful information to assess our financial condition, results of operations (including period-to-period operating performance) or compliance with prospective regulatory requirements. These non-GAAP financial measures are not intended as a substitute for GAAP financial measures and may not be defined or calculated the same way as non-GAAP financial measures used by other companies.
We view net interest income and related ratios and analyses on an FTE basis, which when presented on a consolidated basis are non-GAAP financial measures. To derive the FTE basis, net interest income is adjusted to reflect tax-exempt income on an equivalent before-tax basis with a corresponding increase in income tax expense. For purposes of this calculation, we use the federal statutory tax rate of 21 percent for 2019 and 2018 (35 percent for 2017) and a representative state tax rate. Net interest yield, which measures the basis points we earn over the cost of funds, utilizes net interest income on an FTE basis. We believe that presentation of these items on an FTE basis allows for comparison of amounts from
both taxable and tax-exempt sources and is consistent with industry practices.
We may present certain key performance indicators and ratios excluding certain items (e.g., debit valuation adjustment (DVA) gains (losses)) which result in non-GAAP financial measures. We believe that the presentation of measures that exclude these items
is useful because such measures provide additional information to assess the underlying operational performance and trends of our businesses and to allow better comparison of period-to-period operating performance.
We also evaluate our business based on certain ratios that utilize tangible equity, a non-GAAP financial measure. Tangible equity represents shareholders’ equity or common shareholders’
equity reduced by goodwill and intangible assets (excluding mortgage servicing rights (MSRs)), net of related deferred tax liabilities ("adjusted" shareholders'(“adjusted” shareholders’ equity or common shareholders'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 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.
    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 6 and 7.
For more information on the reconciliation of these non-GAAP financial measures to the corresponding GAAP financial measures, see Non-GAAP Reconciliations on page 80.85.
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 169.
Our consolidated key performance indicators, which include various equity and credit metrics, are presented in Table 1 on page 28, Table 6 on page 32 and Table 7 on page 33.
For information on key segment performance metrics, see Business Segment Operations on page 36.


27Bank of America






           
Table 6Five-year Summary of Selected Financial Data         
           
(In millions, except per share information)2019 2018 2017 2016 2015
Income statement     
  
  
Net interest income$48,891
 $48,162
 $45,239
 $41,486
 $38,958
Noninterest income42,353
 42,858
 41,887
 42,012
 44,007
Total revenue, net of interest expense91,244
 91,020
 87,126
 83,498
 82,965
Provision for credit losses3,590
 3,282
 3,396
 3,597
 3,161
Noninterest expense54,900
 53,154
 54,517
 54,880
 57,617
Income before income taxes32,754
 34,584
 29,213
 25,021
 22,187
Income tax expense5,324
 6,437
 10,981
 7,199
 6,277
Net income27,430
 28,147
 18,232
 17,822
 15,910
Net income applicable to common shareholders25,998
 26,696
 16,618
 16,140
 14,427
Average common shares issued and outstanding9,390.5
 10,096.5
 10,195.6
 10,248.1
 10,462.3
Average diluted common shares issued and outstanding9,442.9
 10,236.9
 10,778.4
 11,046.8
 11,236.2
Performance ratios 
  
  
  
  
Return on average assets1.14% 1.21% 0.80% 0.81% 0.74%
Return on average common shareholders’ equity10.62
 11.04
 6.72
 6.69
 6.28
Return on average tangible common shareholders’ equity (1)
14.86
 15.55
 9.41
 9.51
 9.16
Return on average shareholders’ equity10.24
 10.63
 6.72
 6.70
 6.33
Return on average tangible shareholders’ equity (1)
13.85
 14.46
 9.08
 9.17
 8.88
Total ending equity to total ending assets10.88
 11.27
 11.71
 12.17
 11.92
Total average equity to total average assets11.14
 11.39
 11.96
 12.14
 11.64
Dividend payout23.65
 20.31
 24.24
 15.94
 14.49
Per common share data 
  
  
  
  
Earnings$2.77
 $2.64
 $1.63
 $1.57
 $1.38
Diluted earnings2.75
 2.61
 1.56
 1.49
 1.31
Dividends paid0.66
 0.54
 0.39
 0.25
 0.20
Book value27.32
 25.13
 23.80
 23.97
 22.48
Tangible book value (1)
19.41
 17.91
 16.96
 16.89
 15.56
Market capitalization$311,209
 $238,251
 $303,681
 $222,163
 $174,700
Average balance sheet 
  
  
  
  
Total loans and leases$958,416
 $933,049
 $918,731
 $900,433
 $876,787
Total assets2,405,830
 2,325,246
 2,268,633
 2,190,218
 2,160,536
Total deposits1,380,326
 1,314,941
 1,269,796
 1,222,561
 1,155,860
Long-term debt201,623
 200,399
 194,882
 204,826
 240,059
Common shareholders’ equity244,853
 241,799
 247,101
 241,187
 229,576
Total shareholders’ equity267,889
 264,748
 271,289
 265,843
 251,384
Asset quality (2)��
 
  
  
    
Allowance for credit losses (3)
$10,229
 $10,398
 $11,170
 $11,999
 $12,880
Nonperforming loans, leases and foreclosed properties (4)
3,837
 5,244
 6,758
 8,084
 9,836
Allowance for loan and lease losses as a percentage of total loans and leases outstanding (4)
0.97% 1.02% 1.12% 1.26% 1.37%
Allowance for loan and lease losses as a percentage of total nonperforming loans and leases (4)
265
 194
 161
 149
 130
Net charge-offs$3,648
 $3,763
 $3,979
 $3,821
 $4,338
Net charge-offs as a percentage of average loans and leases outstanding (4)
0.38% 0.41% 0.44% 0.43% 0.50%
Capital ratios at year end (5)
 
  
  
  
  
Common equity tier 1 capital11.2% 11.6% 11.5% 10.8% 9.8%
Tier 1 capital12.6
 13.2
 13.0
 12.4
 11.2
Total capital14.7
 15.1
 14.8
 14.2
 12.8
Tier 1 leverage7.9
 8.4
 8.6
 8.8
 8.4
Supplementary leverage ratio6.4
 6.8
 n/a
 n/a
 n/a
Tangible equity (1)
8.2
 8.6
 8.9
 9.2
 8.9
Tangible common equity (1)
7.3
 7.6
 7.9
 8.0
 7.8
(1)
Tangible equity ratios and tangible book value per share of common stock are non-GAAP financial measures. For more information on these ratios and corresponding reconciliations to GAAP financial measures, see Supplemental Financial Data on page 27 and Non-GAAP Reconciliations on page 80.
(2)
Asset quality metrics include $75 million of non-U.S. consumer credit card net charge-offs in 2017 and $243 million of non-U.S. consumer credit card allowance for loan and lease losses, $9.2 billion of non-U.S. consumer credit card loans and $175 million of non-U.S. consumer credit card net charge-offs in 2016. The non-U.S. consumer credit card business was sold in 2017.
(3)
Includes the allowance for loan and leases 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 59 and corresponding Table 29 and Commercial Portfolio Credit Risk Management – Nonperforming Commercial Loans, Leases and Foreclosed Properties Activity on page 63 and corresponding Table 36.
(5)
Basel 3 transition provisions for regulatory capital adjustments and deductions were fully phased-in as of January 1, 2018. Prior periods are presented on a fully phased-in basis. For more information, including which approach is used to assess capital adequacy, see Capital Management on page 45.
n/a = not applicable


Bank of America 28


                 
Table 7Selected Quarterly Financial Data            
                 
  2019 Quarters 2018 Quarters
(In millions, except per share information)Fourth Third Second First Fourth Third Second First
Income statement     
    
      
Net interest income$12,140
 $12,187
 $12,189
 $12,375
 $12,504
 $12,061
 $11,828
 $11,769
Noninterest income10,209
 10,620
 10,895
 10,629
 10,173
 10,663
 10,721
 11,301
Total revenue, net of interest expense22,349
 22,807
 23,084
 23,004
 22,677
 22,724
 22,549
 23,070
Provision for credit losses941
 779
 857
 1,013
 905
 716
 827
 834
Noninterest expense13,239
 15,169
 13,268
 13,224
 13,074
 13,014
 13,224
 13,842
Income before income taxes8,169
 6,859
 8,959
 8,767
 8,698
 8,994
 8,498
 8,394
Income tax expense1,175
 1,082
 1,611
 1,456
 1,420
 1,827
 1,714
 1,476
Net income6,994
 5,777
 7,348
 7,311
 7,278
 7,167
 6,784
 6,918
Net income applicable to common shareholders6,748
 5,272
 7,109
 6,869
 7,039
 6,701
 6,466
 6,490
Average common shares issued and outstanding9,017.1
 9,303.6
 9,523.2
 9,725.9
 9,855.8
 10,031.6
 10,181.7
 10,322.4
Average diluted common shares issued and outstanding9,079.5
 9,353.0
 9,559.6
 9,787.3
 9,996.0
 10,170.8
 10,309.4
 10,472.7
Performance ratios 
  
  
  
  
      
Return on average assets1.13% 0.95% 1.23% 1.26% 1.24% 1.23% 1.17% 1.21%
Four-quarter trailing return on average assets (1)
1.14
 1.17
 1.24
 1.22
 1.21
 1.00
 0.93
 0.86
Return on average common shareholders’ equity11.00
 8.48
 11.62
 11.42
 11.57
 10.99
 10.75
 10.85
Return on average tangible common shareholders’ equity (2)
15.43
 11.84
 16.24
 16.01
 16.29
 15.48
 15.15
 15.26
Return on average shareholders’ equity10.40
 8.48
 11.00
 11.14
 10.95
 10.74
 10.26
 10.57
Return on average tangible shareholders’ equity (2)
14.09
 11.43
 14.88
 15.10
 14.90
 14.61
 13.95
 14.37
Total ending equity to total ending assets10.88
 11.06
 11.33
 11.23
 11.27
 11.21
 11.53
 11.43
Total average equity to total average assets10.89
 11.21
 11.17
 11.28
 11.30
 11.42
 11.42
 11.41
Dividend payout23.90
 31.48
 19.95
 21.20
 20.90
 22.35
 18.83
 19.06
Per common share data 
  
  
  
  
      
Earnings$0.75
 $0.57
 $0.75
 $0.71
 $0.71
 $0.67
 $0.64
 $0.63
Diluted earnings0.74
 0.56
 0.74
 0.70
 0.70
 0.66
 0.63
 0.62
Dividends paid0.18
 0.18
 0.15
 0.15
 0.15
 0.15
 0.12
 0.12
Book value27.32
 26.96
 26.41
 25.57
 25.13
 24.33
 24.07
 23.74
Tangible book value (2)
19.41
 19.26
 18.92
 18.26
 17.91
 17.23
 17.07
 16.84
Market capitalization$311,209
 $264,842
 $270,935
 $263,992
 $238,251
 $290,424
 $282,259
 $305,176
Average balance sheet 
  
  
  
  
      
Total loans and leases$973,986
 $964,733
 $950,525
 $944,020
 $934,721
 $930,736
 $934,818
 $931,915
Total assets2,450,005
 2,412,223
 2,399,051
 2,360,992
 2,334,586
 2,317,829
 2,322,678
 2,325,878
Total deposits1,410,439
 1,375,052
 1,375,450
 1,359,864
 1,344,951
 1,316,345
 1,300,659
 1,297,268
Long-term debt206,026
 202,620
 201,007
 196,726
 201,056
 203,239
 199,448
 197,787
Common shareholders’ equity243,439
 246,630
 245,438
 243,891
 241,372
 241,812
 241,313
 242,713
Total shareholders’ equity266,900
 270,430
 267,975
 266,217
 263,698
 264,653
 265,181
 265,480
Asset quality 
  
  
  
  
      
Allowance for credit losses (3)
$10,229
 $10,242
 $10,333
 $10,379
 $10,398
 $10,526
 $10,837
 $11,042
Nonperforming loans, leases and foreclosed properties (4)
3,837
 3,723
 4,452
 5,145
 5,244
 5,449
 6,181
 6,694
Allowance for loan and lease losses as a percentage of total loans and leases outstanding (4)
0.97% 0.98% 1.00% 1.02% 1.02% 1.05% 1.08% 1.11%
Allowance for loan and lease losses as a percentage of total nonperforming loans and leases (4)
265
 271
 228
 197
 194
 189
 170
 161
Net charge-offs$959
 $811
 $887
 $991
 $924
 $932
 $996
 $911
Annualized net charge-offs as a percentage of average loans and leases outstanding (4)
0.39% 0.34% 0.38% 0.43% 0.39% 0.40% 0.43% 0.40%
Capital ratios at period end 
  
  
  
  
      
Common equity tier 1 capital11.2% 11.4% 11.7% 11.6% 11.6% 11.4% 11.4% 11.3%
Tier 1 capital12.6
 12.9
 13.3
 13.1
 13.2
 12.9
 13.0
 13.0
Total capital14.7
 15.1
 15.4
 15.2
 15.1
 14.7
 14.8
 14.8
Tier 1 leverage7.9
 8.2
 8.4
 8.4
 8.4
 8.3
 8.4
 8.4
Supplementary leverage ratio6.4
 6.6
 6.8
 6.8
 6.8
 6.7
 6.7
 6.8
Tangible equity (2)
8.2
 8.4
 8.7
 8.5
 8.6
 8.5
 8.7
 8.7
Tangible common equity (2)
7.3
 7.4
 7.6
 7.6
 7.6
 7.5
 7.7
 7.6
Total loss-absorbing capacity and long-term debt metrics (5)
               
Total loss-absorbing capacity to risk-weighted assets24.6% 24.8% 25.5% 24.8%        
Total loss-absorbing capacity to supplementary leverage exposure12.5
 12.7
 13.0
 12.8
        
Eligible long-term debt to risk-weighted assets11.5
 11.4
 11.8
 11.4
        
Eligible long-term debt to supplementary leverage exposure5.8
 5.8
 6.0
 5.9
        
(1)
Calculated as total net income for four consecutive quarters divided by annualized average assets for four consecutive quarters.
(2)
Tangible equity ratios and tangible book value per share of common stock are non-GAAP financial measures. For more information on these ratios and corresponding reconciliations to GAAP financial measures, see Supplemental Financial Data on page 27 and Non-GAAP Reconciliations on page 80.
(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 59 and corresponding Table 29 and Commercial Portfolio Credit Risk Management – Nonperforming Commercial Loans, Leases and Foreclosed Properties Activity on page 63 and corresponding Table 36.
(5)
Effective January 1, 2019, we became subject to minimum total loss-absorbing capacity and long-term debt requirements. For more information, see Capital Management on page 45.



29Bank 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)

2019 2018 2017
Earning assets 
  
  
  
  
  
  
  
  
Interest-bearing deposits with the Federal Reserve, non-U.S. central banks and other banks$125,555
 $1,823
 1.45% $139,848
 $1,926
 1.38% $127,431
 $1,122
 0.88%
Time deposits placed and other short-term investments9,427
 207
 2.19
 9,446
 216
 2.29
 12,112
 241
 1.99
Federal funds sold and securities borrowed or purchased under agreements to resell279,610
 4,843
 1.73
 251,328
 3,176
 1.26
 222,818
 1,806
 0.81
Trading account assets148,076
 5,269
 3.56
 132,724
 4,901
 3.69
 129,007
 4,618
 3.58
Debt securities450,090
 11,917
 2.65
 437,312
 11,837
 2.66
 435,005
 10,626
 2.44
Loans and leases (2):
 
  
  
  
  
  
  
  
  
Residential mortgage220,552
 7,651
 3.47
 207,523
 7,294
 3.51
 197,766
 6,831
 3.45
Home equity44,600
 2,194
 4.92
 53,886
 2,573
 4.77
 62,260
 2,608
 4.19
Credit card94,488
 10,166
 10.76
 94,612
 9,579
 10.12
 91,068
 8,791
 9.65
Non-U.S. credit card (3)

 
 
 
 
 
 3,929
 358
 9.12
Direct/Indirect and other consumer (4)
90,656
 3,261
 3.60
 93,036
 3,104
 3.34
 96,002
 2,734
 2.85
Total consumer450,296
 23,272
 5.17
 449,057
 22,550
 5.02
 451,025
 21,322
 4.73
U.S. commercial321,467
 13,016
 4.05
 304,387
 11,937
 3.92
 292,452
 9,765
 3.34
Non-U.S. commercial103,918
 3,547
 3.41
 97,664
 3,220
 3.30
 95,005
 2,566
 2.70
Commercial real estate (5)
62,044
 2,741
 4.42
 60,384
 2,618
 4.34
 58,502
 2,116
 3.62
Commercial lease financing20,691
 718
 3.47
 21,557
 698
 3.24
 21,747
 706
 3.25
Total commercial508,120
 20,022
 3.94
 483,992
 18,473
 3.82
 467,706
 15,153
 3.24
Total loans and leases (3)
958,416
 43,294
 4.52
 933,049
 41,023
 4.40
 918,731
 36,475
 3.97
Other earning assets69,089
 4,478
 6.48
 76,524
 4,300
 5.62
 76,957
 3,224
 4.19
Total earning assets2,040,263
 71,831
 3.52
 1,980,231
 67,379
 3.40
 1,922,061
 58,112
 3.02
Cash and due from banks26,193
    
 25,830
    
 27,995
    
Other assets, less allowance for loan and lease losses339,374
  
  
 319,185
  
  
 318,577
  
  
Total assets$2,405,830
  
  
 $2,325,246
  
  
 $2,268,633
  
  
Interest-bearing liabilities 
  
  
  
  
  
  
  
  
U.S. interest-bearing deposits: 
  
  
  
  
  
  
  
  
Savings$52,020
 $5
 0.01% $54,226
 $6
 0.01% $53,783
 $5
 0.01%
NOW and money market deposit accounts741,126
 4,471
 0.60
 676,382
 2,636
 0.39
 628,647
 873
 0.14
Consumer CDs and IRAs47,577
 471
 0.99
 39,823
 157
 0.39
 44,794
 121
 0.27
Negotiable CDs, public funds and other deposits66,866
 1,407
 2.11
 50,593
 991
 1.96
 36,782
 354
 0.96
Total U.S. interest-bearing deposits907,589
 6,354
 0.70
 821,024
 3,790
 0.46
 764,006
 1,353
 0.18
Non-U.S. interest-bearing deposits: 
  
  
  
  
  
  
  
  
Banks located in non-U.S. countries1,936
 20
 1.04
 2,312
 39
 1.69
 2,442
 21
 0.85
Governments and official institutions181
 
 0.05
 810
 
 0.01
 1,006
 10
 0.95
Time, savings and other69,351
 814
 1.17
 65,097
 666
 1.02
 62,386
 547
 0.88
Total non-U.S. interest-bearing deposits71,468
 834
 1.17
 68,219
 705
 1.03
 65,834
 578
 0.88
Total interest-bearing deposits979,057
 7,188
 0.73
 889,243
 4,495
 0.51
 829,840
 1,931
 0.23
Federal funds purchased, securities loaned or sold under agreements to repurchase, short-term borrowings and other interest-bearing liabilities276,432
 7,208
 2.61
 269,748
 5,839
 2.17
 274,975
 3,146
 1.14
Trading account liabilities45,449
 1,249
 2.75
 50,928
 1,358
 2.67
 45,518
 1,204
 2.64
Long-term debt201,623
 6,700
 3.32
 200,399
 6,915
 3.45
 194,882
 5,667
 2.91
Total interest-bearing liabilities1,502,561
 22,345
 1.49
 1,410,318
 18,607
 1.32
 1,345,215
 11,948
 0.89
Noninterest-bearing sources: 
  
  
  
  
  
  
  
  
Noninterest-bearing deposits401,269
  
  
 425,698
  
  
 439,956
  
  
Other liabilities (6)
234,111
  
  
 224,482
  
  
 212,173
  
  
Shareholders’ equity267,889
  
  
 264,748
  
  
 271,289
  
  
Total liabilities and shareholders’ equity$2,405,830
  
  
 $2,325,246
  
  
 $2,268,633
  
  
Net interest spread 
  
 2.03%  
  
 2.08%  
  
 2.13%
Impact of noninterest-bearing sources 
  
 0.40
  
  
 0.37
  
  
 0.27
Net interest income/yield on earning assets (7)
 
 $49,486
 2.43%  
 $48,772
 2.45%  
 $46,164
 2.40%
(1)
Includes the impact of interest rate risk management contracts. For more information, see Interest Rate Risk Management for the Banking Book on page 74.
(2)
Nonperforming loans are included in the respective average loan balances. Income on these nonperforming loans is generally recognized on a cost recovery basis.
(3)
Includes assets of the Corporation's non-U.S. consumer credit card business, which was sold during the second quarter of 2017.
(4)
Includes non-U.S. consumer loans of $2.9 billion, $2.8 billion and $2.9 billion for 2019, 2018 and 2017, respectively.
(5)
Includes U.S. commercial real estate loans of $57.3 billion, $56.4 billion and $55.0 billion, and non-U.S. commercial real estate loans of $4.7 billion, $4.0 billion and $3.5 billion for 2019, 2018 and 2017, respectively.
(6)
Includes $35.5 billion, $30.4 billion and $30.3 billion of structured notes and liabilities for 2019, 2018 and 2017, respectively.
(7)
Net interest income includes FTE adjustments of $595 million, $610 million and $925 million for 2019, 2018 and 2017, respectively.



Bank of America 30


             
Table 9Analysis 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 2018 to 2019 From 2017 to 2018
Increase (decrease) in interest income 
  
  
  
  
  
Interest-bearing deposits with the Federal Reserve, non-U.S. central banks and other banks$(193) $90
 $(103) $109
 $695
 $804
Time deposits placed and other short-term investments
 (9) (9) (53) 28
 (25)
Federal funds sold and securities borrowed or purchased under agreements to resell347
 1,320
 1,667
 230
 1,140
 1,370
Trading account assets563
 (195) 368
 134
 149
 283
Debt securities135
 (55) 80
 44
 1,167
 1,211
Loans and leases:       
  
  
Residential mortgage447
 (90) 357
 329
 134
 463
Home equity(446) 67
 (379) (350) 315
 (35)
Credit card(17) 604
 587
 339
 449
 788
Non-U.S. credit card (2)

 
 
 (358) 
 (358)
Direct/Indirect and other consumer(76) 233
 157
 (82) 452
 370
Total consumer 
  
 722
  
  
 1,228
U.S. commercial665
 414
 1,079
 402
 1,770
 2,172
Non-U.S. commercial209
 118
 327
 71
 583
 654
Commercial real estate75
 48
 123
 70
 432
 502
Commercial lease financing(28) 48
 20
 (5) (3) (8)
Total commercial 
  
 1,549
  
  
 3,320
Total loans and leases 
  
 2,271
  
  
 4,548
Other earning assets(417) 595
 178
 (18) 1,094
 1,076
Total interest income 
  
 $4,452
  
  
 $9,267
Increase (decrease) in interest expense 
  
  
  
  
  
U.S. interest-bearing deposits: 
  
  
  
  
  
Savings$(1) $
 $(1) $
 $1
 $1
NOW and money market deposit accounts254
 1,581
 1,835
 74
 1,689
 1,763
Consumer CDs and IRAs29
 285
 314
 (13) 49
 36
Negotiable CDs, public funds and other deposits320
 96
 416
 132
 505
 637
Total U.S. interest-bearing deposits 
  
 2,564
  
  
 2,437
Non-U.S. interest-bearing deposits: 
  
  
  
  
  
Banks located in non-U.S. countries(6) (13) (19) (1) 19
 18
Governments and official institutions
 
 
 (2) (8) (10)
Time, savings and other41
 107
 148
 26
 93
 119
Total non-U.S. interest-bearing deposits 
  
 129
  
  
 127
Total interest-bearing deposits 
  
 2,693
  
  
 2,564
Federal funds purchased, securities loaned or sold under agreements to repurchase, short-term borrowings and other interest-bearing liabilities160
 1,209
 1,369
 (71) 2,764
 2,693
Trading account liabilities(145) 36
 (109) 140
 14
 154
Long-term debt41
 (256) (215) 165
 1,083
 1,248
Total interest expense 
  
 3,738
  
  
 6,659
Net increase in net interest income (3)
 
  
 $714
  
  
 $2,608
(1)
The changes for each category of interest income and expense are divided between the portion of change attributable to the variance in volume and the portion of change attributable to the variance in rate for that category. The unallocated change in rate or volume variance is allocated between the rate and volume variances.
(2)
The Corporation sold its non-U.S. credit card business in the second quarter of 2017.
(3)
Includes decreases in FTE basis adjustments of $15 million from 2018 to 2019 and $315 million from 2017 to 2018.


31 Bank of America






Table 6Selected Annual Financial Data
(In millions, except per share information)202120202019
Income statement 
Net interest income$42,934 $43,360 $48,891 
Noninterest income46,179 42,168 42,353 
Total revenue, net of interest expense89,113 85,528 91,244 
Provision for credit losses(4,594)11,320 3,590 
Noninterest expense59,731 55,213 54,900 
Income before income taxes33,976 18,995 32,754 
Income tax expense1,998 1,101 5,324 
Net income31,978 17,894 27,430 
Net income applicable to common shareholders30,557 16,473 25,998 
Average common shares issued and outstanding8,493.3 8,753.2 9,390.5 
Average diluted common shares issued and outstanding8,558.4 8,796.9 9,442.9 
Performance ratios   
Return on average assets (1)
1.05 %0.67 %1.14 %
Return on average common shareholders’ equity (1)
12.23 6.76 10.62 
Return on average tangible common shareholders’ equity (1, 2)
17.02 9.48 14.86 
Return on average shareholders’ equity (1)
11.68 6.69 10.24 
Return on average tangible shareholders’ equity (1, 2)
15.71 9.07 13.85 
Total ending equity to total ending assets8.52 9.68 10.88 
Total average equity to total average assets9.02 9.96 11.14 
Dividend payout (1)
21.51 38.18 23.65 
Per common share data   
Earnings$3.60 $1.88 $2.77 
Diluted earnings3.57 1.87 2.75 
Dividends paid0.78 0.72 0.66 
Book value (1)
30.37 28.72 27.32 
Tangible book value (2)
21.68 20.60 19.41 
Market capitalization$359,383 $262,206 $311,209 
Average balance sheet   
Total loans and leases$920,401 $982,467 $958,416 
Total assets3,034,623 2,683,122 2,405,830 
Total deposits1,914,286 1,632,998 1,380,326 
Long-term debt237,703 220,440 201,623 
Common shareholders’ equity249,787 243,685 244,853 
Total shareholders’ equity273,757 267,309 267,889 
Asset quality   
Allowance for credit losses (3)
$13,843 $20,680 $10,229 
Nonperforming loans, leases and foreclosed properties (4)
4,697 5,116 3,837 
Allowance for loan and lease losses as a percentage of total loans and leases outstanding (4)
1.28 %2.04 %0.97 %
Allowance for loan and lease losses as a percentage of total nonperforming loans and leases (4)
271 380 265 
Net charge-offs$2,243 $4,121 $3,648 
Net charge-offs as a percentage of average loans and leases outstanding (4)
0.25 %0.42 %0.38 %
Capital ratios at year end (5)
   
Common equity tier 1 capital10.6 %11.9 %11.2 %
Tier 1 capital12.1 13.5 12.6 
Total capital14.1 16.1 14.7 
Tier 1 leverage6.4 7.4 7.9 
Supplementary leverage ratio5.5 7.2 6.4 
Tangible equity (2)
6.4 7.4 8.2 
Tangible common equity (2)
5.7 6.5 7.3 
(1)For definition, see Key Metrics on page 169.
(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 85.
(3)Includes the allowance for loan and leases 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 64 and corresponding Table 27 and Commercial Portfolio Credit Risk Management – Nonperforming Commercial Loans, Leases and Foreclosed Properties Activity on page 68 and corresponding Table 34.
(5)For more information, including which approach is used to assess capital adequacy, see Capital Management on page 49.

Bank of America 32


Table 7Selected Quarterly Financial Data
2021 Quarters2020 Quarters
(In millions, except per share information)FourthThirdSecondFirstFourthThirdSecondFirst
Income statement   
Net interest income$11,410 $11,094 $10,233 $10,197 $10,253 $10,129 $10,848 $12,130 
Noninterest income10,650 11,672 11,233 12,624 9,846 10,207 11,478 10,637 
Total revenue, net of interest expense22,060 22,766 21,466 22,821 20,099 20,336 22,326 22,767 
Provision for credit losses(489)(624)(1,621)(1,860)53 1,389 5,117 4,761 
Noninterest expense14,731 14,440 15,045 15,515 13,927 14,401 13,410 13,475 
Income before income taxes7,818 8,950 8,042 9,166 6,119 4,546 3,799 4,531 
Income tax expense805 1,259 (1,182)1,116 649 (335)266 521 
Net income7,013 7,691 9,224 8,050 5,470 4,881 3,533 4,010 
Net income applicable to common shareholders6,773 7,260 8,964 7,560 5,208 4,440 3,284 3,541 
Average common shares issued and outstanding8,226.5 8,430.7 8,620.8 8,700.1 8,724.9 8,732.9 8,739.9 8,815.6 
Average diluted common shares issued and outstanding8,304.7 8,492.8 8,735.5 8,755.6 8,785.0 8,777.5 8,768.1 8,862.7 
Performance ratios      
Return on average assets (1)
0.88 %0.99 %1.23 %1.13 %0.78 %0.71 %0.53 %0.65 %
Four-quarter trailing return on average assets (2)
1.05 1.04 0.97 0.79 0.67 0.75 0.81 0.99 
Return on average common shareholders’ equity (1)
10.90 11.43 14.33 12.28 8.39 7.24 5.44 5.91 
Return on average tangible common shareholders’ equity (3)
15.25 15.85 19.90 17.08 11.73 10.16 7.63 8.32 
Return on average shareholders’ equity (1)
10.27 11.08 13.47 11.91 8.03 7.26 5.34 6.10 
Return on average tangible shareholders’ equity (3)
13.87 14.87 18.11 16.01 10.84 9.84 7.23 8.29 
Total ending equity to total ending assets8.52 8.83 9.15 9.23 9.68 9.82 9.69 10.11 
Total average equity to total average assets8.56 8.95 9.11 9.52 9.71 9.76 9.85 10.60 
Dividend payout (1)
25.33 24.10 17.25 20.68 30.11 35.36 47.87 44.57 
Per common share data      
Earnings$0.82 $0.86 $1.04 $0.87 $0.60 $0.51 $0.38 $0.40 
Diluted earnings0.82 0.85 1.03 0.86 0.59 0.51 0.37 0.40 
Dividends paid0.21 0.21 0.18 0.18 0.18 0.18 0.18 0.18 
Book value (1)
30.37 30.22 29.89 29.07 28.72 28.33 27.96 27.84 
Tangible book value (3)
21.68 21.69 21.61 20.90 20.60 20.23 19.90 19.79 
Market capitalization$359,383 $349,841 $349,925 $332,337 $262,206 $208,656 $205,772 $184,181 
Average balance sheet      
Total loans and leases$945,062 $920,509 $907,900 $907.723 $934,798 $974,018 $1,031,387 $990,283 
Total assets3,164,118 3,076,452 3,015,113 2,879.221 2,791,874 2,739,684 2,704,186 2,494,928 
Total deposits2,017,223 1,942,705 1,888,834 1,805.747 1,737,139 1,695,488 1,658,197 1,439,336 
Long-term debt248,525 248,988 232,034 220.836 225,423 224,254 221,167 210,816 
Common shareholders’ equity246,519 252,043 250,948 249,648 246,840 243,896 242,889 241,078 
Total shareholders’ equity270,883 275,484 274,632 274,047 271,020 267,323 266,316 264,534 
Asset quality     
Allowance for credit losses (4)
$13,843 $14,693 $15,782 $17,997 $20,680 $21,506 $21,091 $17,126 
Nonperforming loans, leases and foreclosed properties (5)
4,697 4,831 5,031 5,299 5,116 4,730 4,611 4,331 
Allowance for loan and lease losses as a percentage of total loans and leases outstanding (5)
1.28 %1.43 %1.55 %1.80 %2.04 %2.07 %1.96 %1.51 %
Allowance for loan and lease losses as a percentage of total nonperforming loans and leases (5)
271 279 287 313 380 431 441 389 
Net charge-offs$362 $463 $595 $823 $881 $972 $1,146 $1,122 
Annualized net charge-offs as a percentage of average loans and leases outstanding (5)
0.15 %0.20 %0.27 %0.37 %0.38 %0.40 %0.45 %0.46 %
Capital ratios at period end (6)
     
Common equity tier 1 capital10.6 %11.1 %11.5 %11.8 %11.9 %11.9 %11.4 %10.8 %
Tier 1 capital12.1 12.6 13.0 13.3 13.5 13.5 12.9 12.3 
Total capital14.1 14.7 15.1 15.6 16.1 16.1 14.8 14.6 
Tier 1 leverage6.4 6.6 6.9 7.2 7.4 7.4 7.4 7.9 
Supplementary leverage ratio5.5 5.6 5.9 7.0 7.2 6.9 7.1 6.4 
Tangible equity (3)
6.4 6.7 7.0 7.0 7.4 7.4 7.3 7.7 
Tangible common equity (3)
5.7 5.9 6.2 6.2 6.5 6.6 6.5 6.7 
Total loss-absorbing capacity and long-term debt metrics
Total loss-absorbing capacity to risk-weighted assets26.9 %27.7 %27.7 %26.8 %27.4 %26.9 %26.0 %24.6 %
Total loss-absorbing capacity to supplementary leverage exposure12.1 12.4 12.5 14.1 14.5 13.7 14.2 12.8 
Eligible long-term debt to risk-weighted assets14.1 14.4 14.1 13.0 13.3 12.9 12.4 11.6 
Eligible long-term debt to supplementary leverage exposure6.3 6.4 6.3 6.8 7.1 6.6 6.7 6.1 
(1)For definitions, see Key Metrics on page 169.
(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 85.
(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 64 and corresponding Table 27 and Commercial Portfolio Credit Risk Management – Nonperforming Commercial Loans, Leases and Foreclosed Properties Activity on page 68 and corresponding Table 34.
(6)For more information, including which approach is used to assess capital adequacy, see Capital Management on page 49.

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)202120202019
Earning assets         
Interest-bearing deposits with the Federal Reserve, non-
   U.S. central banks and other banks
$255,595 $172 0.07 %$253,227 $359 0.14 %$125,555 $1,823 1.45 %
Time deposits placed and other short-term investments7,603 15 0.19 8,840 29 0.33 9,427 207 2.19 
Federal funds sold and securities borrowed or purchased
   under agreements to resell (2)
267,257 (90)(0.03)309,945 903 0.29 279,610 4,843 1.73 
Trading account assets147,891 3,823 2.58 148,076 4,185 2.83 148,076 5,269 3.56 
Debt securities905,169 12,433 1.38 532,266 9,868 1.87 450,090 11,917 2.65 
Loans and leases (3)
         
Residential mortgage216,983 5,995 2.76 236,719 7,338 3.10 220,552 7,651 3.47 
Home equity31,014 1,066 3.44 38,251 1,290 3.37 44,600 2,194 4.92 
Credit card75,385 7,772 10.31 85,017 8,759 10.30 94,488 10,166 10.76 
Direct/Indirect and other consumer96,472 2,276 2.36 89,974 2,545 2.83 90,656 3,261 3.60 
Total consumer419,854 17,109 4.08 449,961 19,932 4.43 450,296 23,272 5.17 
U.S. commercial324,795 8,606 2.65 344,095 9,712 2.82 321,467 13,161 4.09 
Non-U.S. commercial99,584 1,752 1.76 106,487 2,208 2.07 103,918 3,402 3.27 
Commercial real estate (4)
60,303 1,496 2.48 63,428 1,790 2.82 62,044 2,741 4.42 
Commercial lease financing15,865 462 2.91 18,496 559 3.02 20,691 718 3.47 
Total commercial500,547 12,316 2.46 532,506 14,269 2.68 508,120 20,022 3.94 
Total loans and leases920,401 29,425 3.20 982,467 34,201 3.48 958,416 43,294 4.52 
Other earning assets112,512 2,321 2.06 83,078 2,539 3.06 69,089 4,478 6.48 
Total earning assets2,616,428 48,099 1.84 2,317,899 52,084 2.25 2,040,263 71,831 3.52 
Cash and due from banks31,214  31,885  26,193  
Other assets, less allowance for loan and lease losses386,981   333,338   339,374   
Total assets$3,034,623   $2,683,122   $2,405,830   
Interest-bearing liabilities         
U.S. interest-bearing deposits         
Demand and money market deposits$925,970 $314 0.03 %$829,719 $977 0.12 %$741,126 $4,471 0.60 %
Time and savings deposits161,512 170 0.11 170,750 734 0.43 166,463 1,883 1.13 
Total U.S. interest-bearing deposits1,087,482 484 0.04 1,000,469 1,711 0.17 907,589 6,354 0.70 
Non-U.S. interest-bearing deposits82,769 53 0.06 77,046 232 0.30 71,468 834 1.17 
Total interest-bearing deposits1,170,251 537 0.05 1,077,515 1,943 0.18 979,057 7,188 0.73 
Federal funds purchased and securities loaned or sold
   under agreements to repurchase (5)
210,848 461 0.22 188,511 1,229 0.65 198,533 4,404 2.22 
Short-term borrowings and other interest bearing
   liabilities (2,5)
106,975 (819)(0.77)104,955 (242)(0.23)77,899 2,804 3.60 
Trading account liabilities54,107 1,128 2.08 41,386 974 2.35 45,449 1,249 2.75 
Long-term debt237,703 3,431 1.44 220,440 4,321 1.96 201,623 6,700 3.32 
Total interest-bearing liabilities1,779,884 4,738 0.27 1,632,807 8,225 0.50 1,502,561 22,345 1.49 
Noninterest-bearing sources         
Noninterest-bearing deposits744,035   555,483   401,269   
Other liabilities (6)
236,947   227,523   234,111   
Shareholders’ equity273,757   267,309   267,889   
Total liabilities and shareholders’ equity$3,034,623   $2,683,122   $2,405,830   
Net interest spread  1.57 %  1.75 %  2.03 %
Impact of noninterest-bearing sources  0.09   0.15   0.40 
Net interest income/yield on earning assets (7)
 $43,361 1.66 % $43,859 1.90 % $49,486 2.43 %
(1)Includes the impact of interest rate risk management contracts. For more information, see Interest Rate Risk Management for the Banking Book on page 79.
(2)For more information on negative interest, see Note 1 – Summary of Significant Accounting Principles to the Consolidated Financial Statements.
(3)Nonperforming loans are included in the respective average loan balances. Income on these nonperforming loans is generally recognized on a cost recovery basis.
(4)Includes U.S. commercial real estate loans of $56.5 billion, $59.8 billion and $57.3 billion, and non-U.S. commercial real estate loans of $3.8 billion, $3.6 billion and $4.7 billion for 2021, 2020 and 2019, respectively.
(5)Certain prior-period amounts have been reclassified to conform to current period presentation.
(6)Includes $30.4 billion, $34.3 billion and $35.5 billion of structured notes and liabilities for 2021, 2020 and 2019, respectively.
(7)Net interest income includes FTE adjustments of $427 million, $499 million and $595 million for 2021, 2020 and 2019, 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 2020 to 2021From 2019 to 2020
Increase (decrease) in interest income
Interest-bearing deposits with the Federal Reserve, non-U.S. central banks and other banks$(1)$(186)$(187)$1,849 $(3,313)$(1,464)
Time deposits placed and other short-term investments(4)(10)(14)(13)(165)(178)
Federal funds sold and securities borrowed or purchased under agreements to resell(128)(865)(993)519 (4,459)(3,940)
Trading account assets (362)(362)(1,087)(1,084)
Debt securities7,059 (4,494)2,565 2,188 (4,237)(2,049)
Loans and leases
Residential mortgage(612)(731)(1,343)563 (876)(313)
Home equity(245)21 (224)(312)(592)(904)
Credit card(994)7 (987)(1,018)(389)(1,407)
Direct/Indirect and other consumer185 (454)(269)(22)(694)(716)
Total consumer(2,823)(3,340)
U.S. commercial(553)(553)(1,106)912 (4,361)(3,449)
Non-U.S. commercial(147)(309)(456)80 (1,274)(1,194)
Commercial real estate(89)(205)(294)63 (1,014)(951)
Commercial lease financing(80)(17)(97)(76)(83)(159)
Total commercial(1,953)(5,753)
Total loans and leases(4,776)(9,093)
Other earning assets904 (1,122)(218)905 (2,844)(1,939)
Net decrease in interest income$(3,985)$(19,747)
Increase (decrease) in interest expense
U.S. interest-bearing deposits
Demand and money market deposit accounts$134 $(797)$(663)$507 $(4,001)$(3,494)
Time and savings deposits(39)(525)(564)46 (1,195)(1,149)
Total U.S. interest-bearing deposits(1,227)(4,643)
Non-U.S. interest-bearing deposits16 (195)(179)67 (669)(602)
Total interest-bearing deposits(1,406)(5,245)
Federal funds purchased and securities loaned or sold under agreements to
   repurchase (2)
142 (910)(768)(219)(2,956)(3,175)
Short-term borrowings and other interest bearing liabilities (2)
(4)(573)(577)974 (4,020)(3,046)
Trading account liabilities298 (144)154 (111)(164)(275)
Long-term debt338 (1,228)(890)619 (2,998)(2,379)
Net decrease in interest expense(3,487)(14,120)
Net decrease in net interest income (3)
$(498)$(5,627)
(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 $72 million decrease from 2020 to 2021 and a $96 million decrease from 2019 to 2020.
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 Banking and Global Markets, with the remaining operations recorded in All Other. We manage our segments and report their results on an FTE basis. The primary activities, products and businesses of the business segments and All Other are shown below.
boalobsa10.jpgbac-20211231_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 42.46. 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 our presentation of financial information on an FTE basis, see Supplemental Financial Data on page 27, 31,
and for reconciliations to consolidated total revenue, net income and year-end total assets, see Note 2423 – Business Segment Information to the Consolidated Financial Statements.
Effective October 1, 2021, a business activity previously included in Global Markets is being reported as a liquidating business in All Other, consistent with a realignment in performance reporting to senior management. The activity was not material to Global Markets’ results of operations and historical results have not been restated. For more information, see Note 23 – Business Segment Information to the Consolidated Financial Statements.
Key Performance Indicators
We present certain key financial and nonfinancial performance indicators that management uses when evaluating segment results. We believe they are useful to investors because they provide additional information about our segments’ operational performance, customer trends and business growth.


Bank of America 3236



Consumer Banking
DepositsConsumer LendingTotal Consumer Banking
(Dollars in millions)202120202021202020212020% Change
Net interest income$14,358 $13,739 $10,571 $10,959 $24,929 $24,698 %
Noninterest income:
Card income(28)(20)5,200 4,693 5,172 4,673 11 
Service charges3,535 3,416 3 3,538 3,417 
All other income223 310 143 164 366 474 (23)
Total noninterest income3,730 3,706 5,346 4,858 9,076 8,564 
Total revenue, net of interest expense18,088 17,445 15,917 15,817 34,005 33,262 
Provision for credit losses240 379 (1,275)5,386 (1,035)5,765 (118)
Noninterest expense11,650 11,508 7,640 7,374 19,290 18,882 
Income before income taxes6,198 5,558 9,552 3,057 15,750 8,615 83 
Income tax expense1,519 1,362 2,340 749 3,859 2,111 83 
Net income$4,679 $4,196 $7,212 $2,308 $11,891 $6,504 83 
Effective tax rate (1)
24.5 %24.5 %
Net interest yield1.48 %1.69 %3.77 %3.53 %2.45 2.88 
Return on average allocated capital39 35 27 31 17 
Efficiency ratio64.41 65.97 48.00 46.62 56.73 56.77 
Balance Sheet
Average
Total loans and leases$4,431 $5,144 $279,630 $310,436 $284,061 $315,580 (10)%
Total earning assets (2)
973,018 813,779 280,080 310,862 1,016,751 858,724 18 
Total assets (2)
1,009,387 849,924 285,532 314,599 1,058,572 898,606 18 
Total deposits976,093 816,968 6,934 6,698 983,027 823,666 19 
Allocated capital12,000 12,000 26,500 26,500 38,500 38,500 — 
Year end
Total loans and leases$4,206 $4,673 $282,305 $295,261 $286,511 $299,934 (4)%
Total earning assets (2)
1,048,009 899,951 282,850 295,627 1,090,331 945,343 15 
Total assets (2)
1,082,449 939,629 289,220 299,185 1,131,142 988,580 14 
Total deposits1,049,085 906,092 5,910 6,560 1,054,995 912,652 16 
            
  Deposits Consumer Lending Total Consumer Banking  
(Dollars in millions)20192018 20192018 20192018 % Change
Net interest income$16,904
$15,939
 $11,254
$11,086
 $28,158
$27,025
 4 %
Noninterest income:          
Card income(33)(33) 5,117
5,135
 5,084
5,102
 
Service charges4,217
4,298
 2
2
 4,219
4,300
 (2)
All other income832
762
 294
429
 1,126
1,191
 (5)
Total noninterest income5,016
5,027
 5,413
5,566
 10,429
10,593
 (2)
Total revenue, net of interest expense21,920
20,966
 16,667
16,652
 38,587
37,618
 3
           
Provision for credit losses269
195
 3,503
3,469
 3,772
3,664
 3
Noninterest expense10,682
10,657
 6,936
7,015
 17,618
17,672
 
Income before income taxes10,969
10,114
 6,228
6,168
 17,197
16,282
 6
Income tax expense2,687
2,578
 1,526
1,572
 4,213
4,150
 2
Net income$8,282
$7,536
 $4,702
$4,596
 $12,984
$12,132
 7
           
Effective tax rate (1)
      24.5%25.5%  
           
Net interest yield2.40%2.34% 3.80%3.97% 3.81
3.77
  
Return on average allocated capital69
63
 19
18
 35
33
  
Efficiency ratio48.73
50.83
 41.61
42.12
 45.66
46.98
  
            
Balance Sheet           
            
Average           
Total loans and leases$5,373
$5,233
 $295,562
$278,574
 $300,935
$283,807
 6 %
Total earning assets (2)
703,444
682,592
 296,051
279,217
 738,770
717,189
 3
Total assets (2)
735,232
710,925
 306,169
290,068
 780,676
756,373
 3
Total deposits702,908
678,640
 5,368
5,533
 708,276
684,173
 4
Allocated capital12,000
12,000
 25,000
25,000
 37,000
37,000
 
            
Year end           
Total loans and leases$5,472
$5,470
 $311,942
$288,865
 $317,414
$294,335
 8 %
Total earning assets (2)
724,536
694,672
 312,684
289,249
 760,137
728,813
 4
Total assets (2)
758,385
724,019
 322,717
299,970
 804,019
768,881
 5
Total deposits725,598
691,666
 5,080
4,480
 730,678
696,146
 5
(1)Estimated at the segment level only.
(1)
(2)
Estimated at the segment level only.
(2)
In segments and businesses where the total of liabilities and equity exceeds assets, we allocate assets from All Other to match the segments’ and businesses’ liabilities and allocated shareholders’ equity. As a result, total earning assets and total assets of the businesses may not equal total Consumer Banking.
Consumer Banking, which is comprised of Deposits and Consumer Lending, offers a diversified range of credit, banking and investment products and services to consumers and small businesses. Deposits and Consumer Lending include the net impact of migrating customers and their related deposit, brokerage asset and loan balances between Deposits, Consumer Lending and GWIM, as well as other client-managed businesses. Our customers and clients have access to a coast to coastcoast-to-coast network including financial centers in 38 states and the District of Columbia. OurAs of December 31, 2021, our network includes approximately 4,3004,200 financial centers, approximately 16,80016,000 ATMs, nationwide call centers and leading digital banking platforms with more than 3841 million active users, including over 29approximately 33 million active mobile users.users.
Consumer Banking Results
Net income for Consumer Banking increased $852$5.4 billion to $11.9 billion primarily due to improvement in the provision for credit losses and higher revenue, partially offset by higher noninterest expense. Net interest income increased $231 million to $13.0$24.9 billion in 2019 comparedprimarily due to 2018the benefit of higher

deposit balances and the acceleration of net capitalized loan fees due to PPP loan forgiveness, partially offset by lower interest rates and loan balances. Noninterest income increased $512 million to $9.1 billion primarily driven by higher net interestcard income and lower noninterest expense,service charges due to increased client activity, partially offset by lower noninterest income. Net interest income increased $1.1 billion to $28.2 billion primarily due to growth in depositsthe allocation of asset and loans. Noninterest income decreased $164 million to $10.4 billion driven by lower service charges and lower mortgage banking income, largely offset by higher results from ALM activities.liability management (ALM) results.
The provision for credit losses increased $108 millionimproved $6.8 billion to $3.8 billion driven by overdrafts and portfolio seasoning in the credit card portfolio. Noninterest expense decreased $54 million to
$17.6a benefit of $1.0 billion primarily driven by lower FDICreserve releases due to improvements in the macroeconomic outlook and credit quality. Noninterest expense increased $408 million to $19.3 billion primarily driven by an impairment charge for real estate rationalization, the contribution to the Bank of America Foundation, cost of increased client activity and operating efficiencies,continued investments for business growth, including the merchant services platform, partially offset by continued investment in the business.lower COVID-19 related costs.
The return on average allocated capital was 3531 percent, up from 3317 percent, driven by higher net income. For more information on capital allocated to the business segments, see Business Segment Operations on page 32.36.

37 Bank of America


Deposits
Deposits includes the results of consumer deposit activities whichthat consist of a comprehensive range of products provided to consumers and small businesses. Our deposit products include traditional savingsnoninterest- and interest-bearing checking accounts, money market savings accounts, traditional 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 Consumer Investment accounts. Consumer Investments serves investment client relationships through the 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 providesplatform, providing investment advice and guidance, client brokerage asset services, a self-directed online investing platform and key banking capabilities including access to the Corporation’s network of financial centers and ATMs.


33Bank of America






Net income for Deposits increased $746$483 million to $8.3$4.7 billion drivendue to higher revenue and lower provision for credit losses, partially offset by higher net interest income.noninterest expense. Net interest income increased $965$619 million to $16.9$14.4 billion primarily due to growth in deposits and pricing discipline.the benefit of higher deposit balances. Noninterest income decreased $11increased $24 million to $5.0$3.7 billion primarily driven by lowerhigher service charges and investment and brokerage fees, largely offset by higher results fromthe allocation of ALM activities.results.
The provision for credit losses increased $74decreased $139 million to $269$240 million in 2019.due to an improved macroeconomic outlook. Noninterest expense increased $25$142 million to $10.7$11.7 billion primarily driven by an impairment charge for real estate rationalization, and the cost of increased client activity and continued investment in theinvestments for business growth, partially offset by lower FDIC expense and operating efficiencies.COVID-19 related costs.
Average deposits increased $24.3$159.1 billion to $702.9$976.1 billion in 2019 driven by strong organic growth. Growthprimarily due to net inflows of $90.4 billion in checking and time deposits of $27.0and $68.0 billion was partially offset by a decline in traditional savings and money market savings of $2.5 billion.driven by strong organic growth and government stimulus measures.

The table below provides key performance indicators for Deposits. Management uses these metrics, and we believe they are useful to investors because they provide additional information to evaluate our deposit profitability and digital/mobile trends.
   
Key Statistics – Deposits   Key Statistics – Deposits
   
2019 2018
20212020
Total deposit spreads (excludes noninterest costs) (1)
2.34% 2.14%
Total deposit spreads (excludes noninterest costs) (1)
1.69%1.94%
   
Year end   
Year EndYear End
Consumer investment assets (in millions) (2)
$240,132
 $185,881
Consumer investment assets (in millions) (2)
$368,831$306,104
Active digital banking users (units in thousands) (3)
38,266
 36,264
Active mobile banking users (units in thousands)29,174
 26,433
Active digital banking users (in thousands) (3)
Active digital banking users (in thousands) (3)
41,36539,315
Active mobile banking users (in thousands) (4)
Active mobile banking users (in thousands) (4)
32,98030,783
Financial centers4,300
 4,341
Financial centers4,1734,312
ATMs16,788
 16,255
ATMs16,20916,904
(1)
(1)Includes deposits held in Consumer Lending.
(2)Includes client brokerage assets, deposit sweep balances and AUM in Consumer Banking.
(3)Represents mobile and/or online active users over the past 90 days.
(4)Represents mobile active users over the past 90 days.
Includes deposits held in Consumer Lending.
(2)
Includes client brokerage assets, deposit sweep balances and AUM in Consumer Banking.
(3)
Active digital banking users represents mobile and/or online users.
Consumer investment assets increased $54$62.7 billion in 2019to $368.8 billion driven by strong market performance and client flows. Active mobile banking users increased 3approximately two million, reflecting continuing changes in our customers’ banking preferences. The number of financial centers declined byWe had a net 41 reflecting changes in customer preferences to self-service optionsdecrease of 139 financial centers as we continue 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 creditdebit and debitcredit 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 creditdebit and debitcredit 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.
Bank of America 38


Net income for Consumer Lending increased $106 millionwas $7.2 billion, an increase of $4.9 billion, primarily due to $4.7 billion driven by higher net interest income and lower noninterest expense, partially offset by lower noninterest income.improvement in the provision for credit losses. Net interest income increased $168declined $388 million to $11.3$10.6 billion driven byprimarily due to lower interest rates and loan growth.balances. Noninterest income decreased $153increased $488 million to $5.4$5.3 billion primarily driven by lower mortgage bankinghigher card income and lower card income.due to increased client activity.
The provision for credit losses increased $34 millionimproved $6.7 billion to $3.5a benefit of $1.3 billion primarily driven by portfolio seasoningreserve releases due to improvements in the macroeconomic outlook and credit card portfolio.quality. Noninterest expense decreased $79increased $266 million to $6.9$7.6 billion primarily driven by operating efficiencies.continued investments for business growth, partially offset by lower COVID-19 related costs.
Average loans increased $17.0decreased $30.8 billion to $295.6$279.6 billion primarily driven by increasesa decline in residential mortgagesmortgage and credit card partially offsetloans.
The table below provides key performance indicators for Consumer Lending. Management uses these metrics, and we believe they are useful to investors because they provide additional information about loan growth and profitability.
Key Statistics – Consumer Lending
(Dollars in millions)20212020
Total credit card (1)
Gross interest yield (2)
10.17 %10.27 %
Risk-adjusted margin (3)
10.17 9.16 
New accounts (in thousands)3,594 2,505 
Purchase volumes$311,571 $251,599 
Debit card purchase volumes$473,770 $384,503 
(1)Includes GWIM's credit card portfolio.
(2)Calculated as the effective annual percentage rate divided by lower home equityaverage 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)2019 2018
Total credit card (1)
   
Gross interest yield10.76% 10.12%
Risk-adjusted margin8.28
 8.25
New accounts (in thousands)4,320
 4,544
Purchase volumes$277,852
 $264,706
Debit card purchase volumes$360,672
 $338,810
(1)
Includes GWIM's credit card portfolio.
During 2019,2021, the total credit card risk-adjusted margin increased 3101 bps compared to 2018, primarily driven by a portfolio shift away from promotional-rate loans.lower net credit losses, higher fee income and higher net interest margin. Total credit card purchase volumes increased $13.1$60.0 billion to $277.9$311.6 billion and debitas spending continued to recover, with improvements across all categories. Debit card purchase volumes increased $21.9$89.3 billion to $360.7$473.8 billion reflecting higher levelsdue to continued retail growth from the pandemic recovery, as well as the impact of consumer spending.government stimulus measures, and tax refunds.
Key Statistics – Loan Production (1)
(Dollars in millions)20212020
Consumer Banking:
First mortgage$45,976 $43,197 
Home equity3,996 6,930 
Total (2):
First mortgage$79,692 $69,086 
Home equity4,895 8,160 
    
Key Statistics – Loan Production (1)
    
(Dollars in millions)2019 2018
Total (2):
   
First mortgage$72,467
 $41,195
Home equity11,131
 14,869
Consumer Banking:   
First mortgage$49,179
 $27,280
Home equity9,755
 13,251
(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.
(1)
(2)
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 infor Consumer Bankingand for the total Corporation increased $21.9$2.8 billion and $31.3$10.6 billion in 2019during 2021 primarily driven by a lower interest rate environment driving higher first-lien mortgage refinances.demand.
Home equity production in Consumer Bankingand for the total Corporation decreased $3.5 billion and$3.7decreased $2.9 billion in 2019and $3.3 billion during 2021 primarily driven by lower demand.demand due to increased borrower liquidity.



39Bank of America34


Global Wealth & Investment Management
(Dollars in millions)20212020% Change
Net interest income$5,664 $5,468 %
Noninterest income:
Investment and brokerage services14,312 12,270 17 
All other income772 846 (9)
Total noninterest income15,084 13,116 15 
Total revenue, net of interest expense20,748 18,584 12 
Provision for credit losses(241)357 n/m
Noninterest expense15,258 14,160 
Income before income taxes5,731 4,067 41 
Income tax expense1,404 996 41 
Net income$4,327 $3,071 41 
Effective tax rate24.5 %24.5 %
Net interest yield1.51 1.73 
Return on average allocated capital26 21 
Efficiency ratio73.54 76.19 
Balance Sheet
Average
Total loans and leases$196,899 $183,402 %
Total earning assets374,273 316,008 18 
Total assets386,918 328,384 18 
Total deposits340,124 287,123 18 
Allocated capital16,500 15,000 10 
Year end
Total loans and leases$208,971 $188,562 11 %
Total earning assets425,112 356,873 19 
Total assets438,275 369,736 19 
Total deposits390,143 322,157 21 
       
(Dollars in millions)2019 2018 % Change
Net interest income$6,504
 $6,265
 4 %
Noninterest income:     
Investment and brokerage services11,870
 11,959
 (1)
All other income1,163
 1,229
 (5)
Total noninterest income13,033
 13,188
 (1)
Total revenue, net of interest expense19,537
 19,453
 
      
Provision for credit losses82
 86
 (5)
Noninterest expense13,823
 14,015
 (1)
Income before income taxes5,632
 5,352
 5
Income tax expense1,380
 1,364
 1
Net income$4,252
 $3,988
 7
      
Effective tax rate24.5% 25.5%  
      
Net interest yield2.33
 2.41
  
Return on average allocated capital29
 28
  
Efficiency ratio70.75
 72.04
  
      
Balance Sheet      
    
Average     
Total loans and leases$168,910
 $161,342
 5 %
Total earning assets279,684
 259,808
 8
Total assets292,003
 277,220
 5
Total deposits256,505
 241,256
 6
Allocated capital14,500
 14,500
 
      
Year end     
Total loans and leases$176,600
 $164,854
 7 %
Total earning assets287,212
 287,199
 
Total assets299,756
 305,907
 (2)
Total deposits263,103
 268,700
 (2)
n/m = not meaningful
GWIM consists of two primary businesses: Merrill Lynch Global Wealth Management (MLGWM)(MWM) and Bank of America Private Bank.
MLGWM’sMWM'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. MLGWMMWM provides tailored solutions to meet clients’clients' needs through a full set of investment management, brokerage, banking and retirement products.
Bank of America Private Bank, together with MLGWM’sMWM's Private Wealth Management business, provides comprehensive wealth management solutions targeted to high net worth and ultra high net worth clients, as well as customized solutions to meet clients’clients' wealth structuring, investment management, trust and banking needs, including specialty asset management services.
Net income for GWIM increased $264 million$1.3 billion to $4.3 billion due to lowerdriven by higher revenue and improvement in the provision for credit losses, partially offset by higher noninterest expense and higher revenue.expense. The operating margin was 2928 percent compared to 2822 percent in 2018.a year ago.
Net interest income increased $239$196 million to $6.5$5.7 billion due to the impactbenefits of loan and deposit growth, in deposits and loans.partially offset by lower interest rates.
Noninterest income, which primarily includes investment and brokerage services income, decreased $155 millionincreased $2.0 billion to $13.0 billion. The decrease was$15.1
billion primarily drivendue to higher market valuations and positive AUM flows, partially offset by declines in AUM pricingpricing.
The provision for credit losses improved $598 million to a benefit of $241 million primarily due to improvements in the macroeconomic outlook and transactional revenue, partially offset by the impact of positive AUM flows and higher market valuations.
credit quality. Noninterest expense decreased $192 millionincreased $1.1 billion to $13.8$15.3 billion as investments for business growth were more than offsetprimarily driven by lower amortization of intangibles and FDIC expense.higher revenue-related incentives.
The return on average allocated capital was 2926 percent, up from 2821 percent, due to higher net income.income, partially offset by an increase in allocated capital. For more information on capital allocated to the business segments, see Business Segment Operations on page 36.
MLGWMAverage loans increased $13.5 billion to $196.9 billion primarily driven by securities-based lending, custom lending and residential mortgage. Average deposits increased $53.0 billion to $340.1 billion primarily driven by inflows from new accounts and client responses to market volatility.
MWM revenue of $16.1$17.4 billion increased one14 percent primarily driven by the benefits of higher net interest income and the impact ofmarket valuations, positive AUM flows and higher market valuations, partially offset by lower transactional volumesloan and AUM pricing.deposit growth.
Bank of America Private Bank revenue of $3.4$3.3 billion decreased one percent primarily dueremained relatively flat with the benefits of higher market valuations, AUM flows, and loan and deposit growth mostly offset by the realignment of certain business results to lower net interest income.MWM.

35Bank of America40






   
Key Indicators and Metrics   Key Indicators and Metrics
   
(Dollars in millions, except as noted)2019 2018
(Dollars in millions)(Dollars in millions)20212020
Revenue by Business   Revenue by Business
Merrill Lynch Global Wealth Management$16,111
 $15,998
Merrill Wealth ManagementMerrill Wealth Management$17,448 $15,292 
Bank of America Private Bank3,426
 3,455
Bank of America Private Bank3,300 3,292 
Total revenue, net of interest expense$19,537

$19,453
Total revenue, net of interest expense$20,748 $18,584 
   
Client Balances by Business, at year end   
Merrill Lynch Global Wealth Management$2,558,102
 $2,193,562
Client Balances by Business, at period endClient Balances by Business, at period end
Merrill Wealth ManagementMerrill Wealth Management$3,214,881 $2,808,340 
Bank of America Private Bank489,690
 427,294
Bank of America Private Bank625,453 541,464 
Total client balances$3,047,792
 $2,620,856
Total client balances$3,840,334 $3,349,804 
   
Client Balances by Type, at year end   
Client Balances by Type, at period endClient Balances by Type, at period end
Assets under management$1,275,555
 $1,072,234
Assets under management$1,638,782 $1,408,465 
Brokerage and other assets1,372,733
 1,162,997
Brokerage and other assets1,655,021 1,479,614 
Deposits263,103
 268,700
Deposits390,143 322,157 
Loans and leases (1)
179,296
 167,938
Loans and leases (1)
212,251 191,124 
Less: Managed deposits in assets under management(42,895) (51,013)Less: Managed deposits in assets under management(55,863)(51,556)
Total client balances$3,047,792
 $2,620,856
Total client balances$3,840,334 $3,349,804 
   
Assets Under Management Rollforward   Assets Under Management Rollforward
Assets under management, beginning of year$1,072,234
 $1,121,383
Assets under management, beginning of periodAssets under management, beginning of period$1,408,465 $1,275,555 
Net client flows24,865
 44,607
Net client flows66,250 19,596 
Market valuation/other
178,456
 (93,756)
Market valuation/other
164,067 113,314 
Total assets under management, end of year$1,275,555

$1,072,234
Total assets under management, end of periodTotal assets under management, end of period$1,638,782 $1,408,465 
   
Associates, at year end   
Number of financial advisors17,458
 17,518
Total wealth advisors, including financial advisors19,440
 19,459
Total primary sales professionals, including financial advisors and wealth advisors20,586
 20,586
   
Merrill Lynch Global Wealth Management Metric   
Financial advisor productivity (in thousands)$1,082
 $1,034
Total wealth advisors, at period end (2)
Total wealth advisors, at period end (2)
18,846 20,103 
   
Bank of America Private Bank Metric, at year end   
Primary sales professionals1,766
 1,748
(1)
(1)Includes margin receivables which are classified in customer and other receivables on the Consolidated Balance Sheet.
(2)Includes advisors across all wealth management businesses in GWIM and Consumer Banking. Prior period has been revised to conform to current-period presentation.
Includes margin receivables which are classified in customer and other receivables on the Consolidated Balance Sheet.
Client Balances
Client balances managed under advisory and/or discretion of GWIM are AUM and are typically held in diversified portfolios. Fees earned on AUM are calculated as a percentage of clients’ AUM balances. The asset management fees charged to clients per year depend on various factors, but are commonly driven by the breadth of the client’s relationship. The net client AUM flows represent the
represent the net change in clients’ AUM balances over a specified period of time, excluding market appreciation/depreciation and other adjustments.
Client balances increased $426.9$490.5 billion, or 1615 percent, to $3.0$3.8 trillion at December 31, 20192021 compared to December 31, 2018.2020. The increase in client balances was primarily due to higher market valuations and positive net flows over the last year.client flows.


41Bank of America36


Global Banking
      
(Dollars in millions)(Dollars in millions)2019 2018 % Change(Dollars in millions)20212020% Change
Net interest incomeNet interest income$10,675
 $10,993
 (3)%Net interest income$8,511 $9,013 (6)%
Noninterest income:Noninterest income:     Noninterest income:
Service chargesService charges3,015
 3,027
 
Service charges3,523 3,238 
Investment banking feesInvestment banking fees3,137
 2,891
 9
Investment banking fees5,107 4,010 27 
All other incomeAll other income3,656
 3,090
 18
All other income3,734 2,726 37 
Total noninterest incomeTotal noninterest income9,808
 9,008
 9
Total noninterest income12,364 9,974 24 
Total revenue, net of interest expenseTotal revenue, net of interest expense20,483
 20,001
 2
Total revenue, net of interest expense20,875 18,987 10 
     
Provision for credit lossesProvision for credit losses414
 8
 n/m
Provision for credit losses(3,201)4,897 n/m
Noninterest expenseNoninterest expense9,017
 8,745
 3
Noninterest expense10,632 9,342 14 
Income before income taxesIncome before income taxes11,052
 11,248
 (2)Income before income taxes13,444 4,748 n/m
Income tax expenseIncome tax expense2,984
 2,923
 2
Income tax expense3,630 1,282 n/m
Net incomeNet income$8,068
 $8,325
 (3)Net income$9,814 $3,466 n/m
     
Effective tax rateEffective tax rate27.0% 26.0%  Effective tax rate27.0 %27.0 %
     
Net interest yieldNet interest yield2.75
 3.01
  Net interest yield1.55 1.86 
Return on average allocated capitalReturn on average allocated capital20
 20
  Return on average allocated capital23 
Efficiency ratioEfficiency ratio44.02
 43.72
  Efficiency ratio50.93 49.20 
     
Balance Sheet      Balance Sheet
     
AverageAverage     Average
Total loans and leasesTotal loans and leases$374,304
 $354,236
 6 %
Total loans and leases
$329,655 $382,264 (14)%
Total earning assetsTotal earning assets388,152
 364,748
 6
Total earning assets549,749 485,688 13 
Total assetsTotal assets443,083
 425,675
 4
Total assets611,304 542,302 13 
Total depositsTotal deposits362,731
 336,337
 8
Total deposits522,790 456,562 15 
Allocated capitalAllocated capital41,000
 41,000
 
Allocated capital42,500 42,500 — 
     
Year endYear end     Year end
Total loans and leasesTotal loans and leases$379,268
 $365,717
 4 %Total loans and leases$352,933 $339,649 %
Total earning assetsTotal earning assets407,180
 377,812
 8
Total earning assets574,583 522,650 10 
Total assetsTotal assets464,032
 442,330
 5
Total assets638,131 580,561 10 
Total depositsTotal deposits383,180
 360,248
 6
Total deposits551,752 493,748 12 
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 decreased $257 millionincreased $6.3 billion to $8.1$9.8 billion in 2019 compared to 2018 primarily driven by higherimprovement in the provision for credit losses and noninterest expensehigher revenue, partially offset by higher revenue.noninterest expense.
Revenue increased $482Net interest income decreased $502 million to $20.5$8.5 billion
primarily due to the impact of lower average loan balances and deposit spreads, partially offset by the benefits of higher deposit balances and credit spreads.
Noninterest income increased $2.4 billion to $12.4 billion driven by higher noninterestinvestment banking fees, higher valuation-driven adjustments on the fair value loan portfolio, debt securities and leveraged loans, higher income partially offset by lower net interest income. Net interest income decreased $318 millionfrom ESG investment activities, as well as higher treasury and credit service charges.
The provision for credit losses improved $8.1 billion to $10.7a benefit of $3.2 billion primarily driven by reserve releases due to improvements in the allocation of ALM resultsmacroeconomic outlook and credit spread compression, partly offset by growth in loan and deposit balances.quality.
Noninterest incomeexpense increased $800 million$1.3 billion to $9.8$10.6 billion, primarily due to higher leasing-related revenuerevenue-related incentives and investment banking fees. The provision for credit losses increased $406 million to $414 million primarily driven by reserve releases in 2018 primarily from energy exposures. Noninterest expense increased $272 million primarily due to continued investment in the business partially offset by lower FDIC expense.higher operating costs.
The return on average allocated capital was 2023 percent, in 2019 and 2018.up from eight percent, due to higher net income. For more information on capital allocated to the business segments, see Business Segment Operations on page 32.36.
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.

37Bank of America42








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.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)2019 2018 2019 2018 2019 2018 2019 2018(Dollars in millions)20212020202120202021202020212020
RevenueRevenue               Revenue
Business LendingBusiness Lending$3,994
 $3,904
 $4,132
 $4,330
 $363
 $431
 $8,489
 $8,665
Business Lending$3,725 $3,552 $3,676 $3,743 $225 $261 $7,626 $7,556 
Global Transaction ServicesGlobal Transaction Services3,994
 3,832
 3,499
 3,346
 1,064
 987
 8,557
 8,165
Global Transaction Services3,127 2,986 3,209 3,169 889 893 7,225 7,048 
Total revenue, net of interest expenseTotal revenue, net of interest expense$7,988
 $7,736
 $7,631
 $7,676
 $1,427
 $1,418
 $17,046
 $16,830
Total revenue, net of interest expense$6,852 $6,538 $6,885 $6,912 $1,114 $1,154 $14,851 $14,604 
              
Balance Sheet                Balance Sheet
                
AverageAverage               Average
Total loans and leasesTotal loans and leases$177,713
 $163,516
 $181,485
 $174,279
 $15,058
 $16,432
 $374,256
 $354,227
Total loans and leases
$150,159 $179,393 $161,012 $182,212 $12,763 $14,410 $323,934 $376,015 
Total depositsTotal deposits177,924
 163,559
 144,620
 135,337
 40,196
 37,462
 362,740
 336,358
Total deposits251,303 216,371 213,708 191,813 56,321 48,214 521,332 456,398 
               
Year endYear end               Year end
Total loans and leasesTotal loans and leases$181,409
 $174,378
 $182,727
 $175,937
 $15,152
 $15,402
 $379,288
 $365,717
Total loans and leases$163,027 $153,126 $175,228 $164,641 $12,822 $13,242 $351,077 $331,009 
Total depositsTotal deposits185,352
 173,183
 157,322
 149,118
 40,504
 37,973
 383,178
 360,274
Total deposits259,160 233,484 232,670 207,597 57,848 52,150 549,678 493,231 
Business Lending revenue decreased $176increased $70 million in 20192021 compared to 2018. The decrease was2020 primarily drivendue to higher credit spreads and income from ESG investment activities, partially offset by the allocationimpact of ALM results, partly offset by higher leasing-related revenue.lower average loan balances.
Global Transaction Services revenue increased$392 $177 million in 20192021 compared to 20182020 driven by the impactbenefit of higher deposit balances.balances and treasury service charges, partially offset by lower deposit spreads.
Average loans and leases increasedsixdecreased 14 percent in 20192021 compared to 20182020 driven by growth in the commercialclient paydowns and industrial portfolio.lower demand. Average deposits increased eight14 percent dueprimarily driven by elevated balances from prior-year inflows on client responses to growth in domesticmarket volatility and international interest-bearing balances.government stimulus measures.
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 FeesInvestment Banking Fees      Investment Banking Fees
Global BankingTotal Corporation
  
 Global Banking Total Corporation
(Dollars in millions) 2019 2018 2019 2018(Dollars in millions)2021202020212020
Products        Products
Advisory $1,336
 $1,153
 $1,460
 $1,258
Advisory$2,139 $1,458 $2,311 $1,621 
Debt issuance 1,348
 1,326
 3,107
 3,084
Debt issuance1,736 1,555 4,015 3,443 
Equity issuance 453
 412
 1,259
 1,183
Equity issuance1,232 997 2,784 2,328 
Gross investment banking fees 3,137
 2,891
 5,826
 5,525
Gross investment banking fees5,107 4,010 9,110 7,392 
Self-led deals (62) (68) (184) (198)Self-led deals(93)(93)(223)(212)
Total investment banking fees $3,075
 $2,823
 $5,642
 $5,327
Total investment banking fees$5,014 $3,917 $8,887 $7,180 
Total Corporation investment banking fees, excluding self-led deals, of $5.6$8.9 billion, which are primarily included within Global Banking and Global MarketsMa,rkets, increased six24 percent due to increases inprimarily driven by higher advisory fees as well as higher debt issuance and equity issuance fees.

43Bank of America38



Global Markets
       
(Dollars in millions)2019 2018 % Change
Net interest income$3,915
 $3,857
 2 %
Noninterest income:     
Investment and brokerage services1,738
 1,780
 (2)
Investment banking fees2,288
 2,296
 
Market making and similar activities7,065
 7,260
 (3)
All other income608
 990
 (39)
Total noninterest income11,699
 12,326
 (5)
Total revenue, net of interest expense15,614
 16,183
 (4)
      
Provision for credit losses(9) 
 n/m
Noninterest expense10,722
 10,835
 (1)
Income before income taxes4,901
 5,348
 (8)
Income tax expense1,397
 1,390
 1
Net income$3,504
 $3,958
 (11)
      
Effective tax rate28.5% 26.0%  
      
Return on average allocated capital10
 11
  
Efficiency ratio68.67
 66.96
  
      
Balance Sheet      
Average     
Trading-related assets:     
Trading account securities$246,335
 $215,112
 15 %
Reverse repurchases116,883
 125,084
 (7)
Securities borrowed83,216
 78,889
 5
Derivative assets43,271
 46,047
 (6)
Total trading-related assets489,705
 465,132
 5
Total loans and leases71,334
 72,651
 (2)
Total earning assets476,225
 473,383
 1
Total assets679,297
 666,000
 2
Total deposits31,380
 31,209
 1
Allocated capital35,000
 35,000
 
      
Year end     
Total trading-related assets$452,496
 $447,998
 1 %
Total loans and leases72,993
 73,928
 (1)
Total earning assets471,701
 457,224
 3
Total assets641,806
 641,923
 
Total deposits34,676
 37,841
 (8)
n/m = not meaningful
(Dollars in millions)20212020% Change
Net interest income$4,011 $4,646 (14)%
Noninterest income:
Investment and brokerage services1,979 1,973 — 
Investment banking fees3,616 2,991 21 
Market making and similar activities8,760 8,471 
All other income889 684 30 
Total noninterest income15,244 14,119 
Total revenue, net of interest expense19,255 18,765 
Provision for credit losses65 251 (74)
Noninterest expense13,032 11,417 14 
Income before income taxes6,158 7,097 (13)
Income tax expense1,601 1,845 (13)
Net income$4,557 $5,252 (13)
Effective tax rate26.0 %26.0 %
Return on average allocated capital12 15 
Efficiency ratio67.68 60.84 
Balance Sheet
Average
Trading-related assets:
Trading account securities$291,505 $243,519 20 %
Reverse repurchases113,989 104,697 
Securities borrowed100,292 87,125 15 
Derivative assets43,582 47,655 (9)
Total trading-related assets549,368 482,996 14 
Total loans and leases91,339 73,062 25 
Total earning assets541,391 482,171 12 
Total assets785,998 685,047 15 
Total deposits51,833 47,400 
Allocated capital38,000 36,000 
Year end
Total trading-related assets$491,160 $421,698 16 %
Total loans and leases114,846 78,415 46 
Total earning assets561,135 447,350 25 
Total assets747,794 616,609 21 
Total deposits46,374 53,925 (14)
Global Markets offers sales and trading services and research services to institutional clients across fixed-income, credit, currency, commodity and equity businesses. Global Markets product coverage includes securities and derivative products in both the primary and secondary markets. Global Markets provides market-making, financing, securities clearing, settlement and custody services globally to our institutional investor clients in support of their investing and trading activities. We also work with our commercial and corporate clients to provide risk management products using interest rate, equity, credit, currency and commodity derivatives, foreign exchange, fixed-income and mortgage-related products. As a result of our market-making activities in these products, we may be required to manage risk in a broad range of financial products including government securities, equity and equity-linked securities, high-grade and high-yield corporate debt securities, syndicated loans, MBS, commodities and asset-backed securities. The economics of certain investment banking and underwriting activities are shared primarily between Global Markets and Global Banking under an 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 38.43.
The following explanations for year-over-year changes in results for Global Markets, including those disclosed under Sales and Trading Revenue, excludeare the same for amounts including and excluding net DVA. Amounts excluding net DVA but the explanations would be the same ifare a non-GAAP financial measure. For more information on net DVA, was included.see Supplemental Financial Data on page 31.
Net income for Global Marketsdecreased $454$695 million to $3.5 billion in 2019 compared to 2018.$4.6 billion. Net DVA losses were $222$54 million compared to losses of $162$133 million in 2018.2020. Excluding net DVA, net income decreased $408$755 million to $3.7$4.6 billion. These decreases were primarily driven by a decrease in revenue,higher noninterest expense, partially offset by higher revenue and lower noninterest expense.provision for credit losses.
Revenue declined $569increased $490 million to $15.6$19.3 billion asprimarily driven by higher investment banking fees and sales and trading revenue. Sales and trading revenue decreased $492increased $172 million, and excluding net DVA, decreased $432increased $93 million. These decreasesincreases were primarily driven by a declinehigher revenue in Equities, revenue. partially offset by lower revenue in FICC.
The provision for credit losses decreased $186 million primarily due to an improved macroeconomic outlook.
Noninterest expense decreased $113 millionincreased $1.6 billion to $10.7$13.0 billion primarily driven by lowerhigher revenue-related expenses.expenses for sales and trading as well as costs associated with processing
Bank of America 44


transactional card claims related to state unemployment benefits.
Average total assets increased $13.3$101.0 billion to $679.3$786.0 billion. Year-end total assets increased $131.2 billion to $747.8 billion. Both increases were primarily due to increasedhigher client balances in Equities and higher levels of inventory and loan growth in fixed-income, currencies and commodities (FICC) to facilitate expected client demand. Year-end total assets were largely unchanged at $641.8 billion.FICC.
The return on average allocated capital was 1012 percent, down from 1115 percent, reflecting lower net income.income and an increase in allocated capital. For more information on

39Bank of America






capital allocated to the business segments, see Business Segment Operations on page 32.36.
Sales and Trading Revenue
Sales and trading revenue includes unrealized and realized gains and losses on trading and other assets which are included in market making and similar activities, net interest income, and fees primarily from commissions on equity securities. Sales and trading revenue is segregated into fixed-income (government debt obligations, investment and non-investment grade corporate debt obligations, commercial MBS, residential mortgage-backed securities, collateralized loan obligations, interest rate and credit derivative contracts), currencies (interest rate and foreign exchange contracts), commodities (primarily futures, forwards, swaps and options) and equities (equity-linked derivatives and cash equity activity). The following table and related discussion present sales and trading revenue, substantially all of which is in Global Markets, with the remainder in Global Banking. In addition, the following table and related discussion present sales and trading revenue,
excluding net DVA, which is a non-GAAP financial measure. For more information on net DVA, see Supplemental Financial Data on page 27.31.
Sales and Trading Revenue (1, 2, 3)
(Dollars in millions)20212020
Sales and trading revenue
Fixed income, currencies and commodities$8,761 $9,595 
Equities6,428 5,422 
Total sales and trading revenue$15,189 $15,017 
Sales and trading revenue, excluding net DVA (4)
Fixed income, currencies and commodities$8,810 $9,725 
Equities6,433 5,425 
Total sales and trading revenue, excluding net DVA$15,243 $15,150 
(1)For more information on sales and trading revenue, see Note 3 – Derivatives to the Consolidated Financial Statements.
(2)Includes FTE adjustments of $421 million and $196 million for 2021 and 2020.
(3)    Includes Global Banking sales and trading revenue of $510 million and $479 million for 2021 and 2020.
    
Sales and Trading Revenue (1, 2, 3)
    
(Dollars in millions)2019 2018
Sales and trading revenue (2)
   
Fixed-income, currencies and commodities$8,188
 $8,271
Equities4,491
 4,900
Total sales and trading revenue$12,679
 $13,171
    
Sales and trading revenue, excluding net DVA (4)
   
Fixed-income, currencies and commodities$8,396
 $8,413
Equities4,505
 4,920
Total sales and trading revenue, excluding net DVA$12,901
 $13,333
(1)(4)    FICC and Equities sales and trading revenue, excluding net DVA, is a non-GAAP financial measure. FICC net DVA losses were $49 million and $130 million for 2021 and 2020. Equities net DVA losses were $5 million and $3 million for 2021 and 2020.
For more information on sales and trading revenue, see Note 3 – Derivatives to the Consolidated Financial Statements.
(2)
Includes FTE adjustments of $189 million and $248 million for 2019 and 2018.
(3)
Includes Global Banking sales and trading revenue of $533 million and $421 million for 2019 and 2018.
(4)
FICC and Equities sales and trading revenue, excluding net DVA, is a non-GAAP financial measure. FICC net DVA losses were $208 million and $142 million for 2019 and 2018. Equities net DVA losses were $14 million and $20 million for 2019 and 2018.
FICC revenue decreased $17 million. Equities revenue decreased $415$915 million driven by underreduced activity in macro products, partially offset by stronger performance in equity derivatives compared tocredit and municipal products, and gains in commodities (partially offset by related losses in another segment) from market volatility driven by a strong prior year which benefited from higherweather-related event in the first quarter of 2021. Equities revenue increased $1.0 billion driven by growth in client activityfinancing activities, a stronger trading performance and a more volatile market environment.increased client activity.
All Other
(Dollars in millions)20212020% Change
Net interest income$246 $34 n/m
Noninterest income (loss)(5,589)(3,605)55 %
Total revenue, net of interest expense(5,343)(3,571)50 
Provision for credit losses(182)50 n/m
Noninterest expense1,519 1,412 
Loss before income taxes(6,680)(5,033)33 
Income tax benefit(8,069)(4,634)74 
Net income (loss)$1,389 $(399)n/m
Balance Sheet
Year Ended December 31
Average20212020% Change
Total loans and leases$18,447 $28,159 (34)%
Total assets (1)
191,831 228,783 (16)
Total deposits16,512 18,247 (10)
Year endDecember 31
2021
December 31
2020
% Change
Total loans and leases$15,863 $21,301 (26)%
Total assets (1)
214,153 264,141 (19)
Total deposits21,182 12,998 63 
       
(Dollars in millions)2019 2018 % Change
Net interest income$234
 $632
 (63)%
Noninterest income (loss)(2,616) (2,257) 16
Total revenue, net of interest expense(2,382) (1,625) 47
      
Provision for credit losses(669) (476) 41
Noninterest expense3,720
 1,887
 97
Loss before income taxes(5,433) (3,036) 79
Income tax benefit(4,055) (2,780) 46
Net loss$(1,378) $(256) n/m
       
Balance Sheet      
     
Average      
Total loans and leases$42,933
 $61,013
 (30)%
Total assets (1)
210,771
 199,978
 5
Total deposits21,434
 21,966
 (2)
       
Year end      
Total loans and leases$37,151
 $48,061
 (23)%
Total assets (1)
224,466
 195,466
 15
Total deposits23,166
 18,541
 25
(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. Average allocated assets were $1.1 trillion and $763.1 billion for 2021 and 2020, and year-end allocated assets were $1.2 trillion and $977.7 billion at December 31, 2021 and 2020.
In segments where the total of liabilities and equity exceeds assets, which are generally deposit-taking segments, we allocate assets from All Other to those segments to match liabilities (i.e., deposits) and allocated shareholders’ equity. Average allocated assets were 544.2 billion and $517.0 billion for 2019 and 2018, and year-end allocated assets were $565.3 billion and $540.8 billion at December 31, 2019 and 2018.
n/m = not meaningful
All Other primarily consists of ALM activities, equity investments, non-core mortgage loans and servicing activities, liquidating businesses and certain expenses not otherwise allocated to a business segment. ALM activities encompass certain residential mortgages, debt securities, and interest rate and foreign currency risk management activities. Substantiallyactivities for which substantially all of the results of ALM activities are allocated to our business segments. For more information on our ALM activities, see Note 2423 – Business Segment Information to the Consolidated Financial Statements. Equity investments include our merchant services joint venture, as well as a portfolio of equity, real estate and other alternative investments. For information on our merchant services joint venture, see
Net income increased Note 13 – Commitments and Contingencies$1.8 billion to $1.4 billion primarily due to a higher income tax benefit and improvement in the Consolidated Financial Statements.
Residential mortgage loans that are heldprovision for ALM purposes, including interest rate or liquidity risk management, are classified as core and are presented on the balance sheet of All Other. During 2019, residential mortgage loans held for ALM activities decreased $3.2 billion to $21.7 billion primarily as a result of payoffs and paydowns. Non-core residential mortgage and home equity loans, which are principally runoff portfolios, are also held in All Other. During 2019, total non-core loans decreased $7.8 billion to $15.7 billion due primarily to payoffs, paydowns and sales, as well as Federal Housing Administration (FHA) loan conveyances,credit losses, partially offset by repurchases. For more informationlower revenue.
Revenue decreased $1.8 billionprimarily due to higher partnership losses for ESG investments and a $704 million gain on sales of certain mortgage loans in the composition of the core and non-core portfolios, see Consumer Portfolio Credit Risk Management on page 54.prior year.

45Bank of America40


The net loss for All Otherincreased$1.1 billion to a net loss of $1.4 billion, primarily driven by the $2.1 billion pretax impairment charge disclosed in Executive Summary – Recent Developments – Merchant Services Joint Venture, as well as lower revenue, partially offset by a higher benefit in the provision for credit losses.
Revenue decreased $757losses improved $232 million due to lower net interest income and an increase in the loss in noninterest income. Net interest income decreased $398 million due to the impacta benefit of non-core consumer real estate loan sales and portfolio run-off. The loss in noninterest income increased $359$182 million primarily due to lower gains on salesan improved macroeconomic outlook.
Noninterest expense increased $107 million primarily due to higher technology costs and the realignment of non-core consumer loans and higher partnership losses associated with an increase a liquidating business activity from Global Markets to All Other in tax-advantaged investments,the fourth quarter of 2021, partially offset by a $729 million charge related lower litigation expense. For more information on realignment of the business activity, see Note 23 – Business Segment Information to the redemption of certain trust preferred securities in 2018.
Noninterest expense increased $1.8 billion to $3.7 billion primarily due to the aforementioned $2.1 billion pretax impairment charge.Consolidated Financial Statements.
The income tax benefit was $4.1$8.1 billion in 2021 compared to a benefit of $2.8$4.6 billion in 2018.2020. The increase in the tax benefit was primarily driven by the impact of U.K. tax effect of the higher pretax loss, the positive impact from the resolution of various tax controversy matterslaw changes and a higher level ofincreased income tax credits.credits in 2021. For more information on U.K. tax law changes, see Financial Highlights – Income Tax Expense on page 29. Both years included income tax benefit adjustments to eliminate the FTE treatment of certain tax credits recorded in Global Banking.
Off-Balance Sheet Arrangements and Contractual Obligations
We have contractual obligations to make future payments on debt and lease agreements. Additionally, in the normal course of business, we enter into contractual arrangements whereby we commit to future purchases of products or services from unaffiliated parties. Purchase obligations are defined as obligations that are legally binding agreements whereby we agree
to purchase products or services with a specific minimum quantity at a fixed, minimum or variable price over a specified period of time. Included in purchase obligations are vendor contracts, the most significant of which include communication services, processing services and software contracts. Debt, lease and other obligations are more fully discussed in Note 12 – Long-term Debt and Note 13 – Commitments and Contingencies to the Consolidated Financial Statements.
Other long-term liabilities include our contractual funding obligations related to the Non-U.S. Pension Plans and Nonqualified and Other Pension Plans (together, the Plans). Obligations to the Plans are based on the current and projected obligations of the Plans, performance of the Plans’ assets, and any participant contributions, if applicable. During 2019 and 2018, we contributed $135 million and $156 million to the Plans, and we expect to make $128 million of contributions during 2020. The Plans are more fully discussed in Note 18 – Employee Benefit Plans to the Consolidated Financial Statements.
We enter into commitments to extend credit such as loan commitments, standby letters of credit (SBLCs) and commercial letters of credit to meet the financing needs of our customers. For a summary of the total unfunded, or off-balance sheet, credit extension commitment amounts by expiration date, see Credit Extension Commitments in Note 13 – Commitments and Contingencies to the Consolidated Financial Statements.
We also utilize variable interest entities (VIEs) in the ordinary course of business to support our financing and investing needs as well as those of our customers. For more information on our involvement with unconsolidated VIEs, see Note 7 – Securitizations and Other Variable Interest Entities to the Consolidated Financial Statements.
Table 10 includes certain contractual obligations at December 31, 2019 and 2018.
             
Table 10Contractual Obligations         
             
  December 31, 2019 December 31
2018
(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
Long-term debt$24,151
 $46,049
 $47,096
 $123,560
 $240,856
 $229,392
Operating lease obligations1,966
 3,265
 2,338
 4,225
 11,794
 15,770
Purchase obligations1,272
 1,126
 401
 731
 3,530
 4,048
Time deposits68,351
 4,612
 1,463
 247
 74,673
 61,039
Other long-term liabilities1,670
 1,056
 714
 659
 4,099
 3,933
Estimated interest expense on long-term debt and time deposits (1)
5,571
 8,073
 6,870
 23,871
 44,385
 56,852
Total contractual obligations$102,981

$64,181

$58,882

$153,293

$379,337

$371,034
(1)
Represents forecasted net interest expense on long-term debt and time deposits based on interest rates at December 31, 2019 and 2018. Forecasts are based on the contractual maturity dates of each liability, and are net of derivative hedges, where applicable.

41Bank of America






Representations and Warranties Obligations
For information on representations and warranties obligations in connection with the sale of mortgage loans, see Note 13 – Commitments and Contingencies to the Consolidated Financial Statements.
Managing Risk
Overview
Risk is inherent in all our business activities. Sound risk management enables us to serve our customers and deliver for our shareholders. If not managed well, risksrisk 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.
Strategic risk is the risk resulting from incorrect assumptions about external or internal factors, inappropriate business plans, ineffective business strategy execution, or failure to respond in a timely manner to changes in the regulatory, macroeconomic or competitive environments in the geographic locations in which we operate.
Credit risk is the risk of loss arising from the inability or failure of a borrower or counterparty to meet its obligations.
Market risk is the risk that changes in market conditions may adversely impact the value of assets or liabilities, or otherwise negatively impact earnings.
Liquidity risk is the inability to meet expected or unexpected cash flow and collateral needs while continuing to support our businesses and customers under a range of economic conditions.
Compliance risk is the risk of legal or regulatory sanctions, material financial loss or damage to the reputation of the Corporation arising from the failure of the Corporation to comply with the requirements of applicable laws, rules and regulations and our internal policies and procedures.
Operational risk is the risk of loss resulting from inadequate or failed processes, people and systems, or from external events.
Reputational risk is the risk that negative perceptions of the Corporation’s conduct or business practices may adversely impact its profitability or operations.
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 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 internal processes or systems, people or external events.
Reputational risk is the risk that negative perception of the Corporation may adversely impact 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 fulfillingour values and our purpose, and our values and delivering responsible growth.how we drive 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 promotespromote sound risk-taking within our risk appetite. Sustaining a culture of managing risk well
throughout the organization is critical to ourthe success of the Corporation 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 accountabilityresponsibilities for the management of risk and provides a blueprint for how the Board, through delegation of authority to committees and executive officers, establishes risk appetite and associated limits for our activities.
Executive management assesses, with Board oversight, the risk-adjusted returns of each business. Management reviews and approves the strategic and financial operating plans, as well as the capital plan and Risk Appetite Statement, and recommends them annually to the Board for approval. Our strategic plan takes into consideration return objectives and financial resources, which must align with risk capacity and risk appetite. Management sets financial objectives for each business by allocating capital and setting a target for return on capital for each business. Capital allocations and operating limits are regularly evaluated as part of our overall governance processes as the businesses and the economic environment in which we operate continue to evolve. For more information regarding capital allocations, see Business Segment Operations on page 32.36.
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 aggregatethe level of risk andwe are willing to monitor whether the Corporation’s risk profile remainstake in alignment with our strategic and capital plans.plans and ensure that the Corporation’s risk profile remains aligned with our risk appetite. Our risk appetite is formally articulated in the Risk Appetite Statement, which includes both qualitative components and quantitative limits.
Our overall capacity to take risk is limited; therefore, we prioritize the risks we take in order to maintain a strong and flexible financial position so we can withstand challenging economic conditions and take advantage of organic growth opportunities. Therefore, we set objectives and targets for capital and liquidity that are intended to permit us to continue to operate in a safe and sound manner, including during periods of stress.
Our lines of business operate with risk limits (which may include credit, market and/or operational limits, as applicable) that align with the Corporation’s risk appetite. Executive management is responsible for tracking and reporting performance measurements as well as any exceptions to guidelines or limits. The Board, and its committees when appropriate, oversee financial performance, execution of the strategic and financial operating plans, adherence to risk appetite limits and the adequacy of internal controls.
For a more detailed discussion of our risk management activities, see the discussion below and pages 4549 through 77.82.
For more information about the Corporation's risks related to the pandemic, see Item 1A. Risk Factors on page 8. These
Bank of America 46


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,documents such as committee charters, job descriptions, meeting minutes and resolutions.


Bank of America 42


The chart below illustrates the inter-relationshipinterrelationship among the Board, Board committees and management committees that have the majority of risk oversight responsibilities for the Corporation.
boalobsa09.jpg
(1) Reports to the CEO and CFO with oversight by the Audit Committeebac-20211231_g2.jpg
Board of Directors and Board Committees
The Board is composed of 1716 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 IndependentGlobal Risk Management (IRM)(GRM) and/or Corporate Audit to execute its responsibilities. The Board committees discussed below have the principal responsibility for enterprise-wide oversight of our risk management activities. Through these activities, the Board and applicable committees are provided with information on our risk profile and oversee executive management addressing key risks we face. Other Board committees, as described below, provide additional oversight of specific risks.
Each of the committees shown on the above chart regularly reports to the Board on risk-related matters within the committee’s responsibilities, which is intended to collectively provide the Board with integrated insight about our management of enterprise-wide risks.
Audit Committee
The Audit Committee oversees the qualifications, performance and independence of the Independent Registered Public Accounting Firm, the performance of our corporate audit function, the integrity of our consolidated financial statements, our compliance with legal and regulatory requirements, and makes inquiries of management or the Chief Audit Executive (CAE) to determine whether there are scope or resource limitations that impede the ability of Corporate Audit to execute its responsibilities. The Audit Committee is also responsible for overseeing compliance riskrisks pursuant to the New York Stock Exchange listing standards.
Enterprise Risk Committee
The ERC has primary responsibility for oversight of the Risk Framework and key risks we face and of the Corporation’s
overall risk appetite. It approves the Risk Framework and the Risk Appetite Statement and further recommends these documents to the Board for approval. The ERC oversees senior management’s responsibilities for the identification, measurement, monitoring and control of key risks we face. The ERC may consult with other Board committees on risk-related matters.
Other Board Committees
Our Corporate Governance, ESG, and Sustainability Committee oversees our Board’s governance processes, identifies and reviews the qualifications of potential Board members, recommends nominees for election to our Board, recommends committee appointments for Board approval and reviews our Environmental, Social and GovernanceESG and stockholder engagement activities.
Our Compensation and Human Capital Committee oversees establishing, maintaining and administering our compensation programs and employee benefit plans, including approving and recommending our Chief Executive Officer’s (CEO) compensation to our Board for further approval by all independent directors; reviewing and approving all of our executive officers’ compensation, as well as compensation for non-management directors; and reviewing certain other human capital management topics.
Management Committees
Management committees may receive their authority from the Board, a Board committee, another management committee or from one or more executive officers. Our primary management-levelmanagement risk committee is the Management Risk Committee (MRC).MRC. Subject to Board oversight, the MRC is responsible for management oversight of key risks facing the Corporation. This includes providing management oversightCorporation, including an integrated evaluation of our compliancerisk, earnings, capital 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.liquidity.
Lines of Defense
We have clear ownership and accountability for managing risk across three lines of defense: Front Line Units (FLUs), IRMGRM and Corporate Audit. We also have control functions outside of FLUs and IRMGRM (e.g., Legal and Global Human Resources). The three
47 Bank of America


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.

43Bank of America






Executive Officers
Executive officers lead various functions representing the functional roles. Authority for functional roles may be delegated to executive officers from the Board, Board committees or management-level committees. Executive officers, in turn, may further delegate responsibilities, as appropriate, to management-level committees, management routines or individuals. Executive officers review our activities for consistency with our Risk Framework, Risk Appetite Statementrisk appetite, and applicable strategic, capital and financial operating plans, as well as applicable policies standards, procedures and processes.standards. 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 Global Operations, Group, 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 IRMGRM are first, the Chief Financial Officer (CFO) Group; second, Environmental, Social and Governance (ESG), Capital Deployment (CD) and Public Policy (PP); and third, the Chief Administrative Officer (CAO) Group.Group; and third, Global Strategy and Enterprise Platforms (GSEP).
IndependentGlobal Risk Management
IRMGRM is part of our control functions and includes Global Risk Management. We have other control functions that are not part of IRM (other control functions may also provide oversight to FLU activities), including Legal, Global Human Resources and certain activities within the CFO Group; ESG, CD and PP; and CAO Group. IRM,operates as our independent risk management function. GRM, led by the Chief Risk Officer (CRO), is responsible for independently assessing and overseeing risks within FLUs and other control functions. IRMGRM establishes written enterprise policies and procedures that include concentration risk limits, where appropriate. Such policies and procedures outlineoutlining how aggregate risks are identified, measured, monitored and controlled.
The CRO has the stature, authority and independence needed to develop and implement a meaningful risk management framework.framework and practices to guide the Corporation in managing risk. The CRO has unrestricted access to the Board and reports directly to both the ERC and to the CEO. Global Risk ManagementGRM is organized into horizontal risk teams that cover a specific risk area and vertical CRO teams that cover a particular front line unitFLU or control function. These teams work collaboratively in executing their respective duties.
Corporate Audit
Corporate Audit and the CAE maintain their independence from the FLUs, IRMGRM and other control functions by reporting directly to the Audit Committee or the Board.Committee. The CAE administratively reports to the CEO. Corporate Audit provides independent assessment and validation through testing of key processes and controls across the Corporation. Corporate Audit includes Credit Review, which periodically testsprovides an independent assessment of credit lending decisions and examinesthe effectiveness of credit portfoliosprocesses across the Corporation’s credit platform through examinations and processes.monitoring.
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 ofthereby ensuring risks are appropriately
considered, evaluated and responded to in a timely manner.
We employ ouran effective 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 definedproactively identified and proactively identified.well understood. 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 incorporatingthat incorporates input from FLUs and control functions,functions. It is designed to be forward lookingforward-looking and to capture relevant risk factors across all of our lines of business.
Measure Once a risk is identified, it must be prioritized and accurately measured through a systematic risk quantification process including quantitative and qualitative components. Risk is measured at various levels, including, but not limited to, risk type, FLU and legal entity, and also on an aggregate basis. This risk quantificationmeasurement process helps to capture changes in our risk profile due to changes in strategic direction, concentrations, portfolio quality and the overall economic environment. Senior management considers how risk exposures might evolve under a variety of stress scenarios.
Monitor We monitor risk levels regularly to track adherence to risk appetite, policies standards, procedures and processes.standards. We also regularly update risk assessments and review risk exposures. Through our monitoring, we can determineknow our level of risk relative to limits and can take action in a timely manner. We also can determineknow when risk limits are breached and have processes to appropriately report and escalate exceptions. This includes timely requests for approval to managers and alerts to executive management, management-level committees or the Board (directly or through an appropriate committee).
Control We establish and communicate risk limits and controls through policies, standards, procedures and processes that define the responsibilities and authority for risk-taking.processes. 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)volume, operational loss) or relative (e.g., percentage of loan book in higher-risk categories). Our lines of businessFLUs are held accountable to performfor performing within the established limits.
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 strategyon Responsible Growth is also critical to effective risk management. We understand thatare committed to the highest principles of ethical and professional conduct. Conduct risk is the risk of improper actions, behaviors or practices that are illegal, unethical and/or contrary to our core values that could result in harm to the Corporation, our shareholders or our customers, damage the integrity of the financial markets, or negatively impact our reputation, andreputation. We have established protocols and structures so that such conduct risk is governed and reported across the Corporation. Specifically, ourCorporation appropriately. All employees are held accountable for adhering to the Code of Conduct, provides a framework for all ofoperating within our employees to conduct themselves with the highest integrity. Additionally, we continue to strengthen the link between the employeerisk appetite and managing risk in their daily business activities. In addition, our performance management process and individual compensation topractices encourage employees to work toward enterprise-wideresponsible risk-taking that is consistent with our Risk Framework and risk goals.appetite.

Bank of America 4448


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 certain subsidiaries and how they impact financial resiliency, which provides confidence to management, regulators and our investors.
Contingency Planning
We have developed and maintain contingency plans that are designed to prepare us in advance to respond in the event of potential adverse economic, financial or market stress. These contingency plans include our Capital Contingency Plan and Financial Contingency and Recovery Plan, which provide monitoring, escalation, actions and routines designed to enable us to increase capital, access funding sources and reduce risk through consideration of potential options that include asset sales, business sales, capital or debt issuances, or other de-risking strategies. We also maintain a Resolution Plan to limit adverse systemic impacts that could be associated with a potential resolution of Bank of America.
Strategic Risk Management
Strategic risk is embedded in every business and is one of the major risk categories along with credit, market, liquidity, compliance, operational and reputational risks. This risk results from incorrect assumptions about external or internal factors, inappropriate business plans, ineffective business strategy execution, or failure to respond in a timely manner to changes in the regulatory, macroeconomic or competitive environments in the geographic locations in which we operate, such as competitor actions, changing customer preferences, product obsolescence and technology developments. Our strategic plan is consistent with our risk appetite, capital plan and liquidity requirements, and specifically addresses strategic risks.
On an annual basis, the Board reviews and approves the strategic plan, capital plan, financial operating plan and Risk Appetite Statement. With oversight by the Board, executive management directs the lines of business to execute our strategic plan consistent with our core operating principles and risk appetite. The executive management team monitors business performance throughout the year and provides the Board with regular progress reports on whether strategic objectives and timelines are being met, including reports on strategic risks and if additional or alternative actions need to be considered or implemented. The regular executive reviews focus on assessing forecasted earnings and returns on capital, the current risk profile, current capital and liquidity requirements, staffing levels and changes required to support the strategic plan, stress testing results, and other qualitative factors such as market growth rates and peer analysis.
Significant strategic actions, such as capital actions, material acquisitions or divestitures, and resolution plans are reviewed and approved by the Board. At the business level, processes are in place to discuss the strategic risk implications of new, expanded or modified businesses, products or services
and other strategic initiatives, and to provide formal review and approval where required. With oversight by the Board and the ERC, executive
management performs similar analyses throughout the year, and evaluates changes to the financial forecast or the risk, capital or liquidity positions as deemed appropriate to balance and optimize achieving the targeted risk appetite, shareholder returns and maintaining the targeted financial strength. Proprietary models are used to measure the capital requirements for credit, country, market, operational and strategic risks. The allocated capital assigned to each business is based on its unique risk profile. With oversight by the Board, executive management assesses the risk-adjusted returns of each business in approving strategic and financial operating plans. The businesses use allocated capital to define business strategies, and price products and transactions.
Capital Management
The Corporation manages its capital position so that its capital is more than adequate to support its business activities and aligns with risk, risk appetite and strategic planning. Additionally, we seek to maintain safety and soundness at all times, even under adverse scenarios, take advantage of organic growth opportunities, meet obligations to creditors and counterparties, maintain ready access to financial markets, continue to serve as a credit intermediary, remain a source of strength for our subsidiaries, and satisfy current and future regulatory capital requirements. Capital management is integrated into our risk and governance processes, as capital is a key consideration in the development of our strategic plan, risk appetite and risk limits.
We conduct an Internal Capital Adequacy Assessment Process (ICAAP) on a periodic basis. The ICAAP is a forward-looking assessment of our projected capital needs and resources, incorporating earnings, balance sheet and risk forecasts under baseline and adverse economic and market conditions. We utilize periodic stress tests to assess the potential impacts to our balance sheet, earnings, regulatory capital and liquidity under a variety of stress scenarios. We perform qualitative risk assessments to identify and assess material risks not fully captured in our forecasts or stress tests. We assess the potential capital impacts of proposed changes to regulatory capital requirements. Management assesses ICAAP results and provides documented quarterly assessments of the adequacy of our capital guidelines and capital position to the Board or its committees.
We periodically review capital allocated to our businesses and allocate capital annually during the strategic and capital planning processes. For more information, see Business Segment Operations on page 32.36.
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 Comprehensive Capital Analysis and Review (CCAR) capital plan.
On June 27, 2019, following Based on the Federal Reserve’s non-objection toresults of our 20192021 CCAR capital plan and related supervisory stress tests, we are subject to a 2.5 percent stress capital buffer (SCB), unchanged from the prior level, effective October 1, 2021 through September 30, 2022. Our Common equity tier 1 (CET1) capital ratio under the Standardized approach must remain above 9.5 percent during this period in order to avoid restrictions on capital distributions and discretionary bonus payments.
Due to uncertainty resulting from the pandemic, the Federal Reserve imposed various restrictions on share repurchase programs and dividends during 2020 and the first half of 2021.
49 Bank of America


In conjunction with its release of 2021 CCAR supervisory stress test results, the Federal Reserve announced those restrictions would end as of July 1, 2021 for large banks, including the Corporation, and large banks would be subject to the normal restrictions under the Federal Reserve's SCB framework. On October 20, 2021, we announced that the Board authorizedrenewed the repurchase of approximately $30.9Corporation’s $25 billion in common stock from July 1, 2019 through June 30, 2020, which includes approximately $900 millionrepurchase program previously announced in April 2021. The Board’s authorization replaced the previous program. As with the April authorization, the Board also authorized common stock repurchases to offset shares awarded under the Corporation’s equity-based compensation plans. Pursuant to the Board’s authorization, during 2021 we repurchased $25.1 billion of common stock, including repurchases to offset shares awarded under equity-based compensation plans during the same period. During 2019, pursuant to the Board’s authorizations, including those related to our 2018 CCAR capital plan that expired June 30, 2019, we repurchased $28.1 billionplans.
The timing and amount of common stock which includes common stock repurchases made pursuant to offset equity-based compensation awards. At December 31, 2019, our remaining stock repurchase authorization was $15.6 billion.
Our stock repurchasesprogram are subject to various factors, including the Corporation’s capital position, liquidity, financial performance and alternative uses of capital, stock trading price, regulatory requirements and general

45Bank of America






market conditions, and may be suspended at any time. TheSuch 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 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, 2019,2021, the Common equity tierCET1, Tier 1 (CET1)capital and Tier 1Total capital ratios for the Corporation were lower under the Standardized approach whereas the Advanced approaches yielded a lower Total capital ratio.approach.
Minimum Capital Requirements
Minimum capital requirements and related buffers were fully phased in as of January 1, 2019. The PCA framework established categories of capitalization, including well capitalized, based on
the Basel 3 regulatory ratio requirements. U.S. banking regulators are required to take certain mandatory actions depending on the category of capitalization, with no mandatory actions required for well-capitalized banking organizations.
In order to avoid restrictions on capital distributions and discretionary bonus payments, the Corporation must meet risk-based capital ratio requirements that include a capital
conservation buffer greater thanof 2.5 percent (under the Advanced approaches only), an SCB (under the Standardized approach only), plus any applicable countercyclical capital buffer and a global systemically important bank (G-SIB) surcharge. The buffersIncluding a regulatory minimum requirement of 4.5 percent, an SCB of 2.5 percent and a G-SIB surcharge of 2.5 percent, the Corporation's CET1 capital ratio must be comprised solelya minimum of CET1 capital.9.5 percent under both the Standardized and Advanced approaches.
The Corporation is required to calculate its G-SIB surcharge on an annual basis under two methods and is subject to the higher of the resulting two surcharges. Method 1 is consistent with the approach prescribed by the Basel Committee’s assessment methodology and is calculated using specified indicators of systemic importance. Method 2 modifies the Method 1 approach by, among other factors, including a measure of the Corporation’s reliance on short-term wholesale funding. The Corporation’s G-SIB surcharge, which is higher under Method 2, is expected to increase to 3.0 percent on January 1, 2024 unless its surcharge calculated as of December 31, 2022 is lower than 3.0 percent.
The current SCB of 2.5 percent, which remains effective from October 1, 2021 through September 30, 2022, could change based on results of the 2022 CCAR capital plan and related supervisory stress tests to be submitted in the first half of 2022.
The Corporation is also required to maintain a minimum supplementary leverage ratio (SLR) of 3.0 percent plus a leverage buffer of 2.0 percent in order to avoid certain restrictions on capital distributions and discretionary bonus payments. Our insured depository institution subsidiaries are required to maintain a minimum 6.0 percent SLR to be considered well capitalized under the PCA framework. The numerator of the SLR is quarter-end Basel 3 Tier 1 capital. The denominator is total leverage exposure based on the daily average of the sum of on-balance sheet exposures less permitted Tier 1 deductions, 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. The temporary exclusions expired after March 31, 2021 and were not applicable for December 31, 2021. For more information, see Capital Management – Regulatory Developments on page 54.
Capital Composition and Ratios
Table 1110 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, 20192021 and 2018. As of2020. For the periods presented herein, the Corporation met the definition of well capitalized under current regulatory requirements.

Bank of America 4650


Table 10Table 10Bank of America Corporation Regulatory Capital under Basel 3







Table 11Bank of America Corporation Regulatory Capital under Basel 3  
  
Standardized
Approach
 Advanced
Approaches
 
Regulatory
Minimum
(1)
Standardized
Approach
(1)
Advanced
Approaches
(1)
Regulatory
Minimum
(2)
(Dollars in millions, except as noted)(Dollars in millions, except as noted)December 31, 2019(Dollars in millions, except as noted)December 31, 2021
Risk-based capital metrics:Risk-based capital metrics:     Risk-based capital metrics:
Common equity tier 1 capitalCommon equity tier 1 capital$166,760
 $166,760
  Common equity tier 1 capital$171,759 $171,759 
Tier 1 capitalTier 1 capital188,492
 188,492
  Tier 1 capital196,465 196,465 
Total capital (2)
221,230
 213,098
  
Total capital (3)
Total capital (3)
227,592 220,616 
Risk-weighted assets (in billions)Risk-weighted assets (in billions)1,493
 1,447
  Risk-weighted assets (in billions)1,618 1,399 
Common equity tier 1 capital ratioCommon equity tier 1 capital ratio11.2% 11.5% 9.5%Common equity tier 1 capital ratio10.6 %12.3 %9.5 %
Tier 1 capital ratioTier 1 capital ratio12.6
 13.0
 11.0
Tier 1 capital ratio12.1 14.0 11.0 
Total capital ratioTotal capital ratio14.8
 14.7
 13.0
Total capital ratio14.1 15.8 13.0 
      
Leverage-based metrics:Leverage-based metrics:     Leverage-based metrics:
Adjusted quarterly average assets (in billions) (3)
$2,374
 $2,374
  
Adjusted quarterly average assets (in billions) (4)
Adjusted quarterly average assets (in billions) (4)
$3,087 $3,087 
Tier 1 leverage ratioTier 1 leverage ratio7.9% 7.9% 4.0
Tier 1 leverage ratio6.4 %6.4 %4.0 
     
SLR leverage exposure (in billions)  $2,946
  
SLR  6.4% 5.0
Supplementary leverage exposure (in billions) (5)
Supplementary leverage exposure (in billions) (5)
$3,604 
Supplementary leverage ratioSupplementary leverage ratio5.5 %5.0 












December 31, 2018December 31, 2020
Risk-based capital metrics:Risk-based capital metrics:







Risk-based capital metrics:
Common equity tier 1 capitalCommon equity tier 1 capital$167,272

$167,272



Common equity tier 1 capital$176,660 $176,660 
Tier 1 capitalTier 1 capital189,038

189,038



Tier 1 capital200,096 200,096 
Total capital (2)
221,304

212,878



Total capital (3)
Total capital (3)
237,936 227,685 
Risk-weighted assets (in billions)Risk-weighted assets (in billions)1,437

1,409



Risk-weighted assets (in billions)1,480 1,371 
Common equity tier 1 capital ratioCommon equity tier 1 capital ratio11.6%
11.9%
8.25%Common equity tier 1 capital ratio11.9 %12.9 %9.5 %
Tier 1 capital ratioTier 1 capital ratio13.2

13.4

9.75
Tier 1 capital ratio13.5 14.6 11.0 
Total capital ratioTotal capital ratio15.4

15.1

11.75
Total capital ratio16.1 16.6 13.0 










Leverage-based metrics:Leverage-based metrics:







Leverage-based metrics:
Adjusted quarterly average assets (in billions) (3)
$2,258

$2,258



Adjusted quarterly average assets (in billions) (4)
Adjusted quarterly average assets (in billions) (4)
$2,719 $2,719 
Tier 1 leverage ratioTier 1 leverage ratio8.4%
8.4%
4.0
Tier 1 leverage ratio7.4 %7.4 %4.0 
      
SLR leverage exposure (in billions)  $2,791
  
SLR  6.8% 5.0
Supplementary leverage exposure (in billions) (5)
Supplementary leverage exposure (in billions) (5)
$2,786 
Supplementary leverage ratioSupplementary leverage ratio7.2 %5.0 
(1)
The capital conservation buffer and G-SIB surcharge were 2.5 percent at December 31, 2019 and 1.875 percent at December 31, 2018. The countercyclical capital buffer for both periods was zero. The SLR minimum includes a leverage buffer of 2.0 percent.
(2)
Total capital under the Advanced approaches differs from the Standardized approach due to differences in the amount permitted in Tier 2 capital related to the qualifying allowance for credit losses.
(3)
Reflects total average assets adjusted for certain Tier 1 capital deductions.
At(1)Capital ratios as of December 31, 2019,2021 and 2020 are calculated using the regulatory capital rule that allows a five-year transition period related to the adoption of the current expected credit losses (CECL) accounting standard.
(2)The capital conservation buffer and G-SIB surcharge were 2.5 percent at both December 31, 2021 and 2020. At both December 31, 2021 and 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 CET1 capital regulatory minimum is the sum of the CET1 capital ratio minimum of 4.5 percent, our G-SIB surcharge of 2.5 percent and our SCB or the capital conservation buffer, as applicable, of 2.5 percent. The SLR regulatory minimum includes a leverage buffer of 2.0 percent.
(3)Total capital under the Advanced approaches were relatively unchanged compareddiffers from the Standardized approach due to differences in the amount permitted in Tier 2 capital related to the qualifying allowance for credit losses.
(4)Reflects total average assets adjusted for certain Tier 1 capital deductions.
(5)Supplementary leverage exposure at December 31, 2018. Risk-weighted assets2020 reflects the temporary exclusion of U.S. Treasury securities and deposits at Federal Reserve Banks. The temporary relief expired after March 31, 2021 and is not reflected in supplementary leverage exposure at December 31, 2021.
At December 31, 2021, CET1 capital was $171.8 billion, a decrease of $4.9 billion from December 31, 2020, driven by common stock repurchases, dividends and decreases in net unrealized gains on available-for-sale (AFS) debt securities included in accumulated other comprehensive income (OCI), partially offset by earnings. Tier 1 capital decreased $3.6 billion primarily driven by the same factors as CET1 capital, partially offset by non-cumulative perpetual preferred stock issuances. Total capital under the Standardized approach decreased $10.3 billion primarily due to the same factors driving the decrease in CET1 capital, and a decrease in the adjusted allowance for credit losses included in Tier 2 capital. RWA under the
Standardized approach, which yielded the lower CET1 capital
ratio at December 31, 2019,2021, increased $56.3$138.1 billion during 20192021 to $1,493$1,618 billion
primarily due to loan growth and increasedin Global Banking, strong client activity in Global Markets and an increase in debt securities resulting from the deployment of cash received from deposit inflows. Supplementary leverage exposure at December 31, 2021 increased $818.1 billion during 2021 primarily due to the expiration of the Federal Reserve’s temporary relief to exclude U.S. Treasury securities and deposits at Federal Reserve Banks and an increase in debt securities resulting from the deployment of cash received from deposit inflows.
Global Banking
51 Bank of America

.
Table 1211 shows the capital composition at December 31, 20192021 and 2018.2020.
Table 11Capital Composition under Basel 3
December 31
(Dollars in millions)20212020
Total common shareholders’ equity$245,358 $248,414 
CECL transitional amount (1)
2,508 4,213 
Goodwill, net of related deferred tax liabilities(68,641)(68,565)
Deferred tax assets arising from net operating loss and tax credit carryforwards(7,743)(5,773)
Intangibles, other than mortgage servicing rights, net of related deferred tax liabilities(1,605)(1,617)
Defined benefit pension plan net assets(1,261)(1,164)
Cumulative unrealized net (gain) loss related to changes in fair value of financial liabilities attributable to own creditworthiness,
 net-of-tax
1,400 1,753 
Accumulated net (gain) loss on certain cash flow hedges (2)
1,870 (436)
Other(127)(165)
Common equity tier 1 capital171,759 176,660 
Qualifying preferred stock, net of issuance cost24,707 23,437 
Other(1)(1)
Tier 1 capital196,465 200,096 
Tier 2 capital instruments20,750 22,213 
Qualifying allowance for credit losses (3)
10,534 15,649 
Other(157)(22)
Total capital under the Standardized approach227,592 237,936 
Adjustment in qualifying allowance for credit losses under the Advanced approaches (3)
(6,976)(10,251)
Total capital under the Advanced approaches$220,616 $227,685 
(1)Includes the impact of the Corporation's adoption of the CECL accounting standard on January 1, 2020 and 25 percent of the increase in reserves since the initial adoption.
(2)Includes amounts in accumulated other comprehensive income related to the hedging of items that are not recognized at fair value on the Consolidated Balance Sheet.
(3)Includes the impact of transition provisions related to the CECL accounting standard.
     
Table 12Capital Composition under Basel 3









December 31
(Dollars in millions)2019 2018
Total common shareholders’ equity$241,409

$242,999
Goodwill, net of related deferred tax liabilities(68,570)
(68,572)
Deferred tax assets arising from net operating loss and tax credit carryforwards(5,193)
(5,981)
Intangibles, other than mortgage servicing rights and goodwill, net of related deferred tax liabilities(1,328)
(1,294)
Other442

120
Common equity tier 1 capital166,760

167,272
Qualifying preferred stock, net of issuance cost22,329

22,326
Other(597)
(560)
Tier 1 capital188,492

189,038
Tier 2 capital instruments22,538

21,887
Eligible credit reserves included in Tier 2 capital2,097

1,972
Other(29)
(19)
Total capital under the Advanced approaches$213,098

$212,878

47Bank of America






Table 1312 shows the components of risk-weighted assetsRWA as measured under Basel 3 at December 31, 20192021 and 2018.2020.
        
Table 13Risk-weighted Assets under Basel 3       
Table 12Table 12Risk-weighted Assets under Basel 3
        
Standardized Approach Advanced Approaches Standardized Approach Advanced ApproachesStandardized ApproachAdvanced ApproachesStandardized ApproachAdvanced Approaches
December 31December 31
(Dollars in billions)(Dollars in billions)2019 2018(Dollars in billions)20212020
Credit riskCredit risk$1,437
 $858
 $1,384
 $827
Credit risk$1,549 $913 $1,420 $896 
Market riskMarket risk56
 55
 53
 52
Market risk69 69 60 60 
Operational riskOperational riskn/a
 500
 n/a
 500
Operational riskn/a378 n/a372 
Risks related to credit valuation adjustmentsRisks related to credit valuation adjustmentsn/a
 34
 n/a
 30
Risks related to credit valuation adjustmentsn/a39 n/a43 
Total risk-weighted assetsTotal risk-weighted assets$1,493
 $1,447
 $1,437
 $1,409
Total risk-weighted assets$1,618 $1,399 $1,480 $1,371 
n/a = not applicable
Bank of America 52


Bank of America, N.A. Regulatory Capital
Table 1413 presents regulatory capital information for BANA in accordance with Basel 3 Standardized and Advanced approaches as measured at December 31, 20192021 and 2018.2020. BANA met the definition of well capitalized under the PCA framework for both periods.
Table 13Bank of America, N.A. Regulatory Capital under Basel 3
Standardized
Approach
(1)
Advanced
Approaches
(1)
Regulatory
Minimum 
(2)
(Dollars in millions, except as noted)December 31, 2021
Risk-based capital metrics:
Common equity tier 1 capital$182,526 $182,526 
Tier 1 capital182,526 182,526 
Total capital (3)
194,773 188,091 
Risk-weighted assets (in billions)1,352 1,048 
Common equity tier 1 capital ratio13.5 %17.4 %7.0 %
Tier 1 capital ratio13.5 17.4 8.5 
Total capital ratio14.4 17.9 10.5 
Leverage-based metrics:
Adjusted quarterly average assets (in billions) (4)
$2,414 $2,414 
Tier 1 leverage ratio7.6 %7.6 %5.0 
Supplementary leverage exposure (in billions)$2,824 
Supplementary leverage ratio6.5 %6.0 




December 31, 2020
Risk-based capital metrics:
Common equity tier 1 capital$164,593 $164,593 
Tier 1 capital164,593 164,593 
Total capital (3)
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) (4)
$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 
(1)Capital ratios for both December 31, 2021 and 2020 are calculated using the regulatory capital rule that allows a five-year transition period related to the adoption of CECL.
(2)Risk-based capital regulatory minimums at both year ends.December 31, 2021 and 2020 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.
(3)Total capital under the Advanced approaches differs from the Standardized approach due to differences in the amount permitted in Tier 2 capital related to the qualifying allowance for credit losses.
       
Table 14Bank of America, N.A. Regulatory Capital under Basel 3  
       
  Standardized
Approach
 Advanced
Approaches
 
Regulatory
Minimum 
(1)
(Dollars in millions, except as noted)

December 31, 2019
Risk-based capital metrics:     
Common equity tier 1 capital$154,626
 $154,626
  
Tier 1 capital154,626
 154,626
  
Total capital (2)
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) (3)
$1,780
 $1,780
  
Tier 1 leverage ratio8.7% 8.7% 5.0
      
SLR leverage exposure (in billions)  $2,177
  
SLR  7.1% 6.0












December 31, 2018
Risk-based capital metrics:     
Common equity tier 1 capital$149,824

$149,824

 
Tier 1 capital149,824

149,824

 
Total capital (2)
161,760
 153,627
  
Risk-weighted assets (in billions)1,195
 959
  
Common equity tier 1 capital ratio12.5% 15.6% 6.5%
Tier 1 capital ratio12.5
 15.6
 8.0
Total capital ratio13.5
 16.0
 10.0
      
Leverage-based metrics:     
Adjusted quarterly average assets (in billions) (3)
$1,719
 $1,719
  
Tier 1 leverage ratio8.7% 8.7% 5.0
      
SLR leverage exposure (in billions)  $2,112
  
SLR  7.1% 6.0
(1)(4)Reflects total average assets adjusted for certain Tier 1 capital deductions.
Risk-based capital regulatory minimums at December 31, 2019 are the minimum ratios under Basel 3 including a capital conservation buffer of 2.5 percent. The regulatory minimums for the leverage ratios as of both period ends and risk-based capital ratios as of December 31, 2018 are the percent required to be considered well capitalized under the PCA framework.
(2)
Total capital under the Advanced approaches differs from the Standardized approach due to differences in the amount permitted in Tier 2 capital related to the qualifying allowance for credit losses.
(3)
Reflects total average assets adjusted for certain Tier 1 capital deductions.
Total Loss-Absorbing Capacity Requirements
Effective January 1, 2019, the Corporation is subject to the Federal Reserve’s final rule requiring G-SIBs to maintain minimum levels of totalTotal loss-absorbing capacity (TLAC) and long-term debt. TLAC consists of the Corporation’s Tier 1 capital and eligible long-term debt issued directly by the Corporation. Eligible long-term debt for TLAC ratios is comprised of unsecured debt that has a remaining
maturity of at least one year and satisfies additional requirements as prescribed in the TLAC final rule. As with the
risk-based capital ratios and SLR, the Corporation is required to maintain TLAC ratios in excess of minimum requirements plus applicable buffers to avoid restrictions on capital distributions and discretionary bonus payments. Table 1514 presents the Corporation's TLAC and long-term debt ratios and related information as of December 31, 2019.2021 and 2020.

53Bank of America48


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

TLAC
 
Regulatory Minimum (1)
 
Long-term
Debt
 
Regulatory Minimum (2)
(Dollars in millions)

December 31, 2019
Total eligible balance$367,449
   $171,349
  
Percentage of risk-weighted assets (3)
24.6% 22.0% 11.5% 8.5%
Percentage of SLR leverage exposure12.5
 9.5
 5.8
 4.5
Table 14Bank 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, 2021
Total eligible balance$435,904 $227,714 
Percentage of risk-weighted assets (4)
26.9 %22.0 %14.1 %8.5 %
Percentage of supplementary leverage exposure (5)
12.1 9.5 6.3 4.5 
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)
14.5 9.5 7.1 4.5 
(1)
The TLAC risk-weighted assets regulatory minimum consists of 18.0 percent plus a TLAC risk-weighted assets buffer comprised of 2.5 percent plus the method 1 G-SIB surcharge of 1.5 percent. The countercyclical buffer is zero for this period. The TLAC SLR leverage exposure regulatory minimum consists of 7.5 percent plus a 2.0 percent TLAC leverage buffer. The TLAC risk-weighted assets and leverage buffers must be comprised solely of CET1 capital and Tier 1 capital, respectively.
(2)
The long-term debt risk-weighted assets regulatory minimum is comprised of 6.0 percent plus an additional 2.5 percent requirement based on the Corporation’s method 2 G-SIB surcharge. The long-term debt leverage exposure regulatory minimum is 4.5 percent.
(3)
The approach that yields the higher risk-weighted assets
(1)As of December 31, 2021 and 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 December 31, 2019.
Regulatory Capital and Securities Regulation
The Corporation’s principal U.S. broker-dealer subsidiaries are BofA Securities, Inc. (BofAS), Merrill Lynch Professional Clearing Corp. (MLPCC) and Merrill Lynch, Pierce, Fenner & Smith Incorporated (MLPF&S). BofAS was formed as a result of the reorganization of MLPF&S which was completed in May 2019. The Corporation's principal European broker-dealer subsidiaries are Merrill Lynch International (MLI)the Standardized approach as of December 31, 2021 and BofA Securities Europe SA (BofASE).2020.
The(5)Supplementary leverage exposure at December 31, 2020 reflects the temporary exclusion of U.S. broker-dealer subsidiaries are subject to the net capital requirements of Rule 15c3-1 under the Exchange Act. BofAS computes its minimum capital requirements as an alternative net capital broker-dealer under Rule 15c3-1, and MLPCC and MLPF&S compute their minimum capital requirements in accordance with the alternative standard under Rule 15c3-1. BofAS and MLPCC are also registered as futures commission merchants and are subject to U.S. Commodity Futures Trading Commission (CFTC) Regulation 1.17.
BofAS provides institutional services, and in accordance with the alternative net capital requirements, is required to maintain tentative net capital in excess of $1.0 billion and net capital in excess of the greater of $500 million or a certain percentage of its reserve requirement. BofAS must also notify theTreasury Securities and Exchange Commission (SEC)deposits at Federal Reserve Banks. The temporary relief expired after March 31, 2021 and is not reflected in the event its tentative net capital is less than $5.0 billion. BofAS is also required to hold a certain percentage of its risk-based margin in order to meet its CFTC minimum net capital requirement. Atsupplementary leverage exposure at December 31, 2019, BofAS had tentative net capital of $12.5 billion. BofAS also had regulatory net capital of $10.4 billion which exceeded the minimum requirement of $2.4 billion.2021.
MLPCC is a fully-guaranteed subsidiary of BofAS and provides clearing and settlement services. At December 31, 2019, MLPCC’s regulatory net capital of $5.3 billion exceeded the minimum requirement of $1.3 billion.
MLPF&S provides retail services. At December 31, 2019, MLPF&S' regulatory net capital was $4.1 billion which exceeded the minimum requirement of $102 million.
Our European broker-dealers are regulated by non-U.S. regulators. MLI, a U.K. investment firm, is regulated by the Prudential Regulation Authority and the FCA and is subject to certain regulatory capital requirements. At December 31, 2019, MLI’s capital resources were $34.8 billion, which exceeded the minimum Pillar 1 requirement of $13.9 billion. BofASE, a French investment firm, is regulated by the Autorité de Contrôle Prudentiel et de Résolution and the Autorité des Marchés Financiers, and is subject to certain regulatory capital requirements. At December 31, 2019, BofASE's capital resources were $5.5 billion which exceeded the minimum Pillar 1 requirement of $1.3 billion.
Regulatory Developments
RevisionsSupplementary Leverage Ratio
On March 19, 2021, U.S. banking regulators announced that temporary changes issued in 2020 for BHCs and depository institutions would expire as scheduled after March 31, 2021. These temporary changes to Basel 3the SLR allowed the exclusion of on-balance sheet amounts of U.S. Treasury securities and deposits at Federal Reserve Banks from the calculation of supplementary leverage exposure. While the temporary relief automatically applied to Address Current Expected Credit Loss Accounting
On January 1, 2020, the Corporation, adopted the new accounting standard that requires the measurementCorporation’s lead depository institution, Bank of America, N.A., did not opt to take advantage of the allowance for credit losses to be based on management’s best estimate of lifetime expected credit losses inherent inSLR relief offered by the OCC. At December 31, 2021, the Corporation’s SLR was 5.5 percent, which exceeds the 5.0 percent minimum required by the Federal Reserve.
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 relevant financial assets. For more information, see Note 1 - Summary of Significant Accounting Principlesprincipal 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 Consolidated Financial Statements. Our adoptionnet capital requirements of Rule 15c3-1 under the standard resulted in a decrease to the CET1Exchange Act. BofAS computes its minimum capital ratio of 17 bps, which will be phased in evenly, or approximately four bps per year, at the beginning of each year from January 1, 2020 through January 1, 2023requirements as an alternative net capital broker-dealer under Rule 15c3-1e, and MLPCC and MLPF&S compute their minimum capital requirements in accordance with transition provisions issued by the alternative standard under Rule 15c3-1. BofAS and MLPCC are also registered as futures commission merchants and are subject to Commodity Futures Trading Commission (CFTC) Regulation 1.17. The U.S. banking regulators.
Security-Based Swap Dealer Capital, Margin and Segregation Requirements
On June 21, 2019,broker-dealer subsidiaries are also registered with the SEC published a final rule establishing capital, margin and segregation requirements for security-based swap dealers (SBSDs)Financial Industry Regulatory Authority, Inc. (FINRA). The final rule increases the minimumPursuant to FINRA Rule 4110, FINRA may impose higher net capital requirements for broker-dealers authorizedthan Rule 15c3-1 under the Exchange Act with respect to use internal models to computeeach of the broker-dealers.
BofAS provides institutional services, and in accordance with the alternative net capital (ANC broker-dealers). For ANC broker-dealers, the minimumrequirements, is required to maintain tentative net capital requirement increased from $1.0 billion toin excess of $5.0 billion and the net capital requirement was raised toin excess of the greater of $1.0 billion or two percenta certain percentage of its reserve requirement in addition to a certain percentage of securities-based swap risk margin. BofAS must also notify the applicable risk-margin amount (initial margin maintained for cleared and non-cleared security-based swaps) plus two percent of certain customer-related assets. For stand-alone SBSDs that use models to calculate haircuts,SEC in the minimumevent its tentative net capital requirement is $100 millionless than $6.0 billion. BofAS is also required to hold a certain percentage of its
customers' and theaffiliates' risk-based margin in order to meet its CFTC minimum net capital requirement. At December 31, 2021, BofAS had tentative net capital of $19.4 billion. BofAS also had regulatory net capital of $16.6 billion, which exceeded the minimum requirement is the greater of $20 million or two percent of the risk-margin amount.$3.5 billion.
Capital Requirements for Swap Dealers
On December 10, 2019, the CFTC re-opened the comment period on its 2016 proposal to establish capital requirements for swap dealers and major swap participants that are not subject to existing U.S. prudential regulation. Under the proposal, applicable subsidiaries of the Corporation would be permitted to elect one of two approaches to compute their regulatory capital. The first approachMLPCC is a bank-based capital approach which requires that firms maintain CET1 capital greater than or equal to the largerfully-guaranteed subsidiary of 8.0 percent of the entity’s RWABofAS and provides clearing and settlement services as calculated under Basel 3, or 8.0 percent of the margin of the entity’s clearedwell as prime brokerage and uncleared swaps, security-based swaps, futures and foreign futures positions. The second approach is based on net liquid assets and requires that a firm maintainarranged financing services for institutional clients. At December 31, 2021, MLPCC’s regulatory net capital greater than or equal to 8.0 percent of $6.2 billion exceeded the margin as described above. The proposal also includes liquidity and reporting requirements.
minimum requirement of $1.5 billion.

MLPF&S provides retail services. At December 31, 2021, MLPF&S' regulatory net capital was $5.7 billion, which exceeded the minimum requirement of $199 million.
49Bank of America






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 ruleOur European broker-dealers are regulated by non-U.S. regulators. MLI, a U.K. investment firm, 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 percentPrudential Regulation Authority and the Financial Conduct Authority and is subject to certain regulatory capital requirements. At December 31, 2021, MLI’s capital resources were $33.6 billion, which exceeded the minimum Pillar 1 requirement of Tier$14.0 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, 2021, BofASE's capital resources were $7.9 billion, which exceeded the minimum Pillar 1 capital and exposures to most other counterparties do not breach 25 percentrequirement 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.$2.8 billion.
Liquidity Risk
Funding and Liquidity Risk Management
Our primary liquidity risk management objective is to meet expected or unexpected cash flow and collateral needsrequirements, including payments under long-term debt agreements, commitments to extend credit and customer deposit withdrawals, 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 fluctuation from the pandemic. For more information on the risks of the pandemic, see Part I. Item 1A. Risk Factors – Coronavirus Disease on page 8 and Executive Summary – Recent Developments – COVID-19
Bank of America 54


Pandemic on page 27.
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 obligationsthey 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 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 42.46. 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 theThe parent company, which is a separate and distinct legal entity from our bankingbank and nonbank subsidiaries,
has an intercompany arrangement with our wholly-owned holding company subsidiary, NB Holdings Corporation (NB Holdings). We have transferred, and agreed to transfer, certain additional parent company assets not neededrequired to satisfy anticipated near-term expenditures to NB Holdings Corporation, a wholly-owned holding company subsidiary (NB Holdings).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. 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.
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 other investment-grade securities, 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 1615 presents average GLS for the three months ended December 31, 20192021 and 2018.2020.
Table 15Average Global Liquidity Sources
Three Months Ended
December 31
(Dollars in billions)20212020
Bank entities$1,006 $773 
Nonbank and other entities (1)
152 170 
Total Average Global Liquidity Sources$1,158 $943 
     
Table 16Average Global Liquidity Sources
     
  Three Months Ended
December 31
(Dollars in billions)2019 2018
Parent company and NB Holdings$59
 $76
Bank subsidiaries454
 420
Other regulated entities63
 48
Total Average Global Liquidity Sources$576
 $544
Typically, parent company and(1) Nonbank includes Parent, NB Holdings liquidity is in the form of cash deposited with BANA.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. 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

Bank of America 50


obtained by borrowing against this pool of specifically-identified eligible assets was $372$322 billion and $344$306 billion at December 31, 20192021 and 2018.2020. We have established operational procedures to enable us to borrow against these assets, including regularly monitoring our total pool of eligible loans and securities collateral. Eligibility is defined in guidelines from the FHLBs and the Federal Reserve and is subject to change at their discretion. Due to regulatory restrictions, liquidity generated by the bank subsidiaries can generally be used only to fund obligations within the bank subsidiaries, and transfers to the parent company or nonbank subsidiaries may be subject to prior regulatory approval.
Liquidity 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, which is excluded from the liquidity at bank subsidiaries, and high-quality, liquid, unencumbered securities. 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.
55 Bank of America


Table 1716 presents the composition of average GLS for the three months ended December 31, 20192021 and 2018.2020.
Table 16Table 16Average Global Liquidity Sources Composition
Three Months Ended
December 31
    
Table 17Average Global Liquidity Sources Composition
(Dollars in billions)(Dollars in billions)20212020
  
 Three Months Ended
December 31
(Dollars in billions)2019 2018
Cash on depositCash on deposit$103
 $113
Cash on deposit$259 $322 
U.S. Treasury securitiesU.S. Treasury securities98
 81
U.S. Treasury securities278 141 
U.S. agency securities and mortgage-backed securities358
 340
U.S. agency securities, mortgage-backed securities, and other investment-grade securitiesU.S. agency securities, mortgage-backed securities, and other investment-grade securities606 462 
Non-U.S. government securitiesNon-U.S. government securities17
 10
Non-U.S. government securities15 18 
Total Average Global Liquidity SourcesTotal Average Global Liquidity Sources$576
 $544
Total Average Global Liquidity Sources$1,158 $943 
Our GLS are substantially the same in composition to what qualifies as High Quality Liquid Assets (HQLA) under the final U.S. Liquidity Coverage Ratio (LCR) rules. However, HQLA for purposes of calculating LCR is not reported at market value, but at a lower value that incorporates regulatory deductions and the exclusion of excess liquidity held at certain subsidiaries. The LCR is calculated as the amount of a financial institution’s unencumbered HQLA relative to the estimated net cash outflows the institution could encounter over a 30-day period of significant liquidity stress, expressed as a percentage. Our average consolidated HQLA, on a net basis, was $464$617 billion and $446$584 billion for the three months ended December 31, 20192021 and 2018.2020. For the same periods, the average consolidated LCR was 116115 percent and 118122 percent. Our LCR fluctuates due to normal business flows from customer activity.
Liquidity Stress AnalysisContingency Planning
We utilize liquidity stress analysishave developed and maintain contingency plans that are designed to assistprepare us in determiningadvance 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 amountsto 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 liquidityeach 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 the parent companyall times, even under adverse scenarios, take advantage of organic growth opportunities, meet obligations to creditors and our subsidiariescounterparties, maintain ready access to meet contractual and contingent cash outflows underfinancial markets, continue to serve as a rangecredit intermediary, remain a source of scenarios. The scenarios we consider and utilize incorporate market-wide and Corporation-specific events, including potential credit rating downgradesstrength for the parent company and 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 severe eventsinformation, 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 Comprehensive Capital Analysis and Review (CCAR) capital plan. Based on the results of our 2021 CCAR capital plan and related supervisory stress tests, we are subject to a 2.5 percent stress capital buffer (SCB), unchanged from the prior level, effective October 1, 2021 through September 30, 2022. Our Common equity tier 1 (CET1) capital ratio under the Standardized approach must remain above 9.5 percent during this period in order to avoid restrictions on capital distributions and discretionary bonus payments.
Due to uncertainty resulting from the pandemic, the Federal Reserve imposed various restrictions on share repurchase programs and dividends during 2020 and the first half of 2021.
49 Bank of America


In conjunction with its release of 2021 CCAR supervisory stress test results, the Federal Reserve announced those restrictions would end as of July 1, 2021 for large banks, including potential resolution scenarios.the Corporation, and large banks would be subject to the normal restrictions under the Federal Reserve's SCB framework. On October 20, 2021, we announced that the Board renewed the Corporation’s $25 billion common stock repurchase program previously announced in April 2021. The scenariosBoard’s authorization replaced the previous program. As with the April authorization, the Board also authorized common stock repurchases to offset shares awarded under the Corporation’s equity-based compensation plans. Pursuant to the Board’s authorization, during 2021 we repurchased $25.1 billion of common stock, including repurchases to offset shares awarded under equity-based compensation plans.
The timing and amount of common stock repurchases made pursuant to our stock repurchase program are subject to various factors, including the Corporation’s capital position, liquidity, financial performance and alternative uses of capital, stock trading price, regulatory requirements 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 our historical experience, experience of distressedexposure type, and failed financial institutions, regulatory guidance, and both expected and unexpected future events.the Advanced approaches determine risk weights based on internal models.
The types of potential contractualCorporation's depository institution subsidiaries are also subject to the Prompt Corrective Action (PCA) framework. The Corporation and contingent cash outflows we consider in our scenarios may include, butits primary affiliated banking entity, BANA, are not limited to, upcoming contractual maturities of unsecured debtAdvanced approaches institutions under Basel 3 and reductions in new debt issuance; 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 liquidityare required to maintain businessesreport regulatory risk-based capital ratios and finance customer activities. Changes in certain market factors,RWA under both the Standardized and Advanced approaches. The approach that yields the lower ratio is used to assess capital adequacy, including but not limited to, credit rating downgrades, could negatively impact potential contractualunder the PCA framework. As of December 31, 2021, the CET1, Tier 1 capital and contingent outflows and the related financial instruments, and in some cases these impacts could be material to our financial results.
We consider all sources of funds that we could access during each stress scenario and focus particularly on matching available sources with corresponding liquidity requirements by legal entity. We also use the stress modeling results to manage our asset and liability profile and establish limits and guidelines on certain funding sources and businesses.
Net Stable Funding Ratio
U.S. banking regulators issued a proposalTotal capital ratios for a Net Stable Funding Ratio (NSFR) requirement applicable to U.S. financial institutions following the Basel Committee’s final standard. The proposed U.S. NSFR would apply to the Corporation 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 consolidatedcapital
conservation buffer of 2.5 percent (under the Advanced approaches only), an SCB (under the Standardized approach only), plus any applicable countercyclical capital buffer and a global systemically important bank (G-SIB) surcharge. Including a regulatory minimum requirement of 4.5 percent, an SCB of 2.5 percent and a G-SIB surcharge of 2.5 percent, the Corporation's CET1 capital ratio must be a minimum of 9.5 percent under both the Standardized and Advanced approaches.
The Corporation is required to calculate its G-SIB surcharge on an annual basis and to our insured depository institutions. While the final requirement remains pendingunder two methods and is subject to the higher of the resulting two surcharges. Method 1 is consistent with the approach prescribed by the Basel Committee’s assessment methodology and is calculated using specified indicators of systemic importance. Method 2 modifies the Method 1 approach by, among other factors, including a measure of the Corporation’s reliance on short-term wholesale funding. The Corporation’s G-SIB surcharge, which is higher under Method 2, is expected to increase to 3.0 percent on January 1, 2024 unless its surcharge calculated as of December 31, 2022 is lower than 3.0 percent.
The current SCB of 2.5 percent, which remains effective from October 1, 2021 through September 30, 2022, could change if finalized as proposed, we expectbased on results of the 2022 CCAR capital plan and related supervisory stress tests to be submitted in compliance within the regulatory timeline. first half of 2022.
The standardCorporation is intendedalso required to reduce funding risk overmaintain a longer time horizon.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 NSFRnumerator of the SLR is designed to provide an appropriate amountquarter-end Basel 3 Tier 1 capital. The denominator is total leverage exposure based on the daily average of stable funding, generally capitalthe sum of on-balance sheet exposures less permitted deductions, and liabilities maturing beyond one year, givenapplicable temporary exclusions, as well as the mixsimple average of assets andcertain off-balance sheet items.exposures, as of the end of each month in a quarter. The temporary exclusions expired after March 31, 2021 and were not applicable for December 31, 2021. For more information, see Capital Management – Regulatory Developments on page 54.
Diversified Funding SourcesCapital Composition and Ratios
We fund our assets primarilyTable 10 presents Bank of America Corporation’s capital ratios and related information in accordance with a mix of deposits,Basel 3 Standardized 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 $1.43 trillion and $1.38 trillionAdvanced approaches as measured at December 31, 20192021 and 2018. Deposits2020. For the periods presented herein, the Corporation met the definition of well capitalized under current regulatory requirements.
Bank of America 50


Table 10Bank of America Corporation Regulatory Capital under Basel 3
Standardized
Approach
(1)
Advanced
Approaches
(1)
Regulatory
Minimum
(2)
(Dollars in millions, except as noted)December 31, 2021
Risk-based capital metrics:
Common equity tier 1 capital$171,759 $171,759 
Tier 1 capital196,465 196,465 
Total capital (3)
227,592 220,616 
Risk-weighted assets (in billions)1,618 1,399 
Common equity tier 1 capital ratio10.6 %12.3 %9.5 %
Tier 1 capital ratio12.1 14.0 11.0 
Total capital ratio14.1 15.8 13.0 
Leverage-based metrics:
Adjusted quarterly average assets (in billions) (4)
$3,087 $3,087 
Tier 1 leverage ratio6.4 %6.4 %4.0 
Supplementary leverage exposure (in billions) (5)
$3,604 
Supplementary leverage ratio5.5 %5.0 
December 31, 2020
Risk-based capital metrics:
Common equity tier 1 capital$176,660 $176,660 
Tier 1 capital200,096 200,096 
Total capital (3)
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) (4)
$2,719 $2,719 
Tier 1 leverage ratio7.4 %7.4 %4.0 
Supplementary leverage exposure (in billions) (5)
$2,786 
Supplementary leverage ratio7.2 %5.0 
(1)Capital ratios as of December 31, 2021 and 2020 are calculated using the regulatory capital rule that allows a five-year transition period related to the adoption of the current expected credit losses (CECL) accounting standard.
(2)The capital conservation buffer and G-SIB surcharge were 2.5 percent at both December 31, 2021 and 2020. At both December 31, 2021 and 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 CET1 capital regulatory minimum is the sum of the CET1 capital ratio minimum of 4.5 percent, our G-SIB surcharge of 2.5 percent and our SCB or the capital conservation buffer, as applicable, of 2.5 percent. The SLR regulatory minimum includes a leverage buffer of 2.0 percent.
(3)Total capital under the Advanced approaches differs from the Standardized approach due to differences in the amount permitted in Tier 2 capital related to the qualifying allowance for credit losses.
(4)Reflects total average assets adjusted for certain Tier 1 capital deductions.
(5)Supplementary leverage exposure at December 31, 2020 reflects the temporary exclusion of U.S. Treasury securities and deposits at Federal Reserve Banks. The temporary relief expired after March 31, 2021 and is not reflected in supplementary leverage exposure at December 31, 2021.
At December 31, 2021, CET1 capital was $171.8 billion, a decrease of $4.9 billion from December 31, 2020, driven by common stock repurchases, dividends and decreases in net unrealized gains on available-for-sale (AFS) debt securities included in accumulated other comprehensive income (OCI), partially offset by earnings. Tier 1 capital decreased $3.6 billion primarily generateddriven by ourthe same factors as CET1 capital, partially offset by non-cumulative perpetual preferred stock issuances. Total capital under the Standardized approach decreased $10.3 billion primarily due to the same factors driving the decrease in CET1 capital, and a decrease in the adjusted allowance for credit losses included in Tier 2 capital. RWA under the
Standardized approach, which yielded the lower CET1 capital
ratio at December 31, 2021, increased $138.1 billion during 2021 to $1,618 billion primarily due to loan growth in ConsumerGlobal Banking,, strong client activity in GWIMGlobal Markets and Global Banking segments. Thesean increase in debt securities resulting from the deployment of cash received from deposit inflows. Supplementary leverage exposure at December 31, 2021 increased $818.1 billion during 2021 primarily due to the expiration of the Federal Reserve’s temporary relief to exclude U.S. Treasury securities and deposits are diversified by clients, product typeat Federal Reserve Banks and geography, andan increase in debt securities resulting from the majoritydeployment 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 thiscash received from 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.inflows.
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

51 Bank of America




Table 11 shows the capital composition at December 31, 2021 and 2020.

Table 11Capital Composition under Basel 3
December 31
(Dollars in millions)20212020
Total common shareholders’ equity$245,358 $248,414 
CECL transitional amount (1)
2,508 4,213 
Goodwill, net of related deferred tax liabilities(68,641)(68,565)
Deferred tax assets arising from net operating loss and tax credit carryforwards(7,743)(5,773)
Intangibles, other than mortgage servicing rights, net of related deferred tax liabilities(1,605)(1,617)
Defined benefit pension plan net assets(1,261)(1,164)
Cumulative unrealized net (gain) loss related to changes in fair value of financial liabilities attributable to own creditworthiness,
 net-of-tax
1,400 1,753 
Accumulated net (gain) loss on certain cash flow hedges (2)
1,870 (436)
Other(127)(165)
Common equity tier 1 capital171,759 176,660 
Qualifying preferred stock, net of issuance cost24,707 23,437 
Other(1)(1)
Tier 1 capital196,465 200,096 
Tier 2 capital instruments20,750 22,213 
Qualifying allowance for credit losses (3)
10,534 15,649 
Other(157)(22)
Total capital under the Standardized approach227,592 237,936 
Adjustment in qualifying allowance for credit losses under the Advanced approaches (3)
(6,976)(10,251)
Total capital under the Advanced approaches$220,616 $227,685 

(1)Includes the impact of the Corporation's adoption of the CECL accounting standard on January 1, 2020 and 25 percent of the increase in reserves since the initial adoption.


(2)Includes amounts in accumulated other comprehensive income related to the hedging of items that are not recognized at fair value on the Consolidated Balance Sheet.
often overnight. Disruptions(3)Includes the impact of transition provisions related to the CECL accounting standard.

Table 12 shows the components of RWA as measured under Basel 3 at December 31, 2021 and 2020.
Table 12Risk-weighted Assets under Basel 3
Standardized ApproachAdvanced ApproachesStandardized ApproachAdvanced Approaches
December 31
(Dollars in billions)20212020
Credit risk$1,549 $913 $1,420 $896 
Market risk69 69 60 60 
Operational riskn/a378 n/a372 
Risks related to credit valuation adjustmentsn/a39 n/a43 
Total risk-weighted assets$1,618 $1,399 $1,480 $1,371 
n/a = not applicable
Bank of America 52


Bank of America, N.A. Regulatory Capital
Table 13 presents regulatory capital information for BANA in secured financing marketsaccordance with Basel 3 Standardized and Advanced approaches as measured at December 31, 2021 and 2020. BANA met the definition of well capitalized under the PCA framework for financial institutions have occurred in prior market cycles which resulted in adverse changes in terms or significant reductionsboth periods.
Table 13Bank of America, N.A. Regulatory Capital under Basel 3
Standardized
Approach
(1)
Advanced
Approaches
(1)
Regulatory
Minimum 
(2)
(Dollars in millions, except as noted)December 31, 2021
Risk-based capital metrics:
Common equity tier 1 capital$182,526 $182,526 
Tier 1 capital182,526 182,526 
Total capital (3)
194,773 188,091 
Risk-weighted assets (in billions)1,352 1,048 
Common equity tier 1 capital ratio13.5 %17.4 %7.0 %
Tier 1 capital ratio13.5 17.4 8.5 
Total capital ratio14.4 17.9 10.5 
Leverage-based metrics:
Adjusted quarterly average assets (in billions) (4)
$2,414 $2,414 
Tier 1 leverage ratio7.6 %7.6 %5.0 
Supplementary leverage exposure (in billions)$2,824 
Supplementary leverage ratio6.5 %6.0 




December 31, 2020
Risk-based capital metrics:
Common equity tier 1 capital$164,593 $164,593 
Tier 1 capital164,593 164,593 
Total capital (3)
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) (4)
$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 
(1)Capital ratios for both December 31, 2021 and 2020 are calculated using the regulatory capital rule that allows a five-year transition period related to the adoption of CECL.
(2)Risk-based capital regulatory minimums at both December 31, 2021 and 2020 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.
(3)Total capital under the Advanced approaches differs from the Standardized approach due to differences in the availabilityamount permitted in Tier 2 capital related to the qualifying allowance for credit losses.
(4)Reflects total average assets adjusted for certain Tier 1 capital deductions.
Total Loss-Absorbing Capacity Requirements
Total loss-absorbing capacity (TLAC) consists of such financing. We manage 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 14 presents the Corporation's TLAC and long-term debt ratios and related information as of December 31, 2021 and 2020.
53 Bank of America


Table 14Bank 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, 2021
Total eligible balance$435,904 $227,714 
Percentage of risk-weighted assets (4)
26.9 %22.0 %14.1 %8.5 %
Percentage of supplementary leverage exposure (5)
12.1 9.5 6.3 4.5 
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)
14.5 9.5 7.1 4.5 
(1)As of December 31, 2021 and 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 December 31, 2021 and 2020.
(5)Supplementary leverage exposure at December 31, 2020 reflects the temporary exclusion of U.S. Treasury Securities and deposits at Federal Reserve Banks. The temporary relief expired after March 31, 2021 and is not reflected in supplementary leverage exposure at December 31, 2021.

Regulatory Developments
Supplementary Leverage Ratio
On March 19, 2021, U.S. banking regulators announced that temporary changes issued in 2020 for BHCs and depository institutions would expire as scheduled after March 31, 2021. These temporary changes to the SLR allowed the exclusion of on-balance sheet amounts of U.S. Treasury securities and deposits at Federal Reserve Banks from the calculation of supplementary leverage exposure. While the temporary relief automatically applied to the Corporation, the Corporation’s lead depository institution, Bank of America, N.A., did not opt to take advantage of the SLR relief offered by the OCC. At December 31, 2021, the Corporation’s SLR was 5.5 percent, which exceeds the 5.0 percent minimum required by the Federal Reserve.
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 Commodity Futures Trading Commission (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 $5.0 billion and net capital in excess of the greater of $1.0 billion or a certain percentage of its reserve requirement in addition to a certain percentage of securities-based swap risk margin. BofAS must also notify the SEC in the event its tentative net capital is less than $6.0 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, 2021, BofAS had tentative net capital of $19.4 billion. BofAS also had regulatory net capital of $16.6 billion, which exceeded the minimum requirement of $3.5 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, 2021, MLPCC’s regulatory net capital of $6.2 billion exceeded the minimum requirement of $1.5 billion.
MLPF&S provides retail services. At December 31, 2021, MLPF&S' regulatory net capital was $5.7 billion, which exceeded the minimum requirement of $199 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 and is subject to certain regulatory capital requirements. At December 31, 2021, MLI’s capital resources were $33.6 billion, which exceeded the minimum Pillar 1 requirement of $14.0 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, 2021, BofASE's capital resources were $7.9 billion, which exceeded the minimum Pillar 1 requirement of $2.8 billion.
Liquidity Risk
Funding and Liquidity Risk Management
Our primary liquidity risks arising from secured funding by sourcing funding globally from a diverse group of counterparties, providingrisk management objective is to meet expected or unexpected cash flow and collateral requirements, including payments under long-term debt agreements, commitments to extend credit and customer deposit withdrawals, while continuing to support our businesses and customers under a range of securities collateraleconomic conditions. To achieve that objective, we analyze and pursuing longer durations, when appropriate.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 fluctuation from the pandemic. For more information on secured financing agreements,the risks of the pandemic, see Note 11Part I. Item 1A. Risk FactorsFederal Funds Sold or Purchased, Securities Financing Agreements, Short-term BorrowingsCoronavirus Disease on page 8 and Restricted CashExecutive Summary – Recent Developments – COVID-19
Bank of America 54


Pandemic on page 27.
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 they 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 46. Under this governance framework, we 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
The parent company, which is a separate and distinct legal entity from our bank and nonbank subsidiaries, has an intercompany arrangement with our wholly-owned holding company subsidiary, NB Holdings Corporation (NB Holdings). We have transferred, and agreed to transfer, additional parent company assets not required to satisfy anticipated near-term expenditures to NB Holdings. The parent company is expected to continue to have access to the Consolidated Financial Statements.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 it not entered into these arrangements and transferred any assets. 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.
We issue long-term unsecured debtIn consideration for the transfer of assets, NB Holdings issued a subordinated note to the parent company 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 specificprincipal amount equal to the financial services industry orvalue of the Corporation, we seek to mitigate refinancing risktransferred assets. The aggregate principal amount of the note will increase by actively managing 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 borrowingspreferred 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 other investment-grade securities, and a select group of non-U.S. government securities. We can 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 anticipate will mature within any month or quarter.consider the impact of potential regulatory, tax, legal and other restrictions that could limit the transferability of funds among entities.
Table 1815 presents our long-termaverage GLS for the three months ended December 31, 2021 and 2020.
Table 15Average Global Liquidity Sources
Three Months Ended
December 31
(Dollars in billions)20212020
Bank entities$1,006 $773 
Nonbank and other entities (1)
152 170 
Total Average Global Liquidity Sources$1,158 $943 
(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 major currencypledging 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 $322 billion and $306 billion at December 31, 20192021 and 2018.2020. 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.
     
Table 18Long-term Debt by Major Currency
   
  December 31
(Dollars in millions)2019 2018
U.S. dollar$191,284
 $180,724
Euro32,781
 34,328
British pound5,067
 5,450
Japanese yen4,310
 3,038
Canadian dollar3,857
 2,936
Australian dollar1,957
 1,722
Other1,600
 1,194
Total long-term debt$240,856
 $229,392
Total long-term debt increased $11.5 billion during 2019,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, which is excluded from the liquidity at bank subsidiaries, and high-quality, liquid, unencumbered securities. 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 debt issuancesregulatory restrictions 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.minimum requirements. Our other regulated entities may also make marketshold unencumbered investment-grade securities and equities that we believe could be used to generate additional liquidity.
55 Bank of America


Table 16 presents the composition of average GLS for the three months ended December 31, 2021 and 2020.
Table 16Average Global Liquidity Sources Composition
Three Months Ended
December 31
(Dollars in billions)20212020
Cash on deposit$259 $322 
U.S. Treasury securities278 141 
U.S. agency securities, mortgage-backed securities, and other investment-grade securities606 462 
Non-U.S. government securities15 18 
Total Average Global Liquidity Sources$1,158 $943 
Our GLS are substantially the same in our debt instrumentscomposition to providewhat 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 for investors.
During 2019,held at certain subsidiaries. The LCR is calculated as the Corporation issued $52.5amount 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 $617 billion of long-term debt consisting of $29.3 billion of notes issued by Bank of America Corporation, substantially all of which was TLAC compliant, $10.9 billion of notes issued by Bank of America, N.A. and $12.3 billion of other debt, substantially all of which was structured liabilities. During 2018, the Corporation issued $64.4 billion of long-term debt consisting of $30.7 billion of notes issued by Bank of America Corporation, substantially all of which was TLAC compliant, $18.7 billion of notes issued by Bank of America, N.A. and $15.0 billion of other debt, substantially all of which was structured liabilities.
During 2019, the Corporation had total long-term debt maturities and redemptions in the aggregate of $50.6 billion consisting of $21.1$584 billion for Bank of America Corporation, $19.9 billion for Bank of America, N.A. and $9.6 billion of other debt. During 2018, the Corporation had total long-term debt maturities and redemptions in the aggregate of $53.3 billion consisting of $29.8 billion for Bank of America Corporation, $11.2 billion for Bank of America, N.A. and $12.3 billion of other debt.
Atthree months ended December 31, 2019, Bank of America Corporation's senior notes of $159.8 billion included $107.7 billion of outstanding notes that are both TLAC eligible2021 and callable at least one year before their stated maturities. Of these senior notes, $7.4 billion will be callable2020. For the same periods, the average consolidated LCR was 115 percent and become TLAC ineligible during 2020, and $11.7
billion, $14.8 billion, $10.7 billion and $9.2 billion will do so during each of 2021 through 2024, respectively, and $53.9 billion thereafter.
We use derivative transactions122 percent. Our LCR fluctuates due 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 74.
We may issue unsecured debt in the form of structured notes for client purposes, certain of which qualify as TLAC-eligible debt. During 2019, we issued $9.6 billion of structured notes, which are debt obligations that pay investors returns linked to other debt or equity securities, indices, currencies or commodities. We typically hedge the returns we are obligated to pay on these liabilities with derivatives and/or investments in the underlying instruments, so thatnormal business flows 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.customer activity.
Substantially all of our senior and subordinated debt obligations contain no provisions that could trigger a requirement for an early repayment, require additional collateral support, result in changes to terms, accelerate maturity or create additional financial obligations upon an adverse change in our credit ratings, financial ratios, earnings, cash flows or stock price. For more information on long-term debt funding, including issuances and maturities and redemptions, see Note 12 – Long-term Debt to the Consolidated Financial Statements.
Contingency Planning
We 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 Comprehensive Capital Analysis and Review (CCAR) capital plan. Based on the results of our 2021 CCAR capital plan and related supervisory stress tests, we are subject to a 2.5 percent stress capital buffer (SCB), unchanged from the prior level, effective October 1, 2021 through September 30, 2022. Our Common equity tier 1 (CET1) capital ratio under the Standardized approach must remain above 9.5 percent during this period in order to avoid restrictions on capital distributions and discretionary bonus payments.
Due to uncertainty resulting from the pandemic, the Federal Reserve imposed various restrictions on share repurchase programs and dividends during 2020 and the first half of 2021.
49 Bank of America


In conjunction with its release of 2021 CCAR supervisory stress test results, the Federal Reserve announced those restrictions would end as of July 1, 2021 for large banks, including the Corporation, and large banks would be subject to the normal restrictions under the Federal Reserve's SCB framework. On October 20, 2021, we announced that the Board renewed the Corporation’s $25 billion common stock repurchase program previously announced in April 2021. The Board’s authorization replaced the previous program. As with the April authorization, the Board also authorized common stock repurchases to offset shares awarded under the Corporation’s equity-based compensation plans. Pursuant to the Board’s authorization, during 2021 we repurchased $25.1 billion of common stock, including repurchases to offset shares awarded under equity-based compensation plans.
The timing and amount of common stock repurchases made pursuant to our stock repurchase program are subject to various factors, including the Corporation’s capital position, liquidity, financial performance and alternative uses of capital, stock trading price, regulatory requirements 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, 2021, 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 of 2.5 percent (under the Advanced approaches only), an SCB (under the Standardized approach only), plus any applicable countercyclical capital buffer and a global systemically important bank (G-SIB) surcharge. Including a regulatory minimum requirement of 4.5 percent, an SCB of 2.5 percent and a G-SIB surcharge of 2.5 percent, the Corporation's CET1 capital ratio must be a minimum of 9.5 percent under both the Standardized and Advanced approaches.
The Corporation is required to calculate its G-SIB surcharge on an annual basis under two methods and is subject to the higher of the resulting two surcharges. Method 1 is consistent with the approach prescribed by the Basel Committee’s assessment methodology and is calculated using specified indicators of systemic importance. Method 2 modifies the Method 1 approach by, among other factors, including a measure of the Corporation’s reliance on short-term wholesale funding. The Corporation’s G-SIB surcharge, which is higher under Method 2, is expected to increase to 3.0 percent on January 1, 2024 unless its surcharge calculated as of December 31, 2022 is lower than 3.0 percent.
The current SCB of 2.5 percent, which remains effective from October 1, 2021 through September 30, 2022, could change based on results of the 2022 CCAR capital plan and related supervisory stress tests to be submitted in the first half of 2022.
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. The temporary exclusions expired after March 31, 2021 and were not applicable for December 31, 2021. For more information, see Capital Management – Regulatory Developments on page 54.
Capital Composition and Ratios
Table 10 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, 2021 and 2020. For the periods presented herein, the Corporation met the definition of well capitalized under current regulatory requirements.
Bank of America 50


Table 10Bank of America Corporation Regulatory Capital under Basel 3
Standardized
Approach
(1)
Advanced
Approaches
(1)
Regulatory
Minimum
(2)
(Dollars in millions, except as noted)December 31, 2021
Risk-based capital metrics:
Common equity tier 1 capital$171,759 $171,759 
Tier 1 capital196,465 196,465 
Total capital (3)
227,592 220,616 
Risk-weighted assets (in billions)1,618 1,399 
Common equity tier 1 capital ratio10.6 %12.3 %9.5 %
Tier 1 capital ratio12.1 14.0 11.0 
Total capital ratio14.1 15.8 13.0 
Leverage-based metrics:
Adjusted quarterly average assets (in billions) (4)
$3,087 $3,087 
Tier 1 leverage ratio6.4 %6.4 %4.0 
Supplementary leverage exposure (in billions) (5)
$3,604 
Supplementary leverage ratio5.5 %5.0 
December 31, 2020
Risk-based capital metrics:
Common equity tier 1 capital$176,660 $176,660 
Tier 1 capital200,096 200,096 
Total capital (3)
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) (4)
$2,719 $2,719 
Tier 1 leverage ratio7.4 %7.4 %4.0 
Supplementary leverage exposure (in billions) (5)
$2,786 
Supplementary leverage ratio7.2 %5.0 
(1)Capital ratios as of December 31, 2021 and 2020 are calculated using the regulatory capital rule that allows a five-year transition period related to the adoption of the current expected credit losses (CECL) accounting standard.
(2)The capital conservation buffer and G-SIB surcharge were 2.5 percent at both December 31, 2021 and 2020. At both December 31, 2021 and 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 CET1 capital regulatory minimum is the sum of the CET1 capital ratio minimum of 4.5 percent, our G-SIB surcharge of 2.5 percent and our SCB or the capital conservation buffer, as applicable, of 2.5 percent. The SLR regulatory minimum includes a leverage buffer of 2.0 percent.
(3)Total capital under the Advanced approaches differs from the Standardized approach due to differences in the amount permitted in Tier 2 capital related to the qualifying allowance for credit losses.
(4)Reflects total average assets adjusted for certain Tier 1 capital deductions.
(5)Supplementary leverage exposure at December 31, 2020 reflects the temporary exclusion of U.S. Treasury securities and deposits at Federal Reserve Banks. The temporary relief expired after March 31, 2021 and is not reflected in supplementary leverage exposure at December 31, 2021.
At December 31, 2021, CET1 capital was $171.8 billion, a decrease of $4.9 billion from December 31, 2020, driven by common stock repurchases, dividends and decreases in net unrealized gains on available-for-sale (AFS) debt securities included in accumulated other comprehensive income (OCI), partially offset by earnings. Tier 1 capital decreased $3.6 billion primarily driven by the same factors as CET1 capital, partially offset by non-cumulative perpetual preferred stock issuances. Total capital under the Standardized approach decreased $10.3 billion primarily due to the same factors driving the decrease in CET1 capital, and a decrease in the adjusted allowance for credit losses included in Tier 2 capital. RWA under the
Standardized approach, which yielded the lower CET1 capital
ratio at December 31, 2021, increased $138.1 billion during 2021 to $1,618 billion primarily due to loan growth in Global Banking, strong client activity in Global Markets and an increase in debt securities resulting from the deployment of cash received from deposit inflows. Supplementary leverage exposure at December 31, 2021 increased $818.1 billion during 2021 primarily due to the expiration of the Federal Reserve’s temporary relief to exclude U.S. Treasury securities and deposits at Federal Reserve Banks and an increase in debt securities resulting from the deployment of cash received from deposit inflows.

51 Bank of America


Table 11 shows the capital composition at December 31, 2021 and 2020.
Table 11Capital Composition under Basel 3
December 31
(Dollars in millions)20212020
Total common shareholders’ equity$245,358 $248,414 
CECL transitional amount (1)
2,508 4,213 
Goodwill, net of related deferred tax liabilities(68,641)(68,565)
Deferred tax assets arising from net operating loss and tax credit carryforwards(7,743)(5,773)
Intangibles, other than mortgage servicing rights, net of related deferred tax liabilities(1,605)(1,617)
Defined benefit pension plan net assets(1,261)(1,164)
Cumulative unrealized net (gain) loss related to changes in fair value of financial liabilities attributable to own creditworthiness,
 net-of-tax
1,400 1,753 
Accumulated net (gain) loss on certain cash flow hedges (2)
1,870 (436)
Other(127)(165)
Common equity tier 1 capital171,759 176,660 
Qualifying preferred stock, net of issuance cost24,707 23,437 
Other(1)(1)
Tier 1 capital196,465 200,096 
Tier 2 capital instruments20,750 22,213 
Qualifying allowance for credit losses (3)
10,534 15,649 
Other(157)(22)
Total capital under the Standardized approach227,592 237,936 
Adjustment in qualifying allowance for credit losses under the Advanced approaches (3)
(6,976)(10,251)
Total capital under the Advanced approaches$220,616 $227,685 
(1)Includes the impact of the Corporation's adoption of the CECL accounting standard on January 1, 2020 and 25 percent of the increase in reserves since the initial adoption.
(2)Includes amounts in accumulated other comprehensive income related to the hedging of items that are not recognized at fair value on the Consolidated Balance Sheet.
(3)Includes the impact of transition provisions related to the CECL accounting standard.

Table 12 shows the components of RWA as measured under Basel 3 at December 31, 2021 and 2020.
Table 12Risk-weighted Assets under Basel 3
Standardized ApproachAdvanced ApproachesStandardized ApproachAdvanced Approaches
December 31
(Dollars in billions)20212020
Credit risk$1,549 $913 $1,420 $896 
Market risk69 69 60 60 
Operational riskn/a378 n/a372 
Risks related to credit valuation adjustmentsn/a39 n/a43 
Total risk-weighted assets$1,618 $1,399 $1,480 $1,371 
n/a = not applicable
Bank of America 52


Bank of America, N.A. Regulatory Capital
Table 13 presents regulatory capital information for BANA in accordance with Basel 3 Standardized and Advanced approaches as measured at December 31, 2021 and 2020. BANA met the definition of well capitalized under the PCA framework for both periods.
Table 13Bank of America, N.A. Regulatory Capital under Basel 3
Standardized
Approach
(1)
Advanced
Approaches
(1)
Regulatory
Minimum 
(2)
(Dollars in millions, except as noted)December 31, 2021
Risk-based capital metrics:
Common equity tier 1 capital$182,526 $182,526 
Tier 1 capital182,526 182,526 
Total capital (3)
194,773 188,091 
Risk-weighted assets (in billions)1,352 1,048 
Common equity tier 1 capital ratio13.5 %17.4 %7.0 %
Tier 1 capital ratio13.5 17.4 8.5 
Total capital ratio14.4 17.9 10.5 
Leverage-based metrics:
Adjusted quarterly average assets (in billions) (4)
$2,414 $2,414 
Tier 1 leverage ratio7.6 %7.6 %5.0 
Supplementary leverage exposure (in billions)$2,824 
Supplementary leverage ratio6.5 %6.0 




December 31, 2020
Risk-based capital metrics:
Common equity tier 1 capital$164,593 $164,593 
Tier 1 capital164,593 164,593 
Total capital (3)
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) (4)
$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 
(1)Capital ratios for both December 31, 2021 and 2020 are calculated using the regulatory capital rule that allows a five-year transition period related to the adoption of CECL.
(2)Risk-based capital regulatory minimums at both December 31, 2021 and 2020 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.
(3)Total capital under the Advanced approaches differs from the Standardized approach due to differences in the amount permitted in Tier 2 capital related to the qualifying allowance for credit losses.
(4)Reflects total average assets adjusted for certain Tier 1 capital deductions.
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 14 presents the Corporation's TLAC and long-term debt ratios and related information as of December 31, 2021 and 2020.
53 Bank of America


Table 14Bank 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, 2021
Total eligible balance$435,904 $227,714 
Percentage of risk-weighted assets (4)
26.9 %22.0 %14.1 %8.5 %
Percentage of supplementary leverage exposure (5)
12.1 9.5 6.3 4.5 
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)
14.5 9.5 7.1 4.5 
(1)As of December 31, 2021 and 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 December 31, 2021 and 2020.
(5)Supplementary leverage exposure at December 31, 2020 reflects the temporary exclusion of U.S. Treasury Securities and deposits at Federal Reserve Banks. The temporary relief expired after March 31, 2021 and is not reflected in supplementary leverage exposure at December 31, 2021.

Regulatory Developments
Supplementary Leverage Ratio
On March 19, 2021, U.S. banking regulators announced that temporary changes issued in 2020 for BHCs and depository institutions would expire as scheduled after March 31, 2021. These temporary changes to the SLR allowed the exclusion of on-balance sheet amounts of U.S. Treasury securities and deposits at Federal Reserve Banks from the calculation of supplementary leverage exposure. While the temporary relief automatically applied to the Corporation, the Corporation’s lead depository institution, Bank of America, N.A., did not opt to take advantage of the SLR relief offered by the OCC. At December 31, 2021, the Corporation’s SLR was 5.5 percent, which exceeds the 5.0 percent minimum required by the Federal Reserve.
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 Commodity Futures Trading Commission (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 $5.0 billion and net capital in excess of the greater of $1.0 billion or a certain percentage of its reserve requirement in addition to a certain percentage of securities-based swap risk margin. BofAS must also notify the SEC in the event its tentative net capital is less than $6.0 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, 2021, BofAS had tentative net capital of $19.4 billion. BofAS also had regulatory net capital of $16.6 billion, which exceeded the minimum requirement of $3.5 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, 2021, MLPCC’s regulatory net capital of $6.2 billion exceeded the minimum requirement of $1.5 billion.
MLPF&S provides retail services. At December 31, 2021, MLPF&S' regulatory net capital was $5.7 billion, which exceeded the minimum requirement of $199 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 and is subject to certain regulatory capital requirements. At December 31, 2021, MLI’s capital resources were $33.6 billion, which exceeded the minimum Pillar 1 requirement of $14.0 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, 2021, BofASE's capital resources were $7.9 billion, which exceeded the minimum Pillar 1 requirement of $2.8 billion.
Liquidity Risk
Funding and Liquidity Risk Management
Our primary liquidity risk management objective is to meet expected or unexpected cash flow and collateral requirements, including payments under long-term debt agreements, commitments to extend credit and customer deposit withdrawals, 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 fluctuation from the pandemic. For more information on the risks of the pandemic, see Part I. Item 1A. Risk Factors – Coronavirus Disease on page 8 and Executive Summary – Recent Developments – COVID-19
Bank of America 54


Pandemic on page 27.
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 they 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 46. Under this governance framework, we 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
The parent company, which is a separate and distinct legal entity from our bank and nonbank subsidiaries, has an intercompany arrangement with our wholly-owned holding company subsidiary, NB Holdings Corporation (NB Holdings). We have transferred, and agreed to transfer, additional parent company assets not required to satisfy anticipated near-term expenditures to 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 it not entered into these arrangements and transferred any assets. 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.
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 other investment-grade securities, and a select group of non-U.S. government securities. We can 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 15 presents average GLS for the three months ended December 31, 2021 and 2020.
Table 15Average Global Liquidity Sources
Three Months Ended
December 31
(Dollars in billions)20212020
Bank entities$1,006 $773 
Nonbank and other entities (1)
152 170 
Total Average Global Liquidity Sources$1,158 $943 
(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 $322 billion and $306 billion at December 31, 2021 and 2020. We have established operational procedures to enable us to borrow against these assets, including regularly monitoring our total pool of eligible loans and securities collateral. Eligibility is defined in guidelines from the FHLBs and the Federal Reserve and is subject to change at their discretion. Due to regulatory restrictions, liquidity generated by the bank subsidiaries can generally be used only to fund obligations within the bank subsidiaries, and transfers to the parent company or nonbank subsidiaries may be subject to prior regulatory approval.
Liquidity 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, which is excluded from the liquidity at bank subsidiaries, and high-quality, liquid, unencumbered securities. 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.
55 Bank of America


Table 16 presents the composition of average GLS for the three months ended December 31, 2021 and 2020.
Table 16Average Global Liquidity Sources Composition
Three Months Ended
December 31
(Dollars in billions)20212020
Cash on deposit$259 $322 
U.S. Treasury securities278 141 
U.S. agency securities, mortgage-backed securities, and other investment-grade securities606 462 
Non-U.S. government securities15 18 
Total Average Global Liquidity Sources$1,158 $943 
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 $617 billion and $584 billion for the three months ended December 31, 2021 and 2020. For the same periods, the average consolidated LCR was 115 percent and 122 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, U.S. banking regulators 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 was effective July 1, 2021, and the Corporation is in compliance. The U.S. NSFR applies to the Corporation on a consolidated basis and to our insured depository institutions. There have not been 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 $2.1 trillion and $1.8 trillion at December 31, 2021 and 2020. Deposits are primarily generated by our Consumer Banking, GWIM and Global Banking segments. These deposits are diversified by clients, product type and geography, and the majority of our U.S. deposits are insured by the FDIC. We consider a substantial portion of our deposits to be a stable, low-cost and consistent source of funding. We believe this deposit funding is generally less sensitive to interest rate changes, market volatility or changes in our credit ratings than wholesale funding sources. Our lending activities may also be financed through secured borrowings, including credit card securitizations and securitizations with government-sponsored enterprises (GSE), the Federal Housing Administration (FHA) and private-label investors, as well as FHLB loans.
Our trading activities in other regulated entities are primarily funded on a secured basis through securities lending and repurchase agreements, and these amounts will vary based on customer activity and market conditions. We believe funding these activities in the secured financing markets is more cost-efficient and less sensitive to changes in our credit ratings than unsecured financing. Repurchase agreements are generally short-term and often overnight. Disruptions in secured financing markets for financial institutions have occurred in prior market cycles which resulted in adverse changes in terms or significant reductions in the availability of such financing. We manage the liquidity risks arising from secured funding by sourcing funding globally from a diverse group of counterparties, providing a range of securities collateral and pursuing longer durations, when appropriate. For more information on secured financing agreements, see Note 10 – Securities Financing Agreements, Short-term Borrowings and Restricted Cash to the Consolidated Financial Statements.
Total long-term debt increased $17.2 billion to $280.1 billion during 2021, primarily due to debt issuances, partially offset by debt maturities, redemptions and valuation adjustments. We may, from time to time, purchase outstanding debt instruments in various transactions, depending on market conditions, liquidity and other factors. Our other regulated
Bank of America 56


entities may also make markets in our debt instruments to provide liquidity for investors.
During 2021, we issued $76.7 billion of long-term debt consisting of $56.2 billion of notes issued by Bank of America Corporation, substantially all of which were TLAC compliant, $8.0 billion of notes issued by Bank of America, N.A. and $12.5 billion of other debt. 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 were TLAC compliant, $4.8 billion of notes issued by Bank of America, N.A. and $8.3 billion of other debt.
During 2021, we had total long-term debt maturities and redemptions in the aggregate of $46.4 billion consisting of $24.4 billion for Bank of America Corporation, $10.4 billion for Bank of America, N.A. and $11.6 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.
At December 31, 2021, Bank of America Corporation's senior notes of $212.9 billion included $179.5 billion of outstanding notes that are both TLAC eligible and callable at least one year before their stated maturities. Of these senior notes, $15.0 billion will be callable and become TLAC ineligible during 2022, and $17.0 billion, $17.8 billion, $15.0 billion and $17.7 billion will do so during each of 2023 through 2026, respectively, and $97.0 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 2021, we issued $7.1 billion of structured notes, which are debt obligations that pay investors returns linked to other debt or equity securities, indices, currencies or commodities. We typically hedge the returns we are obligated to pay on these liabilities with derivatives and/or investments in the underlying instruments, so that from a funding perspective, the cost is similar to our other unsecured long-term debt. We could be required to settle certain structured note obligations for cash or other securities prior to maturity under certain circumstances, which we consider for liquidity planning purposes. We believe, however, that a portion of such borrowings will remain outstanding beyond the earliest put or redemption date.
Substantially all of our senior and subordinated debt obligations contain no provisions that could trigger a requirement for an early repayment, require additional collateral support, result in changes to terms, accelerate maturity or create additional financial obligations upon an adverse change in our credit ratings, financial ratios, earnings, cash flows or stock price. For more information on long-term debt funding, including issuances and maturities and redemptions, see Note 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 79.
Uninsured Deposits
The FDIC insures the Corporation’s U.S. deposits up to $250,000 per depositor, per insured bank for each account ownership category, and various country-specific funds insure non-U.S. deposits up to specified limits. Deposits that exceed insurance limits are uninsured. At December 31, 2021, the Corporation’s deposits totaled $2.1 trillion, of which total estimated uninsured U.S. and non-U.S. deposits were $701.4 billion and $111.9 billion. At December 31, 2020, the Corporation’s deposits totaled $1.8 trillion, of which total estimated uninsured U.S. and non-U.S. deposits were $597.7 billion and $104.1 billion.
Table 17 presents information about the Corporation’s total estimated uninsured time deposits. For more information on our liquidity sources, see Global Liquidity Sources and Other Unencumbered Assets, and for more information on deposits, see Diversified Funding Sources in this section. For more information on contractual time deposit maturities, see Note 9 – Deposits to the Consolidated Financial Statements.
Table 17
Uninsured Time Deposits (1)
  December 31, 2021
(Dollars in millions)U.S.Non-U.S.Total
Uninsured time deposits with a maturity of:
3 months or less$2,337 $7,274 $9,611 
Over 3 months through 6 months1,668 1,663 3,331 
Over 6 months through 12 months1,942 239 2,181 
Over 12 months289 1,470 1,759 
Total$6,236 $10,646 $16,882 
(1)Amounts are estimated based on the regulatory methodologies defined by each local jurisdiction.
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
57 Bank of America


by the rating agencies, and they consider a number of factors, including our own financial strength, performance, prospects and operations as well as factors not under our control. The rating

Bank of America 52


agencies could make adjustments to our ratings at any time, and they provide no assurances that they will maintain our ratings at current levels.
Other factors that influence our credit ratings include changes to the rating agencies’ methodologies for our industry or certain security types; the rating agencies’ assessment of the general operating environment for financial services companies; our relative positions in the markets in which we compete; our various risk exposures and risk management policies and activities; pending litigation and other contingencies or potential tail risks; our reputation; our liquidity position, diversity of funding sources and funding costs; the current and expected level and volatility of our earnings; our capital position and capital management practices; our corporate governance; the sovereign credit ratings of the U.S. government; current or future regulatory and legislative initiatives; and the agencies’ views on whether the U.S. government would provide meaningful support to the Corporation or its subsidiaries in a crisis.
On May 24, 2021, Standard & Poor’s Global Ratings (S&P) affirmed the current ratings of the Corporation and its subsidiaries, while at the same time revising its rating outlook to Positive from Stable.
On June 12, 2019,7, 2021, Fitch Ratings (Fitch) completed its periodic review ofupgraded the 12 large, complex securities trading and universal banks, including Bank of America Corporation. The agency affirmed the long-term and short-term senior debt ratings of the Corporation and all of its rated subsidiaries except Bank of America Merrill
Lynch International Designated Activity Company, which Fitch upgraded by one notch, to AA-/F1+. The rating outlook for all long-term ratings is currently stable.
On March 6, 2019, Moody’s Investors Service (Moody’s) and AA, respectively. Fitch also upgraded the long-term andCorporation’s short-term ratings of the Corporation by one notchrating to A2/P-1 from A3/P-2 for senior debt, as well as the long-term ratings of its rated subsidiaries, including BANA,F1+ which the agency upgraded to Aa2 from Aa3 for senior debt. Moody’s concurrently affirmedis now aligned with the short-term ratingsrating of the Corporation’s ratedits subsidiaries, including BANA. Moody’s citedFollowing the Corporation’s strengthening profitability, continued adherence to a conservative risk profile and stable capital ratios as rationale forupgrade, the upgrade. The rating outlook for all long-term ratings is currently stable.
The ratings from Standard & Poor’s Global Ratings (S&P) for the Corporation and its subsidiaries did not change during 2019. The long-term and short-term debtis Stable.
On November 22, 2021, Moody’s Investors Service (Moody’s) affirmed the current ratings of BofASthe Corporation and BofASE, which were initially rated by S&P duringits subsidiaries, while at the first quarter 2019, also remained unchanged during the rest of 2019.same time revising its rating outlook to Positive from Stable.
Table 1918 presents the Corporation’s current long-term/short-term senior debt ratings and outlooks expressed by the rating agencies.
Table 18
Table 19Senior Debt Ratings
Moody’s Investors ServiceStandard & Poor’s Global RatingsFitch Ratings
Long-termShort-termOutlookLong-termShort-termOutlookLong-termShort-termOutlook
Bank of America CorporationA2P-1      StablePositiveA-A-2      StablePositive        A+AA-        F1F1+Stable
Bank of America, N.A.Aa2P-1      StablePositiveA+A-1      StablePositive       AA-AAF1+Stable
Bank of America Merrill Lynch InternationalEurope Designated Activity CompanyNRNRNRA+A-1      StablePositive       AA-AAF1+Stable
Merrill Lynch, Pierce, Fenner & Smith IncorporatedNRNRNRA+A-1      StablePositive       AA-AAF1+Stable
BofA Securities, Inc.NRNRNRA+A-1      StablePositive       AA-AAF1+Stable
Merrill Lynch InternationalNRNRNRA+A-1      StablePositive        A+AA        F1F1+Stable
BofA Securities Europe SANRNRNRA+A-1      StablePositive        A+AA        F1F1+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 revenues, particularly in those businesses where counterparty creditworthiness is critical. In addition, under the terms of certain OTC derivative contracts and other trading agreements, in the event of downgrades of our or our rated subsidiaries’ credit ratings, the counterparties to those agreements may require us to provide additional collateral, or to terminate these contracts or agreements, which could cause us to sustain losses and/or adversely impact our liquidity. If the short-term credit ratings of our parent company, bank or broker-dealer subsidiaries were downgraded by one or more levels, the potential loss of access to short-term funding sources such as repo financing and the effect on our incremental cost of funds could be material.
While certain potential impacts are contractual and quantifiable, the full scope of the consequences of a credit rating downgrade to a financial institution is inherently uncertain, as it depends upon numerous dynamic, complex and inter-related factors and assumptions, including whether any downgrade of a company’s long-term credit ratings precipitates downgrades to its short-term credit ratings, and assumptions about the potential behaviors of various customers, investors and counterparties. For more information on potential impacts of credit rating downgrades, see Liquidity Risk – Liquidity Stress Analysis on page 51.
56.
For more information on additional collateral and termination
payments that could be required in connection with certain OTC derivative contracts and other trading agreements as a result of such a credit rating downgrade, see Note 3 – Derivatives to the Consolidated Financial Statements and Item 1A. Risk Factors.
Common Stock Dividends
For a summary of our declared quarterly cash dividends on common stock during 20192021 and through February 19, 2020,22, 2022, see Note 1413 – 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, BAC Capital Trust XIV and BAC Capital Trust XV, 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) or capital securities (the Capital Securities and, together with the Guaranteed Notes and the Trust Preferred Securities, the Guaranteed Securities), as applicable, that remained outstanding at December 31, 2021. The Corporation guarantees the payment of amounts and distributions with
Bank of America 58


respect to the Trust Preferred Securities and Capital 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 and Capital Securities, effectively constitutes a full and unconditional guarantee of the Trusts’ payment obligations on the Trust Preferred Securities or Capital Securities, as applicable. 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 10.
Representations and Warranties Obligations
For information on representations and warranties obligations in connection with the sale of mortgage loans, see Note 12 – Commitments and Contingencies to the Consolidated Financial Statements.
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

53Bank of America






value adjustments recorded in earnings. For derivative positions,
our credit risk is measured as the net cost in the event the counterparties with contracts in which we are in a gain position fail to perform under the terms of those contracts. We use the current fair value to represent credit exposure without giving consideration to future mark-to-market changes. The credit risk amounts take into consideration the effects of legally enforceable master netting agreements and cash collateral. Our consumer and commercial credit extension and review procedures encompass funded and unfunded credit exposures. For more information on derivatives and credit extension commitments, see Note 3 – Derivatives and Note 1312 – 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 60,65, Non-U.S. Portfolio on page 66, Provision for Credit Losses on page 68,71, Allowance for Credit Losses on page 68,73, and Note 5 – Outstanding Loans and Leases andNote 6 – Allowance for Credit Losses to the Consolidated Financial Statements. For more information on the factors that may expose us to credit risk, see Part I. Item 1A. Risk Factors - Credit on page 12.
During 2021, the economy gained momentum as unemployment continued to decline from double-digit highs during 2020 and the economy re-opened as vaccination rates increased and restrictions eased. With the easing of restrictions, we saw increased business openings, a rebound to commercial and consumer spending, higher asset values and increased global GDP, all of which positively impacted our consumer and commercial credit portfolios. Additionally, individuals and businesses in the U.S. benefited from various forms of government support through economic stimulus packages enacted in 2020 and 2021, which contributed to strong asset quality across our credit portfolios.

As a result of the economic recovery experienced in 2021, net charge-offs, nonperforming loans and commercial reservable criticized exposure declined compared to 2020. While there has been significant economic improvement in comparison to 2020, uncertainty remains about the timing and strength of the economy’s recovery, which may also be hampered by supply chain disruptions and inflationary pressures and could lead to adverse impacts to credit quality metrics in future periods. The pandemic and its full impact on the global economy continue to be highly uncertain. While COVID-19 cases eased throughout the majority of 2021, they reached new highs by the end of 2021, and the spread of new, more contagious variants could impact the magnitude and duration of this health crisis. However, ongoing virus containment efforts and vaccination progress, could support the macroeconomic recovery.
59 Bank of America


For more information on how the pandemic may affect our operations, see Executive Summary – Recent Developments – COVID-19 Pandemic on page 27 and Item 1A. Risk Factors – Coronavirus Disease on 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 inThe economic environment improved during 2021, with the U.S. unemployment rate continuing to decline and home prices continued during 2019 resulting in improvedincreasing. During 2021, net charge-offs decreased $805 million to $1.8 billion primarily due to lower credit quality compared to 2018. Net recoveries incard losses, as the consumer real estate portfolio due primarily to non-core loan salesimpact of government stimulus measures were partially offset by seasoningcharge-offs associated with deferrals that expired in the credit card portfolio compared2020. During 2021, nonperforming loans increased due to 2018.deferral activity.
Improved credit quality and continued loan balance runoff primarily in the non-core consumer real estate portfolio, partially offset by seasoning within the credit card portfolio, drove a $260 million decrease in theThe consumer allowance for loan and lease losses decreased $3.0 billion in 20192021 to $4.5 billion.$7.0 billion primarily due to improvements in the macroeconomic outlook and credit quality. For more information, see Allowance for Credit Losses on page 68.73.
For more information on our accounting policies regarding delinquencies, nonperforming status, charge-offs and troubled debt restructurings (TDRs) for the consumer portfolio, as well as interest accrual policies and delinquency status for loan modifications related to the pandemic, see Note 1 – Summary of Significant Accounting Principles and Note 5 – Outstanding Loans and Leases and Allowance for Credit Losses to the Consolidated Financial Statements.
Table 2019 presents our outstanding consumer loans and leases, consumer nonperforming loans and accruing consumer loans past due 90 days or more.
Table 19Consumer Credit Quality
 OutstandingsNonperformingAccruing Past Due
90 Days or More
December 31
(Dollars in millions)202120202021202020212020
Residential mortgage (1)
$221,963 $223,555 $2,284 $2,005 $634 $762 
Home equity 27,935 34,311 630 649  — 
Credit card81,438 78,708 n/an/a487 903 
Direct/Indirect consumer (2)
103,560 91,363 75 71 11 33 
Other consumer190 124  —  — 
Consumer loans excluding loans accounted for under the fair value option$435,086 $428,061 $2,989 $2,725 $1,132 $1,698 
Loans accounted for under the fair value option (3)
618 735 
Total consumer loans and leases$435,704 $428,796 
Percentage of outstanding consumer loans and leases (4)
n/an/a0.69 %0.64 %0.26 %0.40 %
Percentage of outstanding consumer loans and leases, excluding fully-insured loan portfolios (4)
n/an/a0.71 0.65 0.12 0.22 
             
Table 20Consumer Credit Quality           
             
 Outstandings Nonperforming 
Accruing Past Due
90 Days or More
 December 31
(Dollars in millions)2019 2018 2019 2018 2019 2018
Residential mortgage (1)
$236,169
 $208,557
 $1,470
 $1,893
 $1,088
 $1,884
Home equity 40,208
 48,286
 536
 1,893
 
 
Credit card97,608
 98,338
 n/a
 n/a
 1,042
 994
Direct/Indirect consumer (2)
90,998
 91,166
 47
 56
 33
 38
Other consumer192
 202
 
 
 
 
Consumer loans excluding loans accounted for under the fair value option$465,175
 $446,549

$2,053

$3,842

$2,163

$2,916
Loans accounted for under the fair value option (3)
594
 682
        
Total consumer loans and leases$465,769

$447,231
        
Percentage of outstanding consumer loans and leases (4)
n/a
 n/a
 0.44% 0.86% 0.47% 0.65%
Percentage of outstanding consumer loans and leases, excluding fully-insured loan portfolios (4)
n/a
 n/a
 0.46
 0.90
 0.24
 0.24
(1)
Residential mortgage loans accruing past due 90 days or more are fully-insured loans. At December 31, 2019 and 2018, residential mortgage includes $740 million and $1.4 billion of loans on which interest had been curtailed by the FHA, and therefore were no longer accruing interest, although principal was still insured, and $348 million and $498 million of loans on which interest was still accruing.
(2)
Outstandings primarily include auto and specialty lending loans and leases of $50.4 billion and $50.1 billion, U.S. securities-based lending loans of $36.7 billion and $37.0 billion and non-U.S. consumer loans of $2.8 billion and $2.9 billion at December 31, 2019 and 2018.
(3)
Consumer loans accounted for under the fair value option include residential mortgage loans of $257 million and $336 million and home equity loans of $337 million and $346 million at December 31, 2019 and 2018. For more information on the fair value option, see Note 22 – Fair Value Option to the Consolidated Financial Statements.
(4)
Excludes consumer loans accounted for under the fair value option. At December 31, 2019 and 2018, $6 million and $12 millionResidential mortgage loans accruing past due 90 days or more are fully-insured loans. At December 31, 2021 and 2020, residential mortgage includes $444 million and $537 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 $190 million and $225 million of loans on which interest was still accruing.
(2)Outstandings primarily include auto and specialty lending loans and leases of $48.5 billion and $46.4 billion, U.S. securities-based lending loans of $51.1 billion and $41.1 billion and non-U.S. consumer loans of $3.0 billion and $3.0 billion at December 31, 2021 and 2020.
(3)For more information on the fair value option, see Note 21 – Fair Value Option to the Consolidated Financial Statements.
(4)Excludes consumer loans accounted for under the fair value option. At December 31, 2021 and 2020, $21 million and $11 million of loans accounted for under the fair value option were past due 90 days or more and not accruing interest.
n/a = not applicable

Bank of America 54


Table 2120 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)2021202020212020
Residential mortgage$(28)$(30)(0.01)%(0.01)%
Home equity(119)(73)(0.39)(0.19)
Credit card1,723 2,349 2.29 2.76 
Direct/Indirect consumer1 122  0.14 
Other consumer270 284 n/mn/m
Total$1,847 $2,652 0.44 0.59 
(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 21Consumer Net Charge-offs and Related Ratios      
         
  Net Charge-offs 
Net Charge-off Ratios (1)
(Dollars in millions)2019 2018 2019 2018
Residential mortgage$(47) $28
 (0.02)% 0.01%
Home equity(358) (2) (0.81) 
Credit card2,948
 2,837
 3.12
 3.00
Direct/Indirect consumer209
 195
 0.23
 0.21
Other consumer234
 182
 n/m
 n/m
Total$2,986

$3,240
 0.66
 0.72
(1)
Net charge-off ratios are calculated as net charge-offs divided by average outstanding loans and leases excluding loans accounted for under the fair value option.
n/m = not meaningful
Table 22 presents outstandings, nonperforming balances, net charge-offs, allowance for loan and lease losses and provision for loan and lease losses for the core and non-core portfolios within the consumer real estate portfolio. We categorize consumer real estate loans as core and non-core based on loan and customer characteristics such as origination date, product type, loan-to-value (LTV), Fair Isaac Corporation (FICO) score and delinquency status consistent with our current consumer and mortgage servicing strategy. Generally, loans that were originated after January 1, 2010, qualified under GSE underwriting guidelines, or otherwise met our underwriting guidelines in place in 2015 are characterized
as core loans. All other loans are generally characterized as non-core loans and represent runoff portfolios. Core loans as reported in Table 22 include loans held in the Consumer Banking and GWIM segments, as well as loans held for ALM activities in All Other.
As shown in Table 22, outstanding core consumer real estate loans increased $27.3 billion during 2019 driven by an increase of $32.1 billion in residential mortgage, partially offset by a $4.8 billion decrease in home equity.
During 2019, we sold $4.7 billion of consumer real estate loans, primarily non-core, compared to $11.6 billion in 2018.
             
Table 22
Consumer Real Estate Portfolio (1)
    
       
  Outstandings Nonperforming    
 December 31 Net Charge-offs
(Dollars in millions)2019 2018 2019 2018 2019 2018
Core portfolio 
  
  
  
    
Residential mortgage$225,770
 $193,695
 $883
 $1,010
 $7
 $11
Home equity35,226
 40,010
 363
 955
 51
 78
Total core portfolio260,996

233,705

1,246

1,965

58
 89
Non-core portfolio   
  
  
    
Residential mortgage10,399
 14,862
 587
 883
 (54) 17
Home equity4,982
 8,276
 173
 938
 (409) (80)
Total non-core portfolio15,381

23,138

760

1,821

(463) (63)
Consumer real estate portfolio 
  
  
  
    
 Residential mortgage236,169
 208,557
 1,470
 1,893
 (47) 28
 Home equity40,208
 48,286
 536
 1,893
 (358) (2)
Total consumer real estate portfolio$276,377

$256,843

$2,006

$3,786

$(405) $26
             
      
Allowance for Loan
and Lease Losses
 Provision for Loan
and Lease Losses
      December 31 
      2019 2018 2019 2018
Core portfolio           
Residential mortgage    $229
 $214
 $22
 $7
Home equity    120
 228
 (58) (60)
Total core portfolio    349

442

(36)
(53)
Non-core portfolio     
  
    
Residential mortgage    96
 208
 (134) (104)
Home equity    101
 278
 (510) (335)
Total non-core portfolio    197

486

(644)
(439)
Consumer real estate portfolio     
  
    
 Residential mortgage    325
 422
 (112) (97)
 Home equity    221
 506
 (568) (395)
Total consumer real estate portfolio    $546

$928

$(680)
$(492)
(1)
Outstandings and nonperforming loans exclude loans accounted for under the fair value option. Consumer loans accounted for under the fair value option include residential mortgage loans of $257 million and $336 million and home equity loans of $337 million and $346 million at December 31, 2019 and 2018. For more information, see Note 22 – Fair Value Option to the Consolidated Financial Statements.

55Bank of America60






We believe that the presentation of information adjusted to exclude the impact of the fully-insured loan portfolio and loans accounted for under the fair value option is more representative of the ongoing operations and credit quality of the business. As a result, in the following tables and discussions of the residential mortgage and home equity portfolios, we exclude loans accounted for under the fair value option and provide information that excludes the impact of the fully-insured loan portfolio in certain credit quality statistics.
Residential Mortgage
The residential mortgage portfolio made up the largest percentage of our consumer loan portfolio at 51 percent of consumer loans and leases at December 31, 2019.in 2021. Approximately 5052 percent of the residential mortgage portfolio was in Consumer Banking
and 3643 percent was in GWIM. The remaining portion was in All Other and was comprised of loans used in our overall ALM activities,.
delinquent FHA loans repurchased pursuant to our servicing agreements with the Government National Mortgage Association as well as loans repurchased related to our representations and warranties.
Outstanding balances in the residential mortgage portfolio increased $27.6decreased $1.6 billion in 20192021 as retention of new originations waspaydowns were partially offset by loan sales of $2.7 billion and runoff.originations.
At December 31, 20192021 and 2018,2020, the residential mortgage portfolio included $18.7$12.7 billion and $20.1$11.8 billion of outstanding fully-insured loans, of which $11.2$2.2 billion and $14.0$2.8 billion had FHA insurance, with the remainder protected by Fannie Mae long-term standby agreements.
Table 2321 presents certain residential mortgage key credit statistics on both a reported basis and excluding the fully-insured loan portfolio. The following discussion presents the residential mortgage portfolio excluding the fully-insured loan portfolio.
Table 21Residential Mortgage – Key Credit Statistics
Reported Basis (1)
Excluding Fully-insured Loans (1)
December 31
(Dollars in millions)2021202020212020
Outstandings$221,963 $223,555 $209,259 $211,737 
Accruing past due 30 days or more1,753 2,314 866 1,224 
Accruing past due 90 days or more634 762  — 
Nonperforming loans (2)
2,284 2,005 2,284 2,005 
Percent of portfolio    
Refreshed LTV greater than 90 but less than or equal to 1001 %%1 %%
Refreshed LTV greater than 100  
Refreshed FICO below 6202 1 
                 
Table 23Residential Mortgage – Key Credit Statistics        
                 
          
Reported Basis (1)
 
Excluding Fully-insured Loans (1)
          December 31
(Dollars in millions)        2019 2018 2019 2018
Outstandings       $236,169
 $208,557
 $217,479
 $188,427
Accruing past due 30 days or more       3,108
 3,945
 1,296
 1,155
Accruing past due 90 days or more       1,088
 1,884
 
 
Nonperforming loans       1,470
 1,893
 1,470
 1,893
Percent of portfolio        
  
  
  
Refreshed LTV greater than 90 but less than or equal to 100   2% 2% 2% 2%
Refreshed LTV greater than 100       1
 1
 1
 1
Refreshed FICO below 620       3
 4
 2
 2
2006 and 2007 vintages (2)
       4
 6
 4
 6
(1)Outstandings, accruing past due, nonperforming loans and percentages of portfolio exclude loans accounted for under the fair value option. For information on our interest accrual policies and delinquency status for loan modifications related to the pandemic, see Note 1 – Summary of Significant Accounting Principles to the Consolidated Financial Statements.
(1)
(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.
Outstandings, accruing past due, nonperforming loans and percentages of portfolio exclude loans accounted for under the fair value option.
(2)
These vintages of loans accounted for $365 million, or 25 percent, and $536 million, or 28 percent, of nonperforming residential mortgage loans at December 31, 2019 and 2018.
Nonperforming outstanding balances in the residential mortgage loans decreased $423portfolio increased $279 million in 20192021 primarily driven by sales.deferral activity. Of the nonperforming residential mortgage loans at December 31, 2019, $616 million,2021, $1.2 billion, or 4251 percent, were current on contractual payments. Loans accruing past due 30 days or more increased $141 million.
Net charge-offs improved $75decreased $358 million to a net recovery of $47 million in 2019 compared to net charge-offs of $28 million in 2018 primarily due to recoveries from the sales of previously charged-off loans anddriven by continued improvement in credit quality.
Net recoveries of $28 million in 2021 remained relatively unchanged compared to 2020.
Of the $217.5$209.3 billion in total residential mortgage loans outstanding at December 31, 2019, as shown in Table 23, 262021, 27 percent were originated as interest-only loans. The outstanding balance of interest-only residential mortgage loans that have entered the amortization period was $7.4$4.8 billion, or 13eight percent, at December 31, 2019.2021. Residential mortgage loans that have entered the amortization period generally have experienced a higher rate of early stage delinquencies and nonperforming status compared to the residential mortgage portfolio as a whole. At December 31, 2019, $1242021, $66 million, or twoone percent, of outstanding interest-only residential mortgages that had entered the amortization period were accruing past due 30 days or more
compared to $1.3 billion,$866 million, or less than one percent, for the entire residential
mortgage portfolio. In addition, at December 31, 2019, $2602021, $275 million, or foursix percent, of outstanding interest-only residential mortgage loans that had entered the amortization period were nonperforming, of which $108$83 million were contractually current compared to $1.5$2.3 billion, or one percent, for the entire residential mortgage portfolio. Loans that have yet to enter the amortization period in our interest-only residential mortgage portfolio are primarily well-collateralized loans to our wealth management clients and have an interest-only period of three to ten years. Approximately 9491 percent of these loans that have yet to enter the amortization period will not be required to make a fully-amortizing payment until 20222025 or later.
Table 2422 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 15 percent and 16 percent of outstandings at both December 31, 20192021 and 2018.2020. In the New York area, the New York-Northern New Jersey-Long Island MSA made up 1315 percent and 14 percent of outstandings at both December 31, 20192021 and 2018.2020.

61Bank of America56


Table 22Residential Mortgage State Concentrations
Outstandings (1)
Nonperforming (1)
December 31Net Charge-offs
(Dollars in millions)December 31
2021
December 31
2020
December 31
2021
December 31
2020
20212020
California$77,819 $83,185 $693 $570 $(14)$(18)
New York24,975 23,832 358 272 3 
Florida13,883 13,017 158 175 (8)(5)
Texas9,002 8,868 86 78  — 
New Jersey8,723 8,806 117 98  (1)
Other74,857 74,029 872 812 (9)(9)
Residential mortgage loans$209,259 $211,737 $2,284 $2,005 $(28)$(30)
Fully-insured loan portfolio12,704 11,818   
Total residential mortgage loan portfolio$221,963 $223,555   
(1)Outstandings and nonperforming loans exclude loans accounted for under the fair value option.
             
Table 24Residential Mortgage State Concentrations   
             
 
Outstandings (1)
 
Nonperforming (1)
    
 December 31 Net Charge-offs
(Dollars in millions)2019 2018 2019 2018 2019 2018
California$88,998
 $76,323
 $274
 $314
 $(22) $(22)
New York22,385
 19,219
 196
 222
 5
 10
Florida12,833
 11,624
 143
 221
 (12) (6)
Texas8,943
 7,820
 65
 102
 1
 4
New Jersey8,734
 7,051
 77
 98
 (4) 8
Other75,586
 66,390
 715
 936
 (15) 34
Residential mortgage loans$217,479

$188,427

$1,470

$1,893

$(47)
$28
Fully-insured loan portfolio18,690
 20,130
  
  
    
Total residential mortgage loan portfolio$236,169
 $208,557
  
  
    
(1)
Outstandings and nonperforming loans exclude loans accounted for under the fair value option.

Home Equity
At December 31, 2019,2021, the home equity portfolio made up ninesix percent of the consumer portfolio and was comprised of home equity lines of credit (HELOCs), home equity loans and reverse mortgages. We no longer originate home equity loans or reverse mortgages.
At December 31, 2019, our HELOC portfolio had an outstanding balance of $37.5 billion, or 93 percent of the total home equity portfolio, compared to $44.3 billion, or 92 percent, at December 31, 2018. HELOCs generally have an initial draw period of 10 years, and after the initial draw period ends, the loans generally convert to 15- or 20-year amortizing loans.
At December 31, 2019, our We no longer originate home equity loan portfolio had an outstanding balance of $1.2 billion,loans or three percent of the total home equity portfolio, compared to $1.8 billion, or four percent, at December 31, 2018. At December 31, 2019, our reverse mortgage portfolio had an outstanding balance of $1.5 billion, or four percent of the total home equity portfolio, compared to $2.2 billion, also four percent, at December 31, 2018.mortgages.
At December 31, 2019,2021, 80 percent of the home equity portfolio was in Consumer Banking, 1211 percent was in All Other and the remainder of the portfolio was primarily in GWIM. Outstanding balances in the home equity portfolio decreased $8.1$6.4 billion in 20192021 primarily due to paydowns and loan sales of $2.0 billion outpacing new
originations and draws on existing lines. Of the total home equity portfolio at December 31, 20192021 and 2018, $15.02020, $12.2 billion, or 3744 percent, and $17.3$13.8 billion, or 3640 percent, were in first-lien positions. At December 31, 2019,2021, outstanding balances in the home equity portfolio that were in a second-lien or more junior-lien position and where we also held the first-lien loan totaled $6.9$4.6 billion, or 1716 percent of our total home equity portfolio.
Unused HELOCs totaled $43.6$40.5 billion and $43.1$42.3 billion at December 31, 20192021 and 2018. The increase was primarily driven by the impact of lower utilization of open lines and new production partially offset by customers choosing to close accounts.2020. The HELOC utilization rate was 4639 percent and 5143 percent at December 31, 20192021 and 2018.2020.
Table 2523 presents certain home equity portfolio key credit statistics.
Table 23
Home Equity – Key Credit Statistics (1)
December 31
(Dollars in millions)20212020
Outstandings$27,935 $34,311 
Accruing past due 30 days or more157 186 
Nonperforming loans (2)
630 649 
Percent of portfolio
Refreshed CLTV greater than 90 but less than or equal to 100 %%
Refreshed CLTV greater than 1001 
Refreshed FICO below 6203 
             
Table 25
Home Equity – Key Credit Statistics (1)
             
          December 31
(Dollars in millions)        2019 2018
Outstandings        $40,208
 $48,286
Accruing past due 30 days or more (2)
     218
 363
Nonperforming loans (2)
        536
 1,893
Percent of portfolio           
Refreshed CLTV greater than 90 but less than or equal to 100   1% 2%
Refreshed CLTV greater than 100     2
 3
Refreshed FICO below 620        3
 5
2006 and 2007 vintages (3)
       18
 22
(1)(1)
Outstandings, accruing past due, nonperforming loans and percentages of the portfolio exclude loans accounted for under the fair value option.
(2)
Accruing past due 30 days or more include $30 million and $48 million and nonperforming loans include $57 million and $218 million of loans where we serviced the underlying first lien at December 31, 2019 and 2018.
(3)
These vintages of loans accounted for 34 percent and 49 percent of nonperforming home equity loans at December 31, 2019 and 2018.
Nonperforming outstanding balances in the home equity portfolio decreased $1.4 billion in 2019 as outflows, primarily sales, outpaced new inflows. Ofexclude loans accounted for under the nonperforming home equity loans at December 31, 2019, $241 million, or 45 percent, were currentfair value option. For information on contractual payments. Nonperformingour interest accrual policies and delinquency status for loan modifications related to the pandemic, see Note 1 – Summary of Significant Accounting Principles to the Consolidated Financial Statements.
(2)Includes loans that are contractually current which primarily consist of collateral-dependent TDRs, including those that have been discharged in Chapter 7 bankruptcy, junior-lien loans where the underlying first lien is 90 days or more past due, as well as loans that have not yet demonstrated a sustained period of payment performance following a TDR.

Nonperforming outstanding balances in the home equity portfolio remained relatively flat at $630 million at December 31, 2021. Of the nonperforming home equity loans at December 31, 2021, $227 million, or 36 percent, were current on contractual payments. In addition, $162$273 million, or 3043 percent of nonperforming home equity loans were 180 days or more past due and had been written down to the estimated fair value of the
collateral, less costs to sell. Accruing loans that were 30 days or more past due decreased $145$29 million in 2019.2021.
Net charge-offs decreased $356recoveries increased $46 million to a net recovery of $358$119 million in 20192021 compared to a net recovery of $2 millionthe same period in 2018 primarily2020. The increase was driven by recoveries from the sales of previously charged off non-corefavorable portfolio trends due in part to improvement in home equity loans.prices.
Of the $40.2$27.9 billion in total home equity portfolio outstandings at December 31, 2019,2021, as shown in Table 25, 1723, 14 percent require interest-only payments. The outstanding balance of HELOCs that have reached the end of their draw period and have entered the amortization period was $11.5$6.8 billion at December 31, 2019.2021. The HELOCs that have entered the amortization period have experienced a higher percentage of early stage delinquencies and

57Bank of America






nonperforming status when
compared to the HELOC portfolio as a whole. At December 31, 2019, $1492021, $105 million, or onetwo percent, of outstanding HELOCs that had entered the amortization period were accruing past due 30 days or more. In addition, at December 31, 2019, $4722021, $455 million, or fourseven percent, were nonperforming. Loans that have yet to enter the amortization period in our interest-only portfolio are primarily post-2008 vintages and generally have better credit quality than the previous vintages that had entered the amortization period. We communicate to contractually current customers more than a year prior to the end of their draw period to inform them of the potential change to the payment structure before entering the amortization period, and provide payment options to customers prior to the end of the draw period.
Although we do not actively track how many of our home equity customers pay only the minimum amount due on their home equity
loans and lines, we can infer some of this information through a review of our HELOC portfolio that we service and that is still in its revolving period. During 2019, 132021, nine percent of these customers with an outstanding balance did not pay any principal on their HELOCs.
Bank of America 62


Table 2624 presents outstandings, nonperforming balances and net charge-offsrecoveries by certain state concentrations for the home equity portfolio. In the New York area, the New York-Northern New Jersey-Long Island MSA made up 13 percent of the outstanding home equity portfolio at both December 31, 2019 2021
and 2018.2020. The Los Angeles-Long Beach-Santa Ana MSA within California made up 10 percent and 11 percent of the outstanding home equity portfolio at both December 31, 20192021 and 2018.2020.
Table 24Home Equity State Concentrations
Outstandings (1)
Nonperforming (1)
December 31Net Recoveries
(Dollars in millions)202120202021202020212020
California$7,600 $9,488 $140 $143 $(40)$(26)
Florida2,977 3,715 78 80 (21)(11)
New Jersey2,259 2,749 69 67 (4)(3)
New York2,072 2,495 96 103 (1)(1)
Massachusetts1,422 1,719 32 32 (3)(1)
Other11,605 14,145 215 224 (50)(31)
Total home equity loan portfolio$27,935 $34,311 $630 $649 $(119)$(73)
             
Table 26Home Equity State Concentrations   
             
  
Outstandings (1)
 
Nonperforming (1)
  
  December 31 Net Charge-offs
(Dollars in millions)2019 2018 2019 2018 2019 2018
California$11,232
 $13,515
 $101
 $536
 $(117) $(54)
Florida4,327
 5,418
 71
 315
 (74) 1
New Jersey3,216
 3,871
 56
 150
 (8) 25
New York2,899
 3,590
 85
 194
 (1) 23
Massachusetts2,023
 2,400
 29
 65
 (5) 5
Other16,511
 19,492
 194
 633
 (153) (2)
Total home equity loan portfolio$40,208

$48,286

$536

$1,893

$(358)
$(2)
(1)Outstandings and nonperforming loans exclude loans accounted for under the fair value option.
(1)
Outstandings and nonperforming loans exclude loans accounted for under the fair value option.

Credit Card
At December 31, 2019,2021, 97 percent of the credit card portfolio was managed in Consumer Banking with the remainder in GWIM. Outstandings in the credit card portfolio increased $2.7 billion in 2021 to $81.4 billion due to higher retail spend. Net charge-offs decreased $730 million in 2019 to $97.6 billion. In 2019, net charge-offs increased $111$626 million to $2.9$1.7 billion during 2021 compared to netthe same period in 2020 due to the impact of government stimulus measures, partially offset by charge-offs of $2.8 billioncertain loans with deferrals that expired in2018. 2020. Credit card
loans 30 days or more past due and still
accruing interest increased $46decreased $692 million, and loans 90 days or more past due and still accruing interest increased $48 million. These increases were driven by portfolio seasoning.decreased $416 million primarily due to charge-offs of certain loans with deferrals that expired in 2020 and the impact of government stimulus measures.
Unused lines of credit for credit card increased to $336.9$361.2 billion at December 31, 20192021 from $334.8$342.4 billion at December 31, 2018.2020.
Table 2725 presents certain state concentrations for the credit card portfolio.
Table 25Credit Card State Concentrations
Outstandings
Accruing Past Due
90 Days or More (1)
December 31Net Charge-offs
(Dollars in millions)202120202021202020212020
California$13,076 $12,543 $82 $166 $322 $419 
Florida8,046 7,666 71 135 245 306 
Texas6,894 6,499 47 87 158 202 
New York4,725 4,654 35 76 135 188 
Washington4,080 3,685 13 21 39 56 
Other44,617 43,661 239 418 824 1,178 
Total credit card portfolio$81,438 $78,708 $487 $903 $1,723 $2,349 
             
Table 27Credit Card State Concentrations   
             
  Outstandings 
Accruing Past Due
90 Days or More
  
  December 31 Net Charge-offs
(Dollars in millions)2019 2018 2019 2018 2019 2018
California$16,135
 $16,062
 $178
 $163
 $526
 $479
Florida9,075
 8,840
 135
 119
 363
 332
Texas7,815
 7,730
 93
 84
 241
 224
New York5,975
 6,066
 80
 81
 243
 268
Washington4,639
 4,558
 26
 24
 71
 63
Other53,969
 55,082
 530
 523
 1,504
 1,471
Total credit card portfolio$97,608

$98,338

$1,042

$994

$2,948

$2,837
(1)For information on our interest accrual policies and delinquency status for loan modifications related to the pandemic, see Note 1 – Summary of Significant Accounting Principles to the Consolidated Financial Statements.
Direct/Indirect Consumer
At December 31, 2019, 562021, 47 percent of the direct/indirect portfolio was included in Consumer Banking (consumer auto and specialty lending – automotive, recreational vehicle marine, aircraftlending) and consumer personal loans) and 4453 percent was included in
GWIM (principally securities-based lending loans).
Outstandings of $91.0 billion in the direct/indirect portfolio were relatively unchanged at December 31, 2019.increased by $12.2 billion in 2021 to $103.6 billion driven by client demand for liquidity and high asset values in the securities-based lending portfolio.

63 Bank of America


Table 2826 presents certain state concentrations for the direct/indirect consumer loan portfolio.
Table 26Direct/Indirect State Concentrations
Outstandings
Accruing Past Due
90 Days or More
(1)
December 31Net Charge-offs
(Dollars in millions)202120202021202020212020
California$15,061 $12,248 $2 $$3 $20 
Florida13,352 10,891 1 1 20 
Texas9,505 8,981 2 2 20 
New York7,802 6,609 1 3 
New Jersey4,228 3,572  — (3)
Other53,612 49,062 5 15 (5)51 
Total direct/indirect loan portfolio$103,560 $91,363 $11 $33 $1 $122 

(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.
Bank of America 58


             
Table 28Direct/Indirect State Concentrations   
             
  Outstandings Accruing Past Due
90 Days or More
  
  December 31 Net Charge-offs
(Dollars in millions)2019 2018 2019 2018 2019 2018
California$11,912
 $11,734
 $4
 $4
 $49
 $21
Florida10,154
 10,240
 4
 4
 27
 36
Texas9,516
 9,876
 5
 6
 29
 30
New York6,394
 6,296
 1
 2
 12
 9
New Jersey3,468
 3,308
 1
 1
 4
 2
Other49,554
 49,712
 18
 21
 88
 97
Total direct/indirect loan portfolio$90,998

$91,166

$33

$38

$209

$195
Nonperforming Consumer Loans, Leases and Foreclosed Properties Activity
Table 2927 presents nonperforming consumer loans, leases and foreclosed properties activity during 20192021 and 2018.2020. During 2019,2021, nonperforming consumer loans decreased $1.8 billionincreased $264 million to $2.1$3.0 billion primarily driven by loan sales of $1.5 billion.consumer real estate deferral activity.
At December 31, 2019, $6062021, $888 million, or 2930 percent of nonperforming loans were 180 days or more past due and had been written down to their estimated property value less costs
to sell. In addition, at December 31, 2019, $901 million,2021, $1.4 billion, or 44
48 percent of nonperforming consumer loans were modified and are now current after successful trial periods, or are current loans classified as nonperforming loans in accordance with applicable policies.
Foreclosed properties decreased $15$22 million in 20192021 to $229 million as liquidations outpaced additions.
$101 million. Nonperforming loans also include certain loans that have been modified in TDRs where economic concessions have been granted to borrowers experiencing financial difficulties. Nonperforming TDRs are included in Table 29.
Table 27Nonperforming Consumer Loans, Leases and Foreclosed Properties Activity
(Dollars in millions)20212020
Nonperforming loans and leases, January 1$2,725 $2,053 
Additions2,006 2,278 
Reductions:
Paydowns and payoffs(625)(440)
Sales(4)(38)
Returns to performing status (1)
(1,037)(1,014)
Charge-offs(64)(78)
Transfers to foreclosed properties(12)(36)
Total net additions to nonperforming loans and leases264 672 
Total nonperforming loans and leases, December 312,989 2,725 
Foreclosed properties, December 31 (2)
101 123 
Nonperforming consumer loans, leases and foreclosed properties, December 31$3,090 $2,848 
Nonperforming consumer loans and leases as a percentage of outstanding consumer loans and leases (3)
0.69 %0.64 %
Nonperforming consumer loans, leases and foreclosed properties as a percentage of outstanding consumer loans, leases and foreclosed properties (3)
0.71 0.66 
(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 $52 million and $119 million at December 31, 2021 and 2020.
(3)Outstanding consumer loans and leases exclude loans accounted for under the fair value option.

     
Table 29Nonperforming Consumer Loans, Leases and Foreclosed Properties Activity   
     
(Dollars in millions)2019 2018
Nonperforming loans and leases, January 1$3,842
 $5,166
Additions1,407
 2,440
Reductions:   
Paydowns and payoffs(701) (958)
Sales(1,523) (969)
Returns to performing status (1)
(766) (1,283)
Charge-offs(111) (401)
Transfers to foreclosed properties(95) (151)
Transfers to loans held-for-sale
 (2)
Total net reductions to nonperforming loans and leases(1,789)
(1,324)
Total nonperforming loans and leases, December 312,053

3,842
Foreclosed properties, December 31 (2)
229
 244
Nonperforming consumer loans, leases and foreclosed properties, December 31$2,282

$4,086
Nonperforming consumer loans and leases as a percentage of outstanding consumer loans and leases (3)
0.44% 0.86%
Nonperforming consumer loans, leases and foreclosed properties as a percentage of outstanding consumer loans, leases and foreclosed properties (3)
0.49
 0.92
(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,Bank of America $260 million and $488 million at December 31, 2019 and 2018.64
(3)


Outstanding consumer loans and leases exclude loans accounted for under the fair value option.
Table 3028 presents TDRs for the consumer real estate portfolio. Performing TDR balances are excluded from nonperforming loans and leases in Table 29.27.
Table 28Consumer Real Estate Troubled Debt Restructurings
December 31, 2021December 31, 2020
(Dollars in millions)NonperformingPerformingTotalNonperformingPerformingTotal
Residential mortgage (1, 2)
$1,498 $2,278 $3,776 $1,195 $2,899 $4,094 
Home equity (3)
254 652 906 248 836 1,084 
Total consumer real estate troubled debt restructurings$1,752 $2,930 $4,682 $1,443 $3,735 $5,178 
             
Table 30Consumer Real Estate Troubled Debt Restructurings
             
  December 31, 2019 December 31, 2018
(Dollars in millions)Nonperforming Performing Total Nonperforming Performing Total
Residential mortgage (1, 2)
$921
 $3,832
 $4,753
 $1,209
 $4,988
 $6,197
Home equity (3)
252
 977
 1,229
 1,107
 1,252
 2,359
Total consumer real estate troubled debt restructurings$1,173

$4,809

$5,982

$2,316

$6,240

$8,556
(1)
At December 31, 2019 and 2018, residential mortgage TDRs deemed collateral dependent totaled $1.2 billion and $1.6 billion, and included $748 million and $960 million of loans classified as nonperforming and $468 million and $605 millionAt December 31, 2021 and 2020, residential mortgage TDRs deemed collateral dependent totaled $1.6 billion and $1.4 billion, and included $1.4 billion and $1.0 billion of loans classified as nonperforming and $279 million and $361 million of loans classified as performing.
(2)At December 31, 2021 and 2020, residential mortgage performing TDRs include $1.2 billion and $1.5 billion of loans that were fully-insured.
(3)At December 31, 2021 and 2020, home equity TDRs deemed collateral dependent totaled $370 million and $407 million, and include $222 million and $216 million of loans classified as nonperforming and $148 million and $191 million of loans classified as performing.
(2)
At December 31, 2019 and 2018, residential mortgage performing TDRs include $2.1 billion and $2.8 billion of loans that were fully-insured.
(3)
At December 31, 2019 and 2018, home equity TDRs deemed collateral dependent totaled $442 million and $1.3 billion, and include $209 million and $961 million of loans classified as nonperforming and $233 million and $322 million of loans classified as performing.
In addition to modifying consumer real estate loans, we work with customers who are experiencing financial difficulty by modifying credit card and other consumer loans. Credit card and other consumer loan modifications generally involve a reduction
in the customer’s interest rate on the account and placing the customer on a fixed payment plan not exceeding 60 months, all of which are considered TDRs (the renegotiated TDR portfolio).months.

59Bank of America






Modifications of credit card and other consumer loans are made through renegotiation programs utilizing direct customer contact, but may also utilize external renegotiation programs. The renegotiated TDR portfolio is excluded in large part from Table 29 as substantially all of the loans remain on accrual status until either charged off or paid in full. At December 31, 20192021 and 2018,2020, our renegotiatedcredit card and other consumer TDR portfolio was $679$672 million and $566$701 million, of which $570$599 million and $481$614 million were current or less than 30 days past due under the modified terms. The increase in the renegotiated TDR portfolio was primarily driven by new renegotiated enrollments outpacing runoff of existing portfolios.
Commercial Portfolio Credit Risk Management
Credit risk management for the commercial portfolio begins with an assessment of the credit risk profile of the borrower or counterparty based on an analysis of its financial position. As part of the overall credit risk assessment, our commercial credit exposures are assigned a risk rating and are subject to approval based on defined credit approval standards. Subsequent to loan origination, risk ratings are monitored on an ongoing basis, and if necessary, adjusted to reflect changes in the financial condition, cash flow, risk profile or outlook of a borrower or counterparty. In making credit decisions, we consider risk rating, collateral, country, industry and single-name concentration limits while also balancing these considerations with the total borrower or counterparty relationship. We use a variety of tools to continuously monitor the ability of a borrower or counterparty to perform under its obligations. We use risk rating aggregations to measure and evaluate concentrations within portfolios. In addition, risk ratings are a factor in determining the level of allocated capital and the allowance for credit losses.
As part of our ongoing risk mitigation initiatives, we attempt to work with clients experiencing financial difficulty to modify their loans to terms that better align with their current ability to pay. In situations where an economic concession has been granted to a borrower experiencing financial difficulty, we identify these loans as TDRs. For more information on our accounting policies regarding delinquencies, nonperforming status and net charge-offs for the commercial portfolio, seeNote 1 – Summary of Significant Accounting Principles to the Consolidated Financial Statements.
Management of Commercial Credit Risk Concentrations
Commercial credit risk is evaluated and managed with the goal that concentrations of credit exposure continue to be aligned with our risk appetite. We review, measure and manage concentrations of credit exposure by industry, product,
geography, customer relationship and loan size. We also review, measure and manage commercial real estate loans by geographic location and property type. In addition, within our non-U.S. portfolio, we evaluate exposures by region and by country. Tables 35, 3833, 36 and 4139 summarize our concentrations. We also utilize syndications of
exposure to third parties, loan sales, hedging and other risk mitigation techniquestomanagethesizeandriskprofileofthe commercial credit portfolio. For more information on our industry concentrations, see Commercial Portfolio Credit Risk Management – Industry Concentrations on page 6469 and Table 38.36.
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 1312 – Commitments and Contingencies to the Consolidated Financial Statements.
Commercial Credit Portfolio
During 2019,2021, commercial credit quality among large corporateimproved as the economic recovery gained momentum driven in part by increased consumer spending and middle-market borrowersCOVID-19 vaccination progress. Accordingly, charge-offs, nonperforming commercial loans and reservable criticized utilized exposure declined during this period. Outstanding commercial loans and leases increased $44.4 billion during 2021 due to growth in our commercial and industrial, portfolio remained strong. primarily in Global Markets with most of the increase in investment grade exposures. This increase was partially offset by lower U.S. small business commercial loans due to repayments of PPP loans by the Small Business Administration (SBA) under the terms of the program. For more information on
65 Bank of America


PPP loans, see Note 1 – Summary of Significant Accounting Principles to the Consolidated Financial Statements.
Credit quality of commercial real estate borrowers has begun to stabilize in mostmany sectors remained stable with conservative LTV ratios.as economies have reopened. However, somecertain sectors, including hospitality, while showing signs of improvement, continue to be negatively impacted due to the pandemic. Moreover, many real estate markets, experienced slowingwhile improving, are still experiencing some disruptions in demand, supply chain challenges and tenant difficulties. Current and future office demand is uncertain as companies evaluate space needs with employment models that utilize a mix of remote and decelerating rental income.conventional office use.
The commercial allowance for loan and lease losses decreased $3.4 billion during 2021 to $5.4 billion driven by improvements in the macroeconomic outlook and credit quality. For more information, see Allowance for Credit Losses on page 73.
Total commercial utilized credit exposure increased $14.3$33.2 billion in 2019during 2021 to $635.3$653.5 billion primarily driven by higher loans and leases. The utilization rate for loans and leases, SBLCsstandby letters of credit (SBLCs) and financial guarantees, and commercial letters of credit, in the aggregate, was 5856 percent at December 31, 20192021 and 5957 percent at December 31, 2018.2020.
Table 3129 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 29Commercial Credit Exposure by Type
 
Commercial Utilized (1)
Commercial Unfunded (2, 3, 4)
Total Commercial Committed
December 31
(Dollars in millions)202120202021202020212020
Loans and leases$543,420 $499,065 $454,256 $404,740 $997,676 $903,805 
Derivative assets (5)
35,344 47,179  — 35,344 47,179 
Standby letters of credit and financial guarantees34,389 34,616 639 538 35,028 35,154 
Debt securities and other investments19,427 22,618 4,638 4,827 24,065 27,445 
Loans held-for-sale13,185 8,378 16,581 9,556 29,766 17,934 
Operating leases5,935 6,424  — 5,935 6,424 
Commercial letters of credit1,176 855 247 280 1,423 1,135 
Other652 1,168  — 652 1,168 
Total$653,528 $620,303 $476,361 $419,941 $1,129,889 $1,040,244 
Bank of America (1)60


             
Table 31Commercial Credit Exposure by Type
             
  
Commercial Utilized (1)
 
Commercial Unfunded (2, 3, 4)
 Total Commercial Committed
  December 31
(Dollars in millions)2019 2018 2019 2018 2019 2018
Loans and leases$517,657
 $499,664
 $405,834
 $369,282
 $923,491
 $868,946
Derivative assets (5)
40,485
 43,725
 
 
 40,485
 43,725
Standby letters of credit and financial guarantees36,062
 34,941
 468
 491
 36,530
 35,432
Debt securities and other investments25,546
 25,425
 5,101
 4,250
 30,647
 29,675
Loans held-for-sale7,047
 9,090
 15,135
 14,812
 22,182
 23,902
Operating leases6,660
 6,060
 
 
 6,660
 6,060
Commercial letters of credit1,049
 1,210
 451
 168
 1,500
 1,378
Other800
 898
 
 
 800
 898
Total$635,306
 $621,013
 $426,989
 $389,003
 $1,062,295
 $1,010,016
(1)
Commercial utilized exposure includes loans of $7.7 billion and $3.7 billion and issued letters of credit with a notional amount of $170 million and $100 million accounted for under the fair value option at December 31, 2019 and 2018.
(2)
Commercial unfunded exposure includes commitments accounted for under the fair value option with a notional amount of $4.2 billion and $3.0 billion at December 31, 2019 and 2018.
(3)
Excludes unused business card lines, which are not legally binding.
(4)
Includes the notional amount of unfunded legally binding lending commitments net of amounts distributed (i.e., syndicated or participated) to other financial institutions. The distributed amounts were $10.6 billion and $10.7 billion at December 31, 2019 and 2018.
(5)
Derivative assets are carried at fair value, reflect the effects of legally enforceable master netting agreements and have been reduced by cash collateral of $33.9 billion and $32.4 billion at December 31, 2019 and 2018. Not reflected in utilized and committed exposure is additional non-cash derivative collateral held of $35.2 billion and $33.0 billion at December 31, 2019 and 2018, which consists primarily of other marketable securities.
Outstanding commercial loans and leases increased $18.0 billion during 2019 primarily in the commercial and industrial portfolio. Nonperforming commercial loans increased $397 million and commercial reservable criticized utilized exposure increased $391 million driven byincludes loans of $7.2 billion and $5.9 billion accounted for under the fair value option at December 31, 2021 and 2020.
(2)Commercial unfunded exposure includes commitments accounted for under the fair value option with a small numbernotional amount of client downgrades across industries which were not indicative of broader issues in the
portfolio. The allowance for loan$4.8 billion and lease losses for the commercial portfolio increased $75 million to $4.9$3.9 billion at December 31, 2019. For more information, see Allowance for Credit Losses on page 68.2021 and 2020.
(3)Excludes unused business card lines, which are not legally binding.
(4)Includes the notional amount of unfunded legally binding lending commitments net of amounts distributed (i.e., syndicated or participated) to other financial institutions. The distributed amounts were $10.7 billion and $10.5 billion at December 31, 2021 and 2020.
(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 $30.8 billion and $42.5 billion at December 31, 2021 and 2020. Not reflected in utilized and committed exposure is additional non-cash derivative collateral held of $44.8 billion and $39.3 billion at December 31, 2021 and 2020, which consists primarily of other marketable securities.
Nonperforming commercial loans decreased $649 million. Table 3230 presents our commercial loans and leases portfolio and related credit quality information at December 31, 20192021 and 2018.2020.
Table 30Commercial Credit Quality
OutstandingsNonperformingAccruing Past Due
90 Days or More
December 31
(Dollars in millions)202120202021202020212020
Commercial and industrial:
U.S. commercial$325,936 $288,728 $825 $1,243 $171 $228 
Non-U.S. commercial113,266 90,460 268 418 19 10 
Total commercial and industrial439,202 379,188 1,093 1,661 190 238 
Commercial real estate63,009 60,364 382 404 40 
Commercial lease financing14,825 17,098 80 87 8 25 
517,036 456,650 1,555 2,152 238 269 
U.S. small business commercial (1)
19,183 36,469 23 75 87 115 
Commercial loans excluding loans accounted for under the fair value option$536,219 $493,119 $1,578 $2,227 $325 $384 
Loans accounted for under the fair value option (2)
7,201 5,946 
Total commercial loans and leases$543,420 $499,065 
(1)Includes card-related products.
(2)Commercial loans accounted for under the fair value option include U.S. commercial of $4.6 billion and $2.9 billion and non-U.S. commercial of $2.6 billion and $3.0 billion at December 31, 2021 and 2020. For more information on the fair value option, see Note 21 – Fair Value Option to the Consolidated Financial Statements.
             
Table 32Commercial Credit Quality
   
  Outstandings Nonperforming 
Accruing Past Due
90 Days or More
  December 31
(Dollars in millions)2019 2018 2019 2018 2019 2018
Commercial and industrial:           
U.S. commercial$307,048
 $299,277
 $1,094
 $794
 $106
 $197
Non-U.S. commercial104,966
 98,776
 43
 80
 8
 
Total commercial and industrial412,014
 398,053
 1,137
 874
 114
 197
Commercial real estate62,689
 60,845
 280
 156
 19
 4
Commercial lease financing19,880
 22,534
 32
 18
 20
 29
 494,583
 481,432
 1,449
 1,048
 153
 230
U.S. small business commercial (1)
15,333
 14,565
 50
 54
 97
 84
Commercial loans excluding loans accounted for under the fair value option509,916
 495,997
 1,499
 1,102
 250
 314
Loans accounted for under the fair value option (2)
7,741
 3,667
 
 
 
 
Total commercial loans and leases$517,657
 $499,664
 $1,499
 $1,102
 $250
 $314
(1)
Includes card-related products.
(2)
Commercial loans accounted for under the fair value option include U.S. commercialBank of America $4.7 billion and $2.5 billion and non-U.S. commercial of $3.1 billion and $1.1 billion at December 31, 2019 and 2018. For more information on the fair value option, see Note 22 – Fair Value Option to the Consolidated Financial Statements.66


Table 3331 presents net charge-offs and related ratios for our commercial loans and leases for 20192021 and 2018.2020.
Table 31Commercial Net Charge-offs and Related Ratios
Net Charge-offs
Net Charge-off Ratios (1)
(Dollars in millions)2021202020212020
Commercial and industrial:
U.S. commercial$(23)$718 (0.01)%0.23 %
Non-U.S. commercial35 155 0.04 0.15 
Total commercial and industrial12 873  0.21 
Commercial real estate34 270 0.06 0.43 
Commercial lease financing(1)59  0.32 
45 1,202 0.01 0.24 
U.S. small business commercial351 267 1.19 0.86 
Total commercial$396 $1,469 0.08 0.28 
         
Table 33Commercial Net Charge-offs and Related Ratios
       
  Net Charge-offs 
Net Charge-off Ratios (1)
(Dollars in millions)2019 2018 2019 2018
Commercial and industrial:       
U.S. commercial$256
 $215
 0.08% 0.07%
Non-U.S. commercial84
 68
 0.08
 0.07
Total commercial and industrial340
 283
 0.08
 0.07
Commercial real estate29
 1
 0.05
 
Commercial lease financing21
 (1) 0.10
 (0.01)
  390
 283
 0.08
 0.06
U.S. small business commercial272
 240
 1.83
 1.70
Total commercial$662
 $523
 0.13
 0.11
(1)(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.
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.

61Bank of America






Table 3432 presents commercial reservable criticized utilized exposure by loan type. Criticized exposure corresponds to the Special Mention, Substandard and Doubtful asset categories as defined by regulatory authorities. Total commercial reservable criticized utilized exposure decreased $16.3 billion during 2021, which was broad-based across industries. At December 31, 20192021 and 2018, 902020, 87 percent and 9179 percent of commercial reservable criticized utilized exposure was secured.
Table 32
Commercial Reservable Criticized Utilized Exposure (1, 2)
December 31
(Dollars in millions)20212020
Commercial and industrial:
U.S. commercial$11,327 3.20 %$21,388 6.83 %
Non-U.S. commercial2,582 2.17 5,051 5.03 
Total commercial and industrial13,909 2.94 26,439 6.40 
Commercial real estate7,572 11.72 10,213 16.42 
Commercial lease financing387 2.61 714 4.18 
21,868 3.96 37,366 7.59 
U.S. small business commercial513 2.67 1,300 3.56 
Total commercial reservable criticized utilized exposure$22,381 3.91 $38,666 7.31 
         
Table 34
Commercial Reservable Criticized Utilized Exposure (1, 2)
         
  December 31
(Dollars in millions)2019 2018
Commercial and industrial:
U.S. commercial$8,272
 2.46% $7,986
 2.43%
Non-U.S. commercial989
 0.89
 1,013
 0.97
Total commercial and industrial9,261
 2.07
 8,999
 2.08
Commercial real estate1,129
 1.75
 936
 1.50
Commercial lease financing329
 1.66
 366
 1.62
  10,719
 2.01
 10,301
 1.99
U.S. small business commercial733
 4.78
 760
 5.22
Total commercial reservable criticized utilized exposure (1)
$11,452
 2.09
 $11,061
 2.08
(1)Total commercial reservable criticized utilized exposure includes loans and leases of $21.2 billion and $36.6 billion and commercial letters of credit of $1.2 billion and $2.1 billion at December 31, 2021 and 2020.
(1)
(2)Percentages are calculated as commercial reservable criticized utilized exposure divided by total commercial reservable utilized exposure for each exposure category.
Total commercial reservable criticized utilized exposure includes loans and leases of $10.7 billion and $10.3 billion and commercial letters of credit of $715 million and $781 million at December 31, 2019 and 2018.
(2)
Percentages are calculated as commercial reservable criticized utilized exposure divided by total commercial reservable utilized exposure for each exposure category.
Commercial and Industrial
Commercial and industrial loans include U.S. commercial and non-U.S. commercial portfolios.
U.S. Commercial
At December 31, 2019, 702021, 62 percent of the U.S. commercial loan portfolio, excluding small business, was managed in Global Banking, 1622 percent in Global Markets, 1315 percent in GWIM (generally business-purpose loans(loans that provide financing for asset purchases, business investments and other liquidity needs for high net worth clients) and the remainder primarily in Consumer Banking. U.S. commercial loans increased $7.8$37.2 billion, or 13 percent, during 2019,2021 primarily driven by Global Markets and Global Banking. Reservable criticized utilized exposure decreased $10.1 billion, driven by decreases across linesa broad range of business.industries.
Non-U.S. Commercial
At December 31, 2019, 832021, 69 percent of the non-U.S. commercial loan portfolio was managed in Global Banking, and 1730 percent in Global Marketsand the remainder in GWIM. Non-U.S. commercial loans increased $6.2$22.8 billion, or 25 percent, during 2019,2021 primarily in Global BankingMarkets. Reservable criticized utilized exposure decreased $2.5 billion, which was broad-based across industries. For information on the non-U.S. commercial portfolio, see Non-U.S. Portfolio on page 66.71.


Commercial Real Estate
Commercial real estate primarily includes commercial loans secured by non-owner-occupied real estate and is dependent on the sale or lease of the real estate as the primary source of
repayment. Outstanding loans increased $1.8$2.6 billion, or threefour percent, during 20192021 to $62.7$63.0 billion due to new originations slightly outpacing paydowns. The portfolio remains diversified across property types and geographic regions. California represented the largest state concentration at 2421 percent and 23 percent of the commercial real estate portfolio at December 31, 20192021 and 2018.2020. The commercial real estate portfolio is predominantly managed in Global Banking and consists of loans made primarily to public and private developers, and commercial real estate firms.
During 2019,2021, we continued to see low default rates and solid credit qualityvarying degrees of improvement in bothcertain geographic regions and property types of 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 tofor management by independent special asset officers and the pursuit of loan restructurings or asset sales to achieve the best results for our customers and the Corporation.
Table 3533 presents outstanding commercial real estate loans by geographic region, based on the geographic location of the collateral, and by property type.

67Bank of America62


    
Table 35Outstanding Commercial Real Estate Loans
Table 33Table 33Outstanding Commercial Real Estate Loans
    
 December 31December 31
(Dollars in millions)(Dollars in millions)2019 2018(Dollars in millions)20212020
By Geographic Region By Geographic Region  
  
By Geographic Region   
NortheastNortheast$14,318 $11,628 
CaliforniaCalifornia$14,910
 $14,002
California13,145 14,028 
Northeast12,408
 10,895
SouthwestSouthwest8,408
 7,339
Southwest7,510 8,551 
SoutheastSoutheast5,937
 5,726
Southeast6,758 6,588 
FloridaFlorida3,984
 3,680
Florida4,367 4,294 
MidwestMidwest3,221 3,483 
IllinoisIllinois3,349
 2,989
Illinois2,878 2,594 
Midwest3,203
 3,772
MidsouthMidsouth2,468
 2,919
Midsouth2,289 2,370 
NorthwestNorthwest1,638
 2,178
Northwest1,709 1,634 
Non-U.S. Non-U.S. 3,724
 4,240
Non-U.S. 4,760 3,187 
Other (1)
2,660
 3,105
Other Other 2,054 2,007 
Total outstanding commercial real estate loansTotal outstanding commercial real estate loans$62,689
 $60,845
Total outstanding commercial real estate loans$63,009 $60,364 
By Property TypeBy Property Type 
  
By Property Type  
Non-residentialNon-residential   Non-residential
OfficeOffice$17,902
 $17,246
Office$18,309 $17,667 
Industrial / WarehouseIndustrial / Warehouse8,677
 5,379
Industrial / Warehouse10,749 8,330 
Shopping centers / Retail8,183
 8,798
Multi-family rentalMulti-family rental7,250
 7,762
Multi-family rental8,173 7,051 
Hotels / Motels6,982
 7,248
Shopping centers /RetailShopping centers /Retail6,502 7,931 
Hotel / MotelsHotel / Motels5,932 7,226 
UnsecuredUnsecured3,438
 2,956
Unsecured3,178 2,336 
Multi-useMulti-use1,788
 2,848
Multi-use1,835 1,460 
OtherOther6,958
 7,029
Other7,238 7,146 
Total non-residentialTotal non-residential61,178
 59,266
Total non-residential61,916 59,147 
ResidentialResidential1,511
 1,579
Residential1,093 1,217 
Total outstanding commercial real estate loansTotal outstanding commercial real estate loans$62,689
 $60,845
Total outstanding commercial real estate loans$63,009 $60,364 
(1)
Includes unsecured loans to real estate investment trusts and national home builders whose portfolios of properties span multiple geographic regions and properties in the states of Colorado, Utah, Hawaii, Wyoming and Montana.
U.S. Small Business Commercial
The U.S. small business commercial loan portfolio is comprised of small business card loans and small business loans primarily managed in Consumer Banking,. Credit and includes $4.7 billion and $22.7 billion of PPP loans outstanding at December 31, 2021 and 2020. The decline of $18.0 billion in PPP loans during 2021 was due to repayment of the loans by the SBA under the terms of the program. Excluding PPP, credit card-related products were 52 percent and 5150 percent of the U.S. small business commercial portfolio at both December 31, 20192021 and 2018. Of the U.S. small business commercial2020 and represented 95 percent of net charge-offs 94in 2021 compared to 91 percent and 95 percent were credit card-related products in 2019 and 2018.2020.

Nonperforming Commercial Loans, Leases and Foreclosed Properties Activity
Table 3634 presents the nonperforming commercial loans, leases and foreclosed properties activity during 20192021 and 2018.
2020. Nonperforming loans do not include loans accounted for under the fair value option. During 2019,2021, nonperforming commercial loans and leases increased $397decreased $649 million to $1.5$1.6 billion. At December 31, 2019, 942021, 88 percent of commercial nonperforming loans, leases and foreclosed properties were secured and 6454 percent were contractually current. Commercial nonperforming loans were carried at 8890 percent of their unpaid principal balance, before consideration of the allowance for loan and lease losses as the carrying value of these loans has been reduced to the estimated collateral value less costs to sell.
Table 34
Nonperforming Commercial Loans, Leases and Foreclosed Properties Activity (1, 2)
(Dollars in millions)20212020
Nonperforming loans and leases, January 1$2,227 $1,499 
Additions1,622 3,518 
Reductions: 
Paydowns(1,163)(1,002)
Sales(199)(350)
Returns to performing status (3)
(264)(172)
Charge-offs(254)(1,208)
Transfers to foreclosed properties (2)
Transfers to loans held-for-sale(391)(56)
Total net additions (reductions) to nonperforming loans and leases(649)728 
Total nonperforming loans and leases, December 311,578 2,227 
Foreclosed properties, December 3129 41 
Nonperforming commercial loans, leases and foreclosed properties, December 31$1,607 $2,268 
Nonperforming commercial loans and leases as a percentage of outstanding commercial loans and leases (4)
0.29 %0.45 %
Nonperforming commercial loans, leases and foreclosed properties as a percentage of outstanding commercial loans, leases and foreclosed properties (4)
0.30 0.46 
(1)Balances do not include nonperforming loans held-for-sale of $264 million and $359 million at December 31, 2021 and 2020.
(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 36
Nonperforming Commercial Loans, Leases and Foreclosed Properties Activity (1, 2)
     
(Dollars in millions)2019 2018
Nonperforming loans and leases, January 1$1,102
 $1,304
Additions2,048
 1,415
Reductions:   
Paydowns(648) (771)
Sales(215) (210)
Returns to performing status (3)
(120) (246)
Charge-offs(478) (361)
Transfers to foreclosed properties(9) (12)
Transfers to loans held-for-sale(181) (17)
Total net reductions to nonperforming loans and leases397
 (202)
Total nonperforming loans and leases, December 311,499
 1,102
Foreclosed properties, December 3156
 56
Nonperforming commercial loans, leases and foreclosed properties, December 31$1,555
 $1,158
Nonperforming commercial loans and leases as a percentage of outstanding commercial loans and leases (4)
0.29% 0.22%
Nonperforming commercial loans, leases and foreclosed properties as a percentage of outstanding commercial loans, leases and foreclosed properties (4)
0.30
 0.23
(1)
Balances do not include nonperforming loans held-for-sale of $239 million and $292 million at December 31, 2019 and 2018.
(2)
Includes U.S. small business commercial activity. Small business card loans are excluded as they are not classified as nonperforming.
(3)
Commercial loans and leases may be returned to performing status when all principal and interest is current and full repayment of the remaining contractual principal and interest is expected, or when the loan otherwise becomes well-secured and is in the process of collection. TDRs are generally classified as performing after a sustained period of demonstrated payment performance.
(4)
Outstanding commercial loans exclude loans accounted for under the fair value option.

63Bank of America68








Table 3735 presents our commercial TDRs by product type and performing status. U.S. small business commercial TDRs are comprised of renegotiated small business card loans and small business loans. The renegotiated small business card loans are
not classified as nonperforming as they are charged off no later than the end of the month in which the loan becomes 180 days past due. For more information on TDRs, see Note 5 – Outstanding Loans and Leases to the Consolidated Financial Statements.
            
Table 37Commercial Troubled Debt Restructurings
Table 35Table 35Commercial Troubled Debt Restructurings
  
 December 31, 2019 December 31, 2018December 31, 2021December 31, 2020
(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$617
 $999
 $1,616
 $306
 $1,092
 $1,398
U.S. commercial$359 $685 $1,044 $509 $850 $1,359 
Non-U.S. commercialNon-U.S. commercial41
 193
 234
 78
 162
 240
Non-U.S. commercial72 8 80 49 119 168 
Total commercial and industrialTotal commercial and industrial658
 1,192
 1,850
 384
 1,254
 1,638
Total commercial and industrial431 693 1,124 558 969 1,527 
Commercial real estateCommercial real estate212
 14
 226
 114
 6
 120
Commercial real estate244 437 681 137 — 137 
Commercial lease financingCommercial lease financing18
 31
 49
 3
 68
 71
Commercial lease financing50 7 57 42 44 
888
 1,237
 2,125
 501
 1,328
 1,829
725 1,137 1,862 737 971 1,708 
U.S. small business commercialU.S. small business commercial
 27
��27
 3
 18
 21
U.S. small business commercial 38 38 — 29 29 
Total commercial troubled debt restructuringsTotal commercial troubled debt restructurings$888
 $1,264
 $2,152
 $504
 $1,346
 $1,850
Total commercial troubled debt restructurings$725 $1,175 $1,900 $737 $1,000 $1,737 
Industry Concentrations
Table 3836 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.industry. Our commercial credit exposure is diversified across a broad range of industries. Total commercial committed exposure increased $52.3$89.6 billion, or fivenine percent, during 20192021 to $1.1 trillion. The increase in commercial committed exposure was concentrated in the Real estate, UtilitiesAsset managers and funds, Finance companies and Utilities industry sectors. Increases were partially offset by decreased exposure to the Pharmaceuticals and biotechnology, Technology hardware and equipment, and Government and public education and Automobiles and components industry sectors.
Industry limits are used internally to manage industry concentrations and are based on committed exposure that is allocateddetermined on an industry-by-industry basis. A risk management framework is in place to set and approve industry limits as well
as to provide ongoing monitoring. The MRC oversees industry limit governance.
Asset managers and funds, our largest industry concentration with committed exposure of $110.0$136.9 billion, increased $2.1$36.6 billion, or two37 percent, during 2019.2021, which was primarily driven by secured investment grade exposures.

Real estate, our second largest industry concentration with committed exposure of $96.3$96.2 billion, increased $9.8$4.5 billion, or 11five percent, during 2019. This growth occurred primarily in the category of industrial and warehouse buildings, partially offset by declines in REITs.
Capital goods, our third largest industry concentration with committed exposure of $80.9 billion, increased $5.8 billion, or eight percent, during 2019 with the growth largely occurring in the trading companies and distributors industry categories, partially offset by a decrease in industrial conglomerates.2021. For more information on the commercial real estate and related portfolios, see Commercial Portfolio Credit Risk Management – Commercial Real Estate on page 62.67.
Finance companies, our third largest industry concentration with committed exposure of $86.0 billion, increased $16.0 billion, or 23 percent during 2021, with the growth largely occurring in Consumer Finance, Thrifts and Mortgage Finance and Diversified Financials.
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 that are experiencing or could experience a more significant impact to their financial condition.

69Bank of America64


        
Table 38
Commercial Credit Exposure by Industry (1)
Table 36Table 36
Commercial Credit Exposure by Industry (1)
        
 
Commercial
Utilized
 
Total Commercial
Committed (2)
Commercial
Utilized
Total Commercial
Committed (2)
 December 31December 31
(Dollars in millions)(Dollars in millions)2019 2018 2019 2018(Dollars in millions)2021202020212020
Asset managers and funds$71,289
 $71,756
 $109,972
 $107,888
Asset managers & fundsAsset managers & funds$89,786 $67,360 $136,914 $100,296 
Real estate (3)
Real estate (3)
70,341
 65,328
 96,349
 86,514
Real estate (3)
69,384 68,967 96,202 91,730 
Finance companiesFinance companies59,327 46,948 86,009 70,004 
Capital goodsCapital goods41,060
 39,192
 80,871
 75,080
Capital goods42,784 39,807 84,293 80,815 
Finance companies40,171
 36,662
 63,940
 56,659
Healthcare equipment and servicesHealthcare equipment and services34,353
 35,763
 55,918
 56,489
Healthcare equipment and services32,003 33,488 58,195 57,540 
Government and public education41,889
 43,675
 53,566
 54,749
MaterialsMaterials26,663
 27,347
 52,128
 51,865
Materials25,133 24,516 53,652 50,757 
RetailingRetailing24,514 23,700 50,816 48,306 
Government & public educationGovernment & public education37,597 41,669 50,066 56,212 
Consumer servicesConsumer services28,434
 25,702
 49,071
 43,298
Consumer services28,172 31,993 48,052 47,997 
Retailing25,868
 25,333
 48,317
 47,507
Food, beverage and tobaccoFood, beverage and tobacco24,163
 23,586
 45,956
 42,745
Food, beverage and tobacco21,584 22,755 45,419 44,417 
Commercial services and suppliesCommercial services and supplies23,102
 22,623
 38,943
 39,349
Commercial services and supplies22,390 21,107 42,451 38,092 
Individuals and trustsIndividuals and trusts29,752 24,727 39,869 34,036 
UtilitiesUtilities17,082 12,387 36,855 29,234 
EnergyEnergy16,407
 13,727
 36,327
 32,279
Energy14,217 13,930 34,136 32,974 
Utilities12,383
 12,035
 36,060
 27,623
TransportationTransportation23,448
 22,814
 33,027
 31,523
Transportation21,079 23,126 32,015 33,082 
Global commercial banks26,492
 26,583
 28,670
 28,627
Individuals and trusts18,926
 18,643
 27,815
 25,019
Software and servicesSoftware and services10,663 10,853 27,643 22,524 
Technology hardware and equipmentTechnology hardware and equipment10,645
 13,014
 24,071
 26,228
Technology hardware and equipment10,159 9,935 26,910 24,196 
MediaMedia12,429
 12,132
 23,629
 24,502
Media12,495 12,632 26,318 24,120 
Global commercial banksGlobal commercial banks20,062 20,544 21,390 22,595 
Telecommunication servicesTelecommunication services10,056 9,411 21,270 15,605 
Consumer durables and apparelConsumer durables and apparel9,740 9,232 21,226 20,223 
Pharmaceuticals and biotechnologyPharmaceuticals and biotechnology5,608 4,830 19,439 15,901 
Automobiles and componentsAutomobiles and components9,236 10,792 17,052 20,575 
Vehicle dealersVehicle dealers18,013
 17,603
 21,435
 20,446
Vehicle dealers11,030 15,028 15,678 18,696 
Consumer durables and apparel10,193
 9,904
 21,245
 20,199
Software and services10,432
 8,809
 20,556
 19,172
Pharmaceuticals and biotechnology5,962
 7,430
 20,203
 23,634
Telecommunication services9,144
 8,686
 16,103
 14,166
InsuranceInsurance6,669
 8,674
 15,214
 15,807
Insurance5,743 5,772 14,323 13,277 
Automobiles and components7,345
 7,131
 14,910
 13,893
Food and staples retailingFood and staples retailing6,902 5,209 12,226 11,795 
Financial markets infrastructure (clearinghouses)Financial markets infrastructure (clearinghouses)9,351
 8,317
 11,851
 10,042
Financial markets infrastructure (clearinghouses)3,876 4,939 6,076 8,648 
Food and staples retailing6,290
 4,787
 10,392
 9,093
Religious and social organizationsReligious and social organizations3,844
 3,757
 5,756
 5,620
Religious and social organizations3,154 4,646 5,394 6,597 
Total commercial credit exposure by industryTotal commercial credit exposure by industry$635,306
 $621,013
 $1,062,295
 $1,010,016
Total commercial credit exposure by industry$653,528 $620,303 $1,129,889 $1,040,244 
Net credit default protection purchased on total commitments (4)
 
  
 $(3,349) $(2,663)
(1)
(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 other financial institutions. The distributed amounts were $10.7 billion and $10.5 billion at December 31, 2021 and 2020.
(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.
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 other financial institutions. The distributed amounts were $10.6 billion and $10.7 billion at December 31, 2019 and 2018.
(3)
Industries are viewed from a variety of perspectives to best isolate the perceived risks. For purposes of this table, the real estate industry is defined based on the primary business activity of the borrowers or counterparties using operating cash flows and primary source of repayment as key factors.
(4)
Represents net notional credit protection purchased to hedge funded and unfunded exposures for which we elected the fair value option, as well as certain other credit exposures. For more information, see Commercial Portfolio Credit Risk Management – Risk Mitigation.
Risk Mitigation
We purchase credit protection to cover the funded portion as well as the unfunded portion of certain credit exposures. To lower the cost of obtaining our desired credit protection levels, we may add credit exposure within an industry, borrower or counterparty group by selling protection.
At December 31, 20192021 and 2018,2020, net notional credit default protection purchased in our credit derivatives portfolio to hedge ourfundedand unfundedexposures for whichwe elected the fair value option, as well as certain other credit exposures, was $3.3$2.6 billion and $2.7$4.2 billion. We recorded net losses of $145$91 million in 20192021 compared to net losses of $2$240 million in 2018 on these positions.2020. The gains and losses on these instruments were offset by gains and losses on the related exposures. The Value-at-Risk
(VaR) results for these exposures are included in the fair value
option portfolio information in Table 45.43. For more information, see Trading Risk Management on page 72.76.
Tables 3937 and 4038 present the maturity profiles and the credit exposure debt ratings of the net credit default protection portfolio at December 31, 20192021 and 2018.2020.
    
Table 39Net Credit Default Protection by Maturity
Table 37Table 37Net Credit Default Protection by Maturity
    
 December 31December 31
 2019 201820212020
Less than or equal to one yearLess than or equal to one year54% 20%Less than or equal to one year34 %65 %
Greater than one year and less than or equal to five yearsGreater than one year and less than or equal to five years45
 78
Greater than one year and less than or equal to five years62 34 
Greater than five yearsGreater than five years1
 2
Greater than five years4 
Total net credit default protectionTotal net credit default protection100% 100%Total net credit default protection100 %100 %
Table 38Net 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)20212020
Ratings (2, 3)
    
A$(350)13.4 %$(250)6.0 %
BBB(710)27.1 (1,856)44.5 
BB(809)30.9 (1,363)32.7 
B(659)25.2 (465)11.2 
CCC and below(35)1.3 (182)4.4 
NR (4)
(55)2.1 (54)1.2 
Total net credit
default protection
$(2,618)100.0 %$(4,170)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.

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Table 40Net Credit Default Protection by Credit Exposure Debt Rating
         
  
Net
Notional
(1)
 Percent of
Total
 
Net
Notional
(1)
 Percent of
Total
  December 31
(Dollars in millions)2019 2018
Ratings (2, 3)
 
  
  
  
A$(697) 20.8% $(700) 26.3%
BBB(1,089) 32.5
 (501) 18.8
BB(766) 22.9
 (804) 30.2
B(373) 11.1
 (422) 15.8
CCC and below(119) 3.6
 (205) 7.7
NR (4)
(305) 9.1
 (31) 1.2
Total net credit
default protection
$(3,349) 100.0% $(2,663) 100.0%
(1)
Represents net credit default protection purchased.
(2)
Ratings are refreshed on a quarterly basis.
(3)
Ratings of BBB- or higher are considered to meet the definition of investment grade.
(4)
NR is comprised of index positions held and any names that have not been rated.
In addition to our net notional credit default protection purchased to cover the funded and unfunded portion of certain credit exposures, credit derivatives are used for market-making activities for clients and establishing positions intended to profit from directional or relative value changes. We execute the majority of our credit derivative trades in the OTC market with large, multinational financial institutions, including broker-dealers and, to a lesser degree, with a variety of other investors. Because these transactions are executed in the OTC market, we are subject to settlement risk. We are also subject to credit risk in the event that these counterparties fail to perform under the terms of these contracts. In order to properly reflect counterparty credit risk, we record counterparty credit risk valuation adjustments on certain derivative assets, including our
purchased credit default protection.
In most cases, credit derivative transactions are executed on a daily margin basis. Therefore, events such as a credit downgrade, depending on the ultimate rating level, or a breach of credit covenants would typically require an increase in the amount of collateral required by the counterparty, where applicable, and/or
allow us to take additional protective measures such as early termination of all trades. For more information on credit derivatives and counterparty credit risk valuation adjustments, see Note 3 – Derivatives to the Consolidated Financial Statements.Statements.
Non-U.S. Portfolio
Our non-U.S. credit and trading portfolios are subject to country risk. We define country risk as the risk of loss from unfavorable economic and political conditions, currency fluctuations, social instability and changes in government policies. A risk management framework is in place to measure, monitor and
manage non-U.S. risk and exposures. In addition to the direct risk of doing business in a country, we also are exposed to indirect country risks (e.g., related to the collateral received on secured financing transactions or related to client clearing activities). These indirect exposures are managed in the normal course of business through credit, market and operational risk governance rather than through country risk governance.
Table 4139 presents our 20 largest non-U.S. country exposures at December 31, 2019.2021. These exposures accounted for 8889 percent and 8990 percent of our total non-U.S. exposure at December 31, 20192021 and 2018.2020. Net country exposure for these 20 countries increased $8.5$10.5 billion in 2019,2021 primarily driven by increased sovereignincreases in Australia, Canada and corporate exposure across multiple countries.France, partially offset by reductions in Germany and the United Kingdom.
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 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.

Table 39Top 20 Non-U.S. Countries Exposure
(Dollars in millions)Funded Loans
 and Loan
 Equivalents
Unfunded
 Loan
 Commitments
Net
 Counterparty
 Exposure
Securities/
Other
Investments
Country Exposure at December 31
2021
Hedges and Credit Default ProtectionNet Country Exposure at December 31
2021
Increase (Decrease) from December 31
2020
United Kingdom$32,062 $15,858 $5,932 $2,399 $56,251 $(1,282)$54,969 $(4,503)
Germany21,397 9,790 1,794 1,807 34,788 (963)33,825 (11,078)
Canada9,138 12,783 1,441 3,551 26,913 (602)26,311 5,177 
France12,393 8,234 1,391 3,710 25,728 (821)24,907 4,116 
Australia9,194 9,078 434 2,812 21,518 (214)21,304 8,217 
Japan14,812 1,528 1,308 371 18,019 (757)17,262 (234)
Brazil6,814 1,382 526 4,227 12,949 (199)12,750 2,457 
China9,941 689 894 1,370 12,894 (312)12,582 (838)
Singapore3,914 709 249 5,850 10,722 (57)10,665 1,383 
Netherlands3,839 4,780 452 950 10,021 (425)9,596 (88)
India6,485 388 470 1,454 8,797 (166)8,631 820 
Switzerland5,072 3,125 277 338 8,812 (237)8,575 1,680 
South Korea5,800 771 545 1,191 8,307 (155)8,152 (399)
Hong Kong5,523 315 338 1,167 7,343 (16)7,327 790 
Mexico4,333 1,577 136 629 j6,675 (213)6,462 175 
Spain2,482 2,126 473 1,198 6,279 (359)5,920 1,104 
Ireland4,037 1,019 136 376 5,568 (29)5,539 1,374 
Italy2,843 1,098 348 1,484 5,773 (569)5,204 (488)
Belgium2,548 1,516 462 687 5,213 (182)5,031 64 
United Arab Emirates2,942 329 36 234 3,541 (47)3,494 807 
Total top 20 non-U.S. countries exposure$165,569 $77,095 $17,642 $35,805 $296,111 $(7,605)$288,506 $10,536 

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Table 41Top 20 Non-U.S. Countries Exposure
                 
(Dollars in millions)Funded Loans and Loan Equivalents Unfunded Loan Commitments Net Counterparty Exposure 
Securities/
Other
Investments
 Country Exposure at December 31
2019
 Hedges and Credit Default Protection Net Country Exposure at December 31
2019
 Increase (Decrease) from December 31
2018
United Kingdom$29,156
 $17,341
 $7,800
 $3,545
 $57,842
 $(1,998) $55,844
 $990
Germany21,920
 7,408
 1,828
 1,967
 33,123
 (2,295) 30,828
 2,171
Canada7,967
 8,255
 1,690
 2,879
 20,791
 (669) 20,122
 607
France7,243
 9,208
 876
 969
 18,296
 (2,041) 16,255
 3,604
China13,304
 497
 1,085
 949
 15,835
 (248) 15,587
 946
India7,817
 364
 398
 3,660
 12,239
 (222) 12,017
 905
Brazil7,393
 716
 218
 3,683
 12,010
 (238) 11,772
 1,523
Australia6,100
 3,583
 415
 1,443
 11,541
 (439) 11,102
 1,172
Japan8,450
 896
 1,002
 1,589
 11,937
 (1,405) 10,532
 (9,491)
Netherlands6,322
 3,585
 330
 876
 11,113
 (786) 10,327
 (1,250)
South Korea5,981
 758
 386
 1,762
 8,887
 (182) 8,705
 (465)
Singapore3,749
 435
 172
 3,528
 7,884
 (58) 7,826
 2,309
Mexico4,190
 1,733
 224
 1,814
 7,961
 (150) 7,811
 1,575
Switzerland4,387
 2,947
 213
 325
 7,872
 (487) 7,385
 (379)
Hong Kong5,106
 353
 434
 1,194
 7,087
 (31) 7,056
 (180)
Belgium5,077
 1,259
 526
 159
 7,021
 (514) 6,507
 929
Italy2,353
 2,303
 510
 1,386
 6,552
 (1,175) 5,377
 2,296
Spain3,153
 1,073
 258
 867
 5,351
 (629) 4,722
 72
United Arab Emirates3,267
 229
 119
 10
 3,625
 (38) 3,587
 (62)
Ireland2,142
 979
 76
 201
 3,398
 (31) 3,367
 1,206
Total top 20 non-U.S. countries exposure$155,077
 $63,922
 $18,560
 $32,806
 $270,365
 $(13,636) $256,729
 $8,478
A number of economic conditions and geopolitical events have given rise to risk aversion in certain emerging markets. Additionally, in light of ongoing trade tensions, we continue to closely monitor our exposures to tariff-sensitive regions and industries, particularly to countries that account for a large percentage of U.S. trade, such as China.
Our largest emerging marketnon-U.S. country exposure at December 31, 20192021 was China,the United Kingdom with net exposure of $15.6 billion, concentrated in large state-owned companies, subsidiaries of multinational corporations and commercial banks.
The economic performance in the EU remains uncertain, including as a result of the uncertainty surrounding the terms of a potential trade agreement and other terms associated with the future relationship between the U.K. and the EU, which could weigh unevenly on the economic performance of EU countries generally, and even more heavily on that of the U.K. For more information, see Item 1A. Risk Factors – Geopolitical on page 10and Executive Summary – Recent Developments – U.K. Exit from the EU on page 23. Our largest EU country exposure at December 31, 2019 was
the U.K. with net exposure of $55.8$55.0 billion, which represents a $990 million increase$4.5 billion decrease from December 31, 2018.2020. Our second largest EUnon-U.S. country exposure was Germany with net exposure of $30.8$33.8 billion as ofat December 31, 2019, which represents2021, a $2.2$11.1 billion increasedecrease from December 31, 2018.2020. The increasedecrease in Germanyboth of these countries was primarily driven by a reduction in deposits with central banks.
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 increase in sovereign exposure.attempt to contain the spread and impact of the virus, have affected and will likely continue to adversely affect economic activity.

The impact of COVID-19 could have an adverse impact on the global economy for a prolonged period of time. For more information on how the pandemic may affect our operations, see Executive Summary – Recent Developments – COVID-19 Pandemic on page 27 and Part 1. Item 1A. Risk Factors on page 7.
Loan and Lease Contractual Maturities
Table 42 presents countries that had40 disaggregates total cross-border exposure, includingoutstanding loans and leases by remaining contractual maturities and interest rates. The amounts provided do not reflect prepayment assumptions or hedging activities related to the notional amount of cash loaned under secured financing agreements, exceeding one percentloan portfolio. For information on the asset sensitivity of our total assets at December 31, 2019. Local exposure, defined as exposure booked in local offices of a respective country with clients inbanking book balance sheet, see Interest Rate Risk Management for the same country, is excluded. At December 31, 2019, the U.K. and France were the only countries where their respective total cross-border exposures exceeded one percent of our total assets. At December 31, 2019, Germany had total cross-border exposure of $19.4 billion representing 0.80 percent of our total assets. No other countries had total cross-border exposure that exceeded 0.75 percent of our total assets at December 31, 2019.Banking Book on page 79.
Table 40
Loan and Lease Contractual Maturities (1)
 December 31, 2021
(Dollars in millions)Due in One
Year or Less
Due After One Year Through Five YearsDue After Five Years Through 15 YearsDue After 15 YearsTotal
Residential mortgage$175 $702 $48,614 $172,751 $222,242 
Home equity1,596 92 6,159 20,427 28,274 
Credit card81,438 — — — 81,438 
Direct/Indirect consumer54,080 30,940 14,535 4,005 103,560 
Other consumer190 — — — 190 
Total consumer loans$137,479 $31,734 $69,308 $197,183 $435,704 
U.S. commercial$93,480 $195,157 $39,370 $2,505 $330,512 
Non-U.S. commercial42,570 50,514 21,754 1,053 115,891 
Commercial real estate16,322 42,363 3,386 938 63,009 
Commercial lease financing1,349 8,676 3,865 935 14,825 
U.S. small business commercial9,428 3,895 5,656 204 19,183 
Total commercial loans$163,149 $300,605 $74,031 $5,635 $543,420 
Total loans and leases$300,628 $332,339 $143,339 $202,818 $979,124 
Amount due in one year or less at:Amount due after one year at:
(Dollars in millions)Variable Interest RatesFixed Interest RatesVariable Interest RatesFixed Interest RatesTotal
Residential mortgage$18 $157 $80,967 $141,100 $222,242 
Home equity98 1,498 25,982 696 28,274 
Credit card77,151 4,287 — — 81,438 
Direct/Indirect consumer48,424 5,656 2,551 46,929 103,560 
Other consumer— 190 — — 190 
Total consumer loans$125,691 $11,788 $109,500 $188,725 $435,704 
U.S. commercial$84,398 $9,082 $190,978 $46,054 $330,512 
Non-U.S. commercial39,472 3,098 70,817 2,504 115,891 
Commercial real estate15,673 649 44,626 2,061 63,009 
Commercial lease financing187 1,162 1,560 11,916 14,825 
U.S. small business commercial5,150 4,278 98 9,657 19,183 
Total commercial loans$144,880 $18,269 $308,079 $72,192 $543,420 
Total loans and leases$270,571 $30,057 $417,579 $260,917 $979,124 
             
Table 42Total Cross-border Exposure Exceeding One Percent of Total Assets
             
(Dollars in millions)December 31 Public Sector Banks Private Sector Cross-border
Exposure
 Exposure as a
Percent of
Total Assets
United Kingdom2019 $1,859
 $3,580
 $93,232
 $98,671
 4.05%
 2018 1,505
 3,458
 46,191
 51,154
 2.17
 2017 923
 2,984
 47,205
 51,112
 2.24
France2019 736
 2,473
 23,172
 26,381
 1.08
 2018 633
 2,385
 29,847
 32,865
 1.40
  2017 2,964
 1,521
 27,903
 32,388
 1.42

(1)Includes loans accounted for under the fair value option.
67Bank of America72







Provision for Credit Losses
The provision for credit losses increased $308 million to $3.6 billion in 2019 compared to 2018. The provision for credit losses was $58 million lower than net charge-offs for 2019, resulting in a decrease in the allowance for credit losses. This compared to a decrease of $481 million in the allowance for credit losses in 2018. Net charge-offs in 2019 were $3.6 billion compared to $3.8 billion in 2018.
The provision for credit losses for the consumer portfolio decreased $117 million to $2.8 billion in 2019 compared to 2018. The decrease was primarily driven by consumer real estate loan sales.
The provision for credit losses for the commercial portfolio, including unfunded lending commitments, increased $425 million to $758 million in 2019 compared to 2018. The increase was due in part to energy reserve releases in the prior-year periods.
Assuming a stable economic environment in 2020 compared to the end of 2019, we expect net charge-offs of approximately $1 billion per quarter in 2020. In view of the newly adopted accounting standard on the measurement of the allowance for credit losses, we expect the provision for credit losses to be modestly higher than net charge-offs in 2020, assuming no change in the current economic outlook and estimates of loan growth, including product mix. For more information regarding the new accounting standard, see Note 1 – Summary of Significant Accounting Principles to the Consolidated Financial Statements.
Allowance for Credit Losses
Allowance for Loan and Lease Losses
The allowance for loancredit losses decreased $6.8 billion from December 31, 2020 to $13.8 billion at December 31, 2021, which included a $3.8 billion reserve decrease related to the commercial portfolio and lease losses is comprised of two components.a $3.1 billion reserve decrease related
to the consumer portfolio. 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 representeddecreases were primarily driven by improvements in the loss forecast models. We evaluate the adequacymacroeconomic outlook and credit quality.
Table 41 presents an allocation of the allowance for loan and leasecredit losses based on the total of these two components, each of which is described in more detail below. The allowance for loan and lease losses excludes loans held-for-sale (LHFS) and loans accounted for under the fair value option as the fair value reflects a credit risk component.
The first component of the allowance for loan and lease losses covers both nonperforming commercial loans and all TDRs within the consumer and commercial portfolios. These loans are subject to impairment measurement based on the present value of projected future cash flows discounted at the loan’s original effective interest rate, or in certain circumstances, impairment may also be based upon the collateral value or the loan’s observable market price if available. Impairment measurement for the renegotiated consumer credit card and small business credit card TDR portfolios is based on the present value of projected cash flows discounted using the average portfolio contractual interest rate, excluding promotionally priced loans, in effect prior to restructuring. For purposes of computing this specific loss component of the allowance, larger impaired loans are evaluated individually and smaller impaired loans are evaluated as a pool using historical experience for the respective product types and risk ratings of the loans.
The second component of the allowance for loan and lease losses covers the remaining consumer and commercial loans and leases that have incurred losses that are not yet individually identifiable. The allowance for consumer (including credit card and other consumer loans) and certain homogeneous commercial loan and lease products is based on aggregated portfolio evaluations, which include both quantitative and qualitative components,
generally by product type. Loss forecast models are utilized that consider a variety of factors including, but not limited to, historical loss experience, estimated defaults or foreclosures based on portfolio trends, delinquencies, economic trends, credit scores and the amount of loss in the event of default. Our consumer real estate loss forecast model estimates the portion of loans that will default based on individual loan attributes, the most significant of which are refreshed LTV or combined loan-to-value (CLTV), and borrower credit score as well as vintage and geography, all of which are further broken down into current delinquency status. Additionally, we incorporate the delinquency status of underlying first-lien loans on our junior-lien home equity portfolio in our allowance process. Incorporating refreshed LTV and CLTV into our probability of default allows us to factor the impact of changes in home prices into our allowance for loan and lease losses. These loss forecast models are updated on a quarterly basis to incorporate information reflecting the current economic environment. As of December 31, 2019, the loss forecast process resulted in reductions in the allowance related to the residential mortgage and home equity portfolios compared to December 31, 2018.
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 and obligor concentrations within each portfolio and any other pertinent information. The statistical models for commercial loans are generally updated annually and utilize our historical database of actual defaults and other data, including external default data. The loan risk ratings and composition of the commercial portfolios used to calculate the allowance are updated quarterly to incorporate the most recent data reflecting the current economic environment. For risk-rated commercial loans, we estimate the probability of default and the loss given default (LGD) based on our historical experience of defaults and credit losses. Factors considered when assessing the internal risk rating include the value of the underlying collateral, if applicable, the industry in which the obligor operates, the obligor’s liquidity and other financial indicators, and other quantitative and qualitative factors relevant to the obligor’s credit risk. As of December 31, 2019, the allowance for the commercial real estate portfolio increased compared to December 31, 2018.
Also included within the second component of the allowance for loan and lease losses are reserves to cover losses that are incurred but, in our assessment, may not be adequately represented in the historical loss data used in the loss forecast models. For example, factors that we consider include, among others, changes in lending policies and procedures, changes in economic and business conditions, changes in the nature and size of the portfolio, changes in portfolio concentrations, changes in the volume and severity of past due loans and nonaccrual loans, the effect of external factors such as competition, and legal and regulatory requirements. Further, we consider the inherent uncertainty in mathematical models that are built upon historical data.
We monitor differences between estimated and actual incurred loan and lease losses. This monitoring process includes periodic assessments by senior management of loan and lease portfolios and the models used to estimate incurred losses in those portfolios.
The allowance for loan and lease losses for the consumer portfolio, as presented in Table 43, was $4.5 billion at December 31, 2019, a decrease of $260 million from December 31, 2018. The decrease was primarily in the consumer real estate portfolio, partially offset by an increase in the credit card portfolio. The2021and 2020.

Table 41Allocation 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)
(Dollars in millions)December 31, 2021December 31, 2020
Allowance for loan and lease losses      
Residential mortgage$351 2.83 %0.16 %$459 2.44 %0.21 %
Home equity206 1.66 0.74 399 2.12 1.16 
Credit card5,907 47.70 7.25 8,420 44.79 10.70 
Direct/Indirect consumer523 4.22 0.51 752 4.00 0.82 
Other consumer46 0.37 n/m41 0.22 n/m
Total consumer7,033 56.78 1.62 10,071 53.57 2.35 
U.S. commercial (2)
3,019 24.37 0.87 5,043 26.82 1.55 
Non-U.S. commercial975 7.87 0.86 1,241 6.60 1.37 
Commercial real estate1,292 10.43 2.05 2,285 12.15 3.79 
Commercial lease financing68 0.55 0.46 162 0.86 0.95 
Total commercial5,354 43.22 1.00 8,731 46.43 1.77 
Allowance for loan and lease losses12,387 100.00 %1.28 18,802 100.00 %2.04 
Reserve for unfunded lending commitments1,456 1,878  
Allowance for credit losses$13,843 $20,680 
Bank of America 68


reduction in the allowance for the consumer real estate portfolio was driven by improved credit quality, a decrease in loan balances in our non-core portfolio, proactive credit risk management initiatives and high credit quality originations. The improved credit quality was impacted by continuing improvements in the U.S. economy and strong labor markets evidenced by low levels of unemployment and increases in home prices. Nonperforming consumer loans decreased $1.8 billion during 2019(1)Ratios are calculated as loan sales, returns to performing status and paydowns continued to outpace additions. The increase in allowance for the credit card portfolio was primarily driven by continued portfolio seasoning.
The allowance for loan and lease losses for the commercial portfolio, as presented in Table 43, was $4.9 billion at December 31, 2019, an increase of $75 million from December 31, 2018. Commercial reservable criticized utilized exposure increased to $11.5 billion at December 31, 2019 from $11.1 billion (to 2.09 percent from 2.08 percent of total commercial reservable utilized exposure) at December 31, 2018, and nonperforming commercial loans increased to $1.5 billion at December 31, 2019 from $1.1 billion (to 0.29 percent from 0.22 percent of outstanding commercial loans excluding loans accounted for under the fair value option) at December 31, 2018 with the increases spread across multiple industries. See Tables 32, 33 and 34 for more details on key commercial credit statistics.
The allowance for loan and lease losses as a percentage of total loans and leases outstanding was 0.97 percentexcluding loans accounted for under the fair value option.
(2)Includes allowance for loan and lease losses for U.S. small business commercial loans of $1.2 billion and $1.5 billion at December 31, 20192021 and 2020.
n/m = not meaningful
Net charge-offs for 2021 were $2.2 billion compared to 1.02 percent at December 31, 2018.$4.1 billion in 2020 driven by decreases across most products. The provision for credit losses decreased $15.9 billion to a $4.6 billion benefit during 2021 compared to 2020. The allowance for credit losses had a reserve release of $6.8 billion for 2021, primarily driven by improvements in the macroeconomic outlook and credit quality. The provision for credit losses for the consumer portfolio, including unfunded lending commitments, decreased $6.1 billion to a benefit of $1.2 billion during 2021 compared to 2020. The provision for credit losses for the
On January 1, 2020, the Corporation adopted the new accounting standard that requires the measurement
commercial portfolio, including unfunded lending commitments, decreased $9.8 billion to a $3.4 billion benefit for 2021 compared to 2020.
Table 42 presents a rollforward of the allowance for credit losses, to be basedincluding certain loan and allowance ratios for 2021 and 2020. For more information on management’s best estimate of lifetime expectedthe Corporation’s credit losses inherent in the
Corporation’s relevant financial assets. Upon adoption of the standard on January 1, 2020, the Corporation recorded a $3.3 billion, or 32 percent, increaseloss accounting policies and activity related to the allowance for credit losses. After adjusting for deferred taxes and other adoption effects, a $2.4 billion decrease was recorded in retained earnings through a cumulative-effect adjustment. For more information regarding this new accounting standard,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.
Reserve
73 Bank of America


Table 42Allowance for Credit Losses
(Dollars in millions)20212020
Allowance for loan and lease losses, January 1$18,802 $12,358 
Loans and leases charged off
Residential mortgage(34)(40)
Home equity(44)(58)
Credit card(2,411)(2,967)
Direct/Indirect consumer(297)(372)
Other consumer(292)(307)
Total consumer charge-offs(3,078)(3,744)
U.S. commercial (1)
(626)(1,163)
Non-U.S. commercial(47)(168)
Commercial real estate(46)(275)
Commercial lease financing (69)
Total commercial charge-offs(719)(1,675)
Total loans and leases charged off(3,797)(5,419)
Recoveries of loans and leases previously charged off
Residential mortgage62 70 
Home equity163 131 
Credit card688 618 
Direct/Indirect consumer296 250 
Other consumer22 23 
Total consumer recoveries1,231 1,092 
U.S. commercial (2)
298 178 
Non-U.S. commercial12 13 
Commercial real estate12 
Commercial lease financing1 10 
Total commercial recoveries323 206 
Total recoveries of loans and leases previously charged off1,554 1,298 
Net charge-offs(2,243)(4,121)
Provision for loan and lease losses(4,173)10,565 
Other1 — 
Allowance for loan and lease losses, December 3112,387 18,802 
Reserve for unfunded lending commitments, January 11,878 1,123 
Provision for unfunded lending commitments(421)755 
Other(1)— 
Reserve for unfunded lending commitments, December 311,456 1,878 
Allowance for credit losses, December 31$13,843 $20,680 
Loan and allowance ratios (3) :
Loans and leases outstanding at December 31$971,305 $921,180 
Allowance for loan and lease losses as a percentage of total loans and leases outstanding at December 311.28 %2.04 %
Consumer allowance for loan and lease losses as a percentage of total consumer loans and leases outstanding at December 311.62 2.35 
Commercial allowance for loan and lease losses as a percentage of total commercial loans and leases outstanding at December 311.00 1.77 
Average loans and leases outstanding$913,354 $974,281 
Annualized net charge-offs as a percentage of average loans and leases outstanding0.25 %0.42 %
Allowance for loan and lease losses as a percentage of total nonperforming loans and leases at December 31271 380 
Ratio of the allowance for loan and lease losses at December 31 to net charge-offs5.52 4.56 
Amounts included in allowance for loan and lease losses for loans and leases that are excluded from nonperforming loans and leases at December 31 (4)
$7,027 $9,854 
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 (4)
117 %181 %
(1)Includes U.S. small business commercial charge-offs of $425 million in 2021 compared to $321 million in 2020.
(2)Includes U.S. small business commercial recoveries of $74 million for Unfunded Lending Commitments2021 compared to $54 million in 2020.
In addition to the(3)Ratios are calculated as allowance for loan and lease losses we also estimate probable losses related to unfunded lending commitments such as lettersa percentage of credit, financial guarantees, unfunded bankers’ acceptancesloans and binding loan commitments,leases outstanding excluding commitmentsloans accounted for under the fair value option. Unfunded lending commitments are subject to the same assessment as funded loans, including estimates of probability of default and LGD. Due to the nature of unfunded commitments, the estimate of probable losses must also consider utilization. To estimate the portion of these undrawn commitments that is likely to be drawn by a borrower at the time of estimated default, analyses of our historical experience are applied to the unfunded commitments to estimate the funded exposure at default (EAD). The expected loss for unfunded lending commitments is the product of the probability of default, the LGD and the EAD, adjusted for any qualitative factors including economic uncertainty and inherent imprecision in models.
The reserve for unfunded lending commitments was $813 million at December 31, 2019 compared to $797 million at December 31, 2018.
             
Table 43Allocation 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, 2019 December 31, 2018
Allowance for loan and lease losses 
  
  
  
  
  
Residential mortgage$325
 3.45% 0.14% $422
 4.40% 0.20%
Home equity221
 2.35
 0.55
 506
 5.27
 1.05
Credit card3,710
 39.39
 3.80
 3,597
 37.47
 3.66
Direct/Indirect consumer234
 2.49
 0.26
 248
 2.58
 0.27
Other consumer52
 0.55
 n/m
 29
 0.30
 n/m
Total consumer4,542
 48.23
 0.98
 4,802
 50.02
 1.08
U.S. commercial (2)
3,015
 32.02
 0.94
 3,010
 31.35
 0.96
Non-U.S. commercial658
 6.99
 0.63
 677
 7.05
 0.69
Commercial real estate1,042
 11.07
 1.66
 958
 9.98
 1.57
Commercial lease financing159
 1.69
 0.80
 154
 1.60
 0.68
Total commercial4,874
 51.77
 0.96
 4,799
 49.98
 0.97
Allowance for loan and lease losses9,416
 100.00% 0.97
 9,601
 100.00% 1.02
Reserve for unfunded lending commitments813
     797
    
Allowance for credit losses$10,229
     $10,398
    
(1)
Ratios are calculated as allowance for loan and lease losses as a percentage of loans and leases outstanding excluding loans accounted for under the fair value option. Consumer loans accounted for under the fair value option include residential mortgage loans of $257 million and $336 million and home equity loans of $337 million and $346 million at December 31, 2019 and 2018. Commercial loans accounted for under the fair value option include U.S. commercial loans of $4.7 billion and $2.5 billion and non-U.S. commercial loans of $3.1 billion and $1.1 billion at December 31, 2019 and 2018.
(2)
Includes allowance for loan and lease losses for U.S. small business commercial loans of $523 million and $474 million at December 31, 2019 and 2018.
n/m = not meaningful

69Bank of America






Table 44 presents a rollforward of the allowance for credit losses, which(4)Primarily includes the allowance for loan and lease losses and the reserve for unfunded lending commitments, for 2019 and 2018.
     
Table 44Allowance for Credit Losses   
     
(Dollars in millions)2019 2018
Allowance for loan and lease losses, January 1$9,601
 $10,393
Loans and leases charged off   
Residential mortgage(93) (207)
Home equity(429) (483)
Credit card(3,535) (3,345)
Direct/Indirect consumer(518) (495)
Other consumer(249) (197)
Total consumer charge-offs(4,824) (4,727)
U.S. commercial (1)
(650) (575)
Non-U.S. commercial(115) (82)
Commercial real estate(31) (10)
Commercial lease financing(26) (8)
Total commercial charge-offs(822) (675)
Total loans and leases charged off(5,646) (5,402)
Recoveries of loans and leases previously charged off   
Residential mortgage140
 179
Home equity787
 485
Credit card587
 508
Direct/Indirect consumer309
 300
Other consumer15
 15
Total consumer recoveries1,838
 1,487
U.S. commercial (2)
122
 120
Non-U.S. commercial31
 14
Commercial real estate2
 9
Commercial lease financing5
 9
Total commercial recoveries160
 152
Total recoveries of loans and leases previously charged off1,998
 1,639
Net charge-offs(3,648) (3,763)
Provision for loan and lease losses3,574
 3,262
Other (3)
(111) (291)
Allowance for loan and lease losses, December 319,416
 9,601
Reserve for unfunded lending commitments, January 1797
 777
Provision for unfunded lending commitments16
 20
Reserve for unfunded lending commitments, December 31813
 797
Allowance for credit losses, December 31$10,229
 $10,398
     
Loan and allowance ratios:   
Loans and leases outstanding at December 31 (4)
$975,091
 $942,546
Allowance for loan and lease losses as a percentage of total loans and leases outstanding at December 31 (4)
0.97% 1.02%
Consumer allowance for loan and lease losses as a percentage of total consumer loans and leases outstanding at
December 31 (5)
0.98
 1.08
Commercial allowance for loan and lease losses as a percentage of total commercial loans and leases outstanding at December 31 (6)
0.96
 0.97
Average loans and leases outstanding (4)
$951,583
 $927,531
Net charge-offs as a percentage of average loans and leases outstanding (4)
0.38% 0.41%
Allowance for loan and lease losses as a percentage of total nonperforming loans and leases at December 31265
 194
Ratio of the allowance for loan and lease losses at December 31 to net charge-offs2.58
 2.55
Amounts included in allowance for loan and lease losses for loans and leases that are excluded from nonperforming loans and leases at December 31 (7)
$4,151
 $4,031
Allowance for loan and lease losses as a percentage of total nonperforming loans and leases, excluding the allowance for loan and lease losses for loans and leases that are excluded from nonperforming loans and leases at December 31 (7)
148% 113%
(1)
Includes U.S. small business commercial charge-offs of $320 million and $287 million in 2019 and 2018.
(2)
Includes U.S. small business commercial recoveries of $48 million and $47 million in 2019 and 2018.
(3)
Primarily represents write-offs of purchased credit-impaired (PCI) loans, the net impact of portfolio sales, and transfers to loans held-for-sale.
(4)
Outstanding loan and lease balances and ratios do not include loans accounted for under the fair value option of $8.3 billion and $4.3 billion at December 31, 2019 and 2018. Average loans accounted for under the fair value option were $6.8 billion and $5.5 billion in 2019 and 2018.
(5)
Excludes consumer loans accounted for under the fair value option of $594 million and $682 million at December 31, 2019 and 2018.
(6)
Excludes commercial loans accounted for under the fair value option of $7.7 billion and $3.7 billion at December 31, 2019 and 2018.
(7)
Primarily includes amounts allocatedamounts related to credit card and unsecured consumer lending portfolios in Consumer Banking.


Bank of America 7074


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 74.79.
We have been affected, and may continue to be affected, by market stress resulting from the pandemic that began in the first quarter of 2020. For more information, see Part 1. Item 1A. Risk Factors – Coronavirus Disease on page 8.
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 risk.risks. The Enterprise Model Risk Committee (EMRC), a subcommittee of the MRC, is responsible forproviding management oversight and approval of model risk management and governance. The EMRCPolicy defines model risk standards, consistent with the Corporation’sour 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 EMRCEnterprise 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 76.80.
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
75 Bank of America


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

71Bank of America






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 45.49.
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 4543 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.
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In addition, Table 4543 presents our fair value option portfolio, which includes substantially all of the funded and unfunded exposures for which we elect the fair value option, and their corresponding hedges. Additionally, market risk VaR for trading activities as presented in Table 4543 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 4543 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 4543 presents year-end, average, high and low daily trading VaR for 20192021 and 20182020 using a 99 percent confidence level. The amounts disclosed in Table 4543 and Table 4644 align to the view of covered positions used in the Basel 3 capital calculations. Foreign

Bank of America 72


exchange and commodity positions are always considered covered positions, regardless of trading or banking treatment for the trade, except for structural foreign currency positions that are excluded with prior regulatory approval.
The annual average of total covered positions and less liquid trading positions portfolio VaR slightly increased during 2019 with no significant drivers.decreased for 2021 compared to 2020 primarily due to an increase in diversification across asset classes.
Table 43Market Risk VaR for Trading Activities
20212020
(Dollars in millions)Year
End
Average
High (1)
Low (1)
Year
End
Average
High (1)
Low (1)
Foreign exchange$11 $12 $21 $5 $$$25 $
Interest rate54 40 80 16 30 19 39 
Credit73 69 84 53 79 58 91 25 
Equity21 24 35 19 20 24 162 12 
Commodities6 8 28 4 12 
Portfolio diversification(114)(100)  (72)(61)— — 
Total covered positions portfolio51 53 85 34 69 53 171 27 
Impact from less liquid exposures (2)
8 20   52 27 — — 
Total covered positions and less liquid trading positions portfolio59 73 125 46 121 80 169 30 
Fair value option loans51 50 65 31 52 52 84 
Fair value option hedges15 16 20 11 11 13 17 
Fair value option portfolio diversification(27)(32)  (17)(24)— — 
Total fair value option portfolio39 34 53 23 46 41 86 
Portfolio diversification(24)(10)  (4)(15)— — 
Total market-based portfolio$74 $97 169 54 $163 $106 171 32 
                 
Table 45Market Risk VaR for Trading Activities       
   
 2019 2018
(Dollars in millions)Year End Average 
High (1)
 
Low (1)
 Year End Average 
High (1)
 
Low (1)
Foreign exchange$4
 $6
 $13
 $2
 $9
 $8
 $15
 $2
Interest rate25
 24
 49
 14
 36
 25
 45
 15
Credit26
 23
 32
 16
 26
 25
 31
 20
Equity29
 22
 33
 14
 20
 20
 40
 11
Commodities4
 6
 31
 4
 13
 8
 15
 3
Portfolio diversification(47) (49) 
 
 (59) (55) 
 
Total covered positions portfolio41
 32
 47
 24
 45
 31
 45
 20
Impact from less liquid exposures
 3
 
 
 5
 3
 
 
Total covered positions and less liquid trading positions portfolio41
 35
 53
 27
 50
 34
 51
 23
Fair value option loans8
 10
 13
 7
 8
 11
 18
 8
Fair value option hedges10
 10
 17
 4
 5
 9
 17
 4
Fair value option portfolio diversification(9) (10) 
 
 (7) (11) 
 
Total fair value option portfolio9

10
 16
 5
 6
 9
 16
 5
Portfolio diversification(5) (7) 
 
 (3) (5) 
 
Total market-based portfolio$45

$38
 56
 28
 $53
 $38
 57
 26
(1)The high and low for each portfolio may have occurred on different trading days than the high and low for the components. Therefore the impact from less liquid exposures and the amount of portfolio diversification, which is the difference between the total portfolio and the sum of the individual components, is not relevant.
(1)
(2)Impact is net of diversification effects between the covered positions and less liquid trading positions portfolios.
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 2019,2021, corresponding to the data in Table 45.43.
varchartimageq4v2a01.jpg
bac-20211231_g3.jpg
77 Bank of America


Additional VaR statistics produced within our single VaR model are provided in Table 4644 at the same level of detail as in Table 45.43. 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 4644 presents average trading VaR statistics at 99 percent and 95 percent confidence levels for 20192021 and 2018.2020.
         
Table 46Average Market Risk VaR for Trading Activities – 99 percent and 95 percent VaR Statistics
         
  2019 2018
(Dollars in millions)99 percent 95 percent 99 percent 95 percent
Foreign exchange$6
 $3
 $8
 $5
Interest rate24
 15
 25
 16
Credit23
 15
 25
 15
Equity22
 11
 20
 11
Commodities6
 3
 8
 4
Portfolio diversification(49) (29) (55) (33)
Total covered positions portfolio32
 18
 31
 18
Impact from less liquid exposures3
 2
 3
 1
Total covered positions and less liquid trading positions portfolio35
 20
 34
 19
Fair value option loans10
 5
 11
 6
Fair value option hedges10
 6
 9
 6
Fair value option portfolio diversification(10) (5) (11) (7)
Total fair value option portfolio10
 6
 9
 5
Portfolio diversification(7) (5) (5) (3)
Total market-based portfolio$38
 $21
 $38
 $21

Table 44Average Market Risk VaR for Trading Activities – 99 percent and 95 percent VaR Statistics
20212020
(Dollars in millions)99 percent95 percent99 percent95 percent
Foreign exchange$12 $8 $$
Interest rate40 20 19 
Credit69 21 58 18 
Equity24 12 24 13 
Commodities8 4 
Portfolio diversification(100)(39)(61)(26)
Total covered positions portfolio53 26 53 21 
Impact from less liquid exposures20 2 27 
Total covered positions and less liquid trading positions portfolio73 28 80 23 
Fair value option loans50 12 52 13 
Fair value option hedges16 9 13 
Fair value option portfolio diversification(32)(9)(24)(8)
Total fair value option portfolio34 12 41 12 
Portfolio diversification(10)(7)(15)(6)
Total market-based portfolio$97 $33 $106 $29 
73Bank of America






Backtesting
The accuracy of the VaR methodology is evaluated by backtesting, which compares the daily VaR results, utilizing a one-day holding period, against a comparable subset of trading revenue. A backtesting excess occurs when a trading loss exceeds the VaR for the corresponding day. These excesses are evaluated to understand the positions and market moves that produced the trading loss with a goal to ensure that the VaR methodology accurately represents those losses. We expect the frequency of trading losses in excess of VaR to be in line with the confidence level of the VaR statistic being tested. For example, with a 99 percent confidence level, we expect one trading loss in excess of VaR every 100 days or between two to three trading losses in excess of VaR over the course of a year. The number of backtesting excesses observed can differ from the statistically expected number of excesses if the current level of market volatility is materially different than the level of market volatility that existed during the three years of historical data used in the VaR calculation.
The trading revenue used for backtesting is defined by regulatory agencies in order to most closely align with the VaR component of the regulatory capital calculation. This revenue differs from total trading-related revenue in that it excludes revenue from trading activities that either do not generate market risk or the market risk cannot be included in VaR. Some examples of the types of revenue excluded for backtesting are fees, commissions, reserves, net interest income and intra-day trading revenues.
We conduct daily backtesting on the VaR results used for regulatory capital calculations as well as the VaR results for key legal entities, regions and risk factors. These results are reported to senior market risk management. Senior management regularly reviews and evaluates the results of these tests.
During 2019,2021, there were notwo days in which there was a backtesting excess forwhere 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. Trading account assets and liabilities are reported at fair value. For more information on fair value, see Note 2120 – 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 20192021 and 2018.2020. During 2019,2021, positive trading-related revenue was recorded for 9897 percent of the trading days, of which 80 percent were daily trading gains of over $25 million, and the largest loss was $35$45 million. This compares to 20182020 where positive trading-related revenue was recorded for 98 percent of the trading days, of which 7987 percent were daily trading gains of over $25 million, and the largest loss was $90 million.
bac-20211231_g4.jpg

pnlchartimageq4.jpg
Bank of America 78


Trading Portfolio Stress Testing
Because the very nature of a VaR model suggests results can exceed our estimates and it is dependent on a limited historical window, we also stress test our portfolio using scenario analysis. This analysis estimates the change in the value of our trading portfolio that may result from abnormal market movements.
A set of scenarios, categorized as either historical or hypothetical, are computed daily for the overall trading portfolio and individual businesses. These scenarios include shocks to underlying market risk factors that may be well beyond the shocks found in the historical data used to calculate VaR. Historical scenarios simulate the impact of the market moves that occurred during a period of extended historical market stress. Generally, a multi-week period representing the most severe point during a crisis is selected for each historical scenario. Hypothetical scenarios provide estimated portfolio impacts from potential future market stress events. Scenarios are reviewed and updated in response to changing positions and new economic or political information. In addition, new or ad hoc scenarios are developed to address specific potential market events or particular vulnerabilities in the portfolio. The stress tests are reviewed on a regular basis and the results are presented to senior management.
Stress testing for the trading portfolio is integrated with enterprise-wide stress testing and incorporated into the limits framework. The macroeconomic scenarios used for enterprise-wide stress testing purposes differ from the typical trading portfolio scenarios in that they have a longer time horizon and the results are forecasted over multiple periods for use in consolidated capital and liquidity planning. For more information, see Managing Risk on page 42.46.
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

Bank of America 74


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 4745 presents the spot and 12-month forward rates used in our baseline forecasts at December 31, 20192021 and 2018.2020.
      
Table 47Forward Rates
Table 45Table 45Forward Rates
      
 December 31, 2019December 31, 2021
 
Federal
Funds
 
Three-month
LIBOR
 
10-Year
Swap
 Federal
Funds
Three-month
LIBOR
10-Year
Swap
Spot ratesSpot rates1.75% 1.91% 1.90%Spot rates0.25 %0.21 %1.58 %
12-month forward rates12-month forward rates1.50
 1.62
 1.92
12-month forward rates1.00 1.07 1.84 
      
 December 31, 2018December 31, 2020
Spot ratesSpot rates2.50% 2.81% 2.71%Spot rates0.25 %0.24 %0.93 %
12-month forward rates12-month forward rates2.50
 2.64
 2.75
12-month forward rates0.25 0.19 1.06 
Table 4846 shows the pretax impact to forecasted net interest income over the next 12 months from December 31, 20192021 and 2018,2020 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 2019,2021, the overall decrease in asset sensitivity of our balance sheet increasedto Up-rate and Down-rate scenarios was primarily due to decreasesALM activity and an increase in interestlong-end rates. 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 available for sale (AFS),AFS, may adversely affect accumulated other comprehensive income (OCI)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 46.50.
        
Table 48Estimated Banking Book Net Interest Income Sensitivity to Curve Changes
Table 46Table 46Estimated Banking Book Net Interest Income Sensitivity to Curve Changes
        
 
Short
Rate (bps)
 
Long
Rate (bps)
    Short
Rate (bps)
Long
Rate (bps)
 December 31December 31
(Dollars in millions)(Dollars in millions) 2019 2018(Dollars in millions)20212020
Parallel ShiftsParallel Shifts       Parallel Shifts
+100 bps
instantaneous shift
+100 bps
instantaneous shift
+100 +100 $4,190
 $2,833
+100 bps
instantaneous shift
+100+100$6,542 $10,468 
-100 bps
instantaneous shift
-100
 -100
 (6,536) (4,280)
-25 bps
instantaneous shift
-25 bps
instantaneous shift
-25 -25 (2,092)(2,766)
FlattenersFlatteners 
  
    Flatteners  
Short-end
instantaneous change
Short-end
instantaneous change
+100 
 2,641
 2,158
Short-end
instantaneous change
+100— 4,982 6,321 
Long-end
instantaneous change
Long-end
instantaneous change

 -100
 (2,965) (1,618)
Long-end
instantaneous change
— -25 (735)(1,686)
SteepenersSteepeners 
  
    Steepeners  
Short-end
instantaneous change
Short-end
instantaneous change
-100
 
 (3,527) (2,648)
Short-end
instantaneous change
-25 — (1,344)(1,084)
Long-end
instantaneous change
Long-end
instantaneous change

 +100 1,561
 675
Long-end
instantaneous change
— +1001,646 4,333 
The sensitivity analysis in Table 4846 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 4846 assumes no change in
79 Bank of America


deposit portfolio size or mix from the baseline forecast in alternate rate environments. In higher rate scenarios, any customer activity resulting in the replacement of low-cost or noninterest-bearing deposits with higher yielding deposits or market-based funding would reduce our benefit in those scenarios.
Interest Rate and Foreign Exchange Derivative Contracts
InterestWe use 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. Werisks. Specifically, we use those derivatives to hedgemanage both the variability in cash flows orand changes in fair value on our balance sheet dueof various assets and liabilities arising from those risks. Our interest rate derivative contracts are generally non-leveraged swaps tied to various benchmark interest raterates and foreign exchange components.basis swaps, options, futures and forwards, and our foreign exchange contracts include cross-currency interest rate swaps, foreign currency futures contracts, foreign currency forward contracts and options.
The derivatives used in our ALM activities can be split into two broad categories: designated accounting hedges and other risk management derivatives. Designated accounting hedges are primarily used to manage our exposure to interest rates as described in the Interest Rate Risk Management for the Banking Book section and are included in the sensitivities presented in Table 46. The Corporation also uses foreign currency derivatives in accounting hedges to manage substantially all of the foreign exchange risk of our foreign operations. By hedging the foreign exchange risk of our foreign operations, the Corporation's market risk exposure in this area is insignificant.
Risk management derivatives are predominantly used to hedge foreign exchange risks related to various foreign currency-denominated assets and liabilities and eliminate substantially all foreign currency exposures in the cash flows of the Corporation’s non-trading foreign currency-denominated financial instruments. These foreign exchange derivatives are sensitive to other market risk exposures such as cross-currency basis spreads and interest rate risk. However, as these features are not a significant component of these foreign exchange derivatives, the market risk related to this exposure is insignificant. For more information on our hedging activities,the accounting for derivatives, see Note 3 – Derivatives to the Consolidated Financial Statements.
Our interest rate contracts are generally non-leveraged generic interest rate and foreign exchange basis swaps, options, futures and forwards. In addition, we use foreign exchange contracts, including cross-currency interest rate swaps, foreign currency futures contracts, foreign currency forward contracts and options to mitigate the foreign exchange risk associated with foreign currency-denominated assets and liabilities.
Changes to the composition of our derivatives portfolio during 2019 reflect actions taken for interest rate and foreign exchange rate risk management. The decisions to reposition our derivatives portfolio are based on the current assessment of economic and financial conditions including the interest rate and foreign currency environments, balance sheet composition and trends, and the relative mix of our cash and derivative positions.
We use interest rate derivative instruments to hedge the variability in the cash flows of our assets and liabilities and other forecasted transactions (collectively referred to as cash flow hedges). The net losses on both open and terminated cash flow hedge derivative instruments recorded in accumulated OCI were $496 million and $1.3 billion, on a pretax basis, at December 31, 2019 and 2018. These net losses are expected to be reclassified into earnings in the same period as the hedged cash flows affect earnings and will decrease income or increase expense on the respective hedged cash flows. Assuming no change in open cash flow derivative hedge positions and no changes in prices or interest rates beyond what is implied in forward yield curves at December 31, 2019, the pretax net losses are expected to be reclassified into earnings as follows: 17 percent within the next year, 44 percent in years two through five, 22 percent in years six through ten, with the remaining 17 percent thereafter. For more information on derivatives designated as cash flow hedges, see Note 3 – Derivatives to the Consolidated Financial Statements.
We hedge our net investment in non-U.S. operations determined to have functional currencies other than the U.S. dollar using forward foreign exchange contracts that typically settle in less than 180 days, cross-currency basis swaps and foreign exchange options. We recorded net after-tax losses on derivatives in accumulated OCI associated with net investment hedges which were offset by gains on our net investments in consolidated non-U.S. entities at December 31, 2019.
Table 49 presents derivatives utilized in our ALM activities and shows the notional amount, fair value, weighted-average receive-fixed and pay-fixed rates, expected maturity and average estimated

75Bank of America






durations of our open ALM derivatives at December 31, 2019 and 2018. These amounts do not include derivative hedges on our MSRs. During 2019, the fair value of receive-fixed interest rate
swaps increased while pay-fixed interest rate swaps decreased, driven by lower swap rates.
                   
Table 49Asset and Liability Management Interest Rate and Foreign Exchange Contracts
       
    December 31, 2019  
    Expected Maturity  
(Dollars in millions, average estimated duration in years)Fair
Value
 Total 2020 2021 2022 2023 2024 Thereafter Average
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-rate  2.68% 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-rate  2.36% 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
  
  
  
  
  
  
  
  
    December 31, 2018  
    Expected Maturity  
(Dollars in millions, average estimated duration in years)Fair
Value
 Total 2019 2020 2021 2022 2023 Thereafter Average
Estimated
Duration
Receive-fixed interest rate swaps (1)
$2,128
  
  
  
  
  
  
  
 5.17
Notional amount 
 $198,914
 $27,176
 $16,347
 $14,640
 $19,866
 $36,215
 $84,670
  
Weighted-average fixed-rate 
 2.66% 1.87% 2.68% 3.17% 2.56% 2.37% 2.97%  
Pay-fixed interest rate swaps (1)
295
  
  
  
  
  
  
  
 6.30
Notional amount 
 $49,275
 $1,210
 $4,344
 $1,616
 $
 $10,801
 $31,304
  
Weighted-average fixed-rate 
 2.50% 2.07% 2.16% 2.22% % 2.59% 2.55%  
Same-currency basis swaps (2)
21
  
  
  
  
  
  
  
  
Notional amount 
 $101,203
 $7,628
 $15,097
 $15,493
 $2,586
 $2,017
 $58,382
  
Foreign exchange basis swaps (1, 3, 4)
(1,716)  
  
  
  
  
  
  
  
Notional amount 
 106,742
 13,946
 21,448
 19,241
 10,239
 6,260
 35,608
  
Foreign exchange contracts (1, 4, 5)
82
  
  
  
  
  
  
  
  
Notional amount (6)
 
 (8,447) (27,823) 13
 4,196
 2,741
 2,448
 9,978
  
Option products2
  
  
  
  
  
  
  
  
Notional amount 
 587
 572
 
 
 
 15
 
  
Net ALM contracts$812
  
  
  
  
  
  
  
  
(1)
Does not include basis adjustments on either fixed-rate debt issued by the Corporation or AFS debt securities, which are hedged using derivatives designated as fair value hedging instruments, that substantially offset the fair values of these derivatives.
(2)
At December 31, 2019 and 2018, the notional amount of same-currency basis swaps included $152.2 billion and $101.2 billion in both foreign currency and U.S. dollar-denominated basis swaps in which both sides of the swap are in the same currency.
(3)
Foreign exchange basis swaps consisted of cross-currency variable interest rate swaps used separately or in conjunction with receive-fixed interest rate swaps.
(4)
Does not include foreign currency translation adjustments on certain non-U.S. debt issued by the Corporation that substantially offset the fair values of these derivatives.
(5)
The notional amount of foreign exchange contracts of $(53.1) billion at December 31, 2019 was comprised of $29.0 billion in foreign currency-denominated and cross-currency receive-fixed swaps, $(82.4) billion in net foreign currency forward rate contracts, $(313) million in foreign currency-denominated interest rate swaps and $644 million in net foreign currency futures contracts. Foreign exchange contracts of $(8.4) billion at December 31, 2018 were comprised of $25.2 billion in foreign currency-denominated and cross-currency receive-fixed swaps, $(32.7) billion in net foreign currency forward rate contracts, $(1.8) billion in foreign currency-denominated interest rate swaps and $814 million in foreign currency futures contracts.
(6)
Reflects the net of long and short positions. Amounts shown as negative reflect a net short position.
Mortgage Banking Risk Management
We originate, fund and service mortgage loans, which subject us to credit, liquidity and interest rate risks, among others. We determine whether loans will be held for investment or held for sale at the time of commitment and manage credit and liquidity risks by selling or securitizing a portion of the loans we originate.
Interest rate risk and market risk can be substantial in the mortgage business. Changes in interest rates and other market factors impact the volume of mortgage originations. Changes in interest rates also impact the value of interest rate lock commitments (IRLCs) and the related residential first mortgage LHFS between the date of the IRLC and the date the loans are
sold to the secondary market. An increase in mortgage interest rates typically leads to a decrease in the value of these instruments. Conversely, when there is an increase in interest
rates, the value of the MSRs will increase driven by lower prepayment expectations. Because the interest rate risks of these hedged items offset, we combine them into one overall hedged item with one combined economic hedge portfolio consisting of derivative contracts and securities.
During 2019, 20182021, 2020 and 2017,2019, we recorded gains of $291$39 million, $244$321 million and $118 million related to the change in fair value of the MSRs, IRLCs and LHFS, net of gains and losses on the hedge portfolio.$291 million. For more information on MSRs, see Note 2120 – 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

Bank of America 76


requirements of applicable laws, rules, regulations and our internal policies and procedures (collectively, applicable laws, rules and regulations). We are subject to comprehensive regulation under federal and state laws, rules and regulations in the U.S. and the laws of the various jurisdictions in which we operate, including those related to financial crimes and anti-money laundering, market conduct, trading activities, fair lending, privacy, data protection and unfair, deceptive or abusive acts or practices.
Operational risk is the risk of loss resulting from inadequate or failed processes or systems, people or external events, and systems or from external events.includes legal risk. Operational risk may occur anywhere in the Corporation, including third-party business processes, and is not limited to operations functions. Effects may extend beyondThe Corporation faces a number of key operational risks including third-party risk, model risk, conduct risk, technology risk, information security risk and data risk. Operational risk can result in financial losses and may result in reputational risk impacts. Operational risk includes legal risk. Additionally, operational riskimpacts and is a component in the calculation of total risk-weighted assetsRWA used in the Basel 3 capital calculation. For more information on Basel 3 calculations, see Capital Management on page 45.49.
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 and 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. Collectively, these efforts are important to strengthen their compliance and operational resiliency, which is the ability to deliver critical operations through disruption.

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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,GRM, works with Global Compliance and Operational Risk, the FLUs and control functions in the identification of testing needs and test design, and is accountable for test execution, reporting and analysis of results.
Corporate Audit provides an 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 ofand reflect Global Compliance and Operational Risk’s responsibilities for conducting independent oversight of ourthe Corporation’s compliance and operational risk management activities. The Board provides oversight of compliance risk through its Audit Committee and the ERC, and operational risk through theits 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.data. The Corporation managesseeks to mitigate information security risk in accordance withinternal policiesand associated reputational and compliance risk by employing a multi-layered and intelligence-led Global Information Security Program, which govern our
is focused on preparing for, preventing, detecting, mitigating, responding to and recovering from cyber threats and incidents and ensuring the Corporation’s processes operate effectively and mitigate the aforementioned risks.
comprehensive information security program designed to protect the CorporationThe Global Information Security Program is supported by enabling preventative, detective and responsive measures to combat information and cybersecurity risks.three lines of defense. The Board and the ERC provide cybersecurity and information security risk oversight for the Corporation and our Global Information Security Team manageswithin the first line of defense is responsible for the day-to-day implementationmanagement of ourthe Global Information Security Program, which includes defining policies and procedures to safeguard the Corporation’s information systems and data, conducting vulnerability and third-party information security program.assessments, information security event management (e.g., responding to ransomware and distributed denial of service attacks), evaluation of external cyber intelligence, supporting industry cybersecurity efforts and working with governmental agencies, as well as developing employee training to support adherence to the Corporation’s policies and procedures. As the second line of defense, Global Compliance and Operational Risk independently assesses, monitors and tests information security risk across the Corporation as well as the effectiveness of the Global Information Security Program. Corporate Audit serves as the third line of defense, conducting additional independent review and validation of the first line processes and functions.

Through established governance structures, we have processes to help facilitate appropriate and effective oversight of information security risk. These routines enable our three lines of defense and management to debate information security risks and monitor control performance to allow for further escalation to executive management, management and Board-level committees or to the Board, as appropriate. The Board is actively engaged in the oversight of Bank of America’s Global Information Security Program, primarily through the ERC.
Reputational Risk Management
Reputational risk is the risk that negative perceptionsperception of the Corporation’s conduct or business practicesCorporation 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 inembedded throughout its businessesbusiness and risk management processes. We proactively monitor and identify potential reputational risk events and have processes established to mitigate reputational risks in a timely manner and through proactive monitoring and identification of potential reputational risk events.manner. 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 reputationalrisks. 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 providingrisk, including 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 rising average global temperatures and sea-level rise. 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. These risks can impact both financial and nonfinancial risk types. The impacts of transition risk can lead to and amplify credit risk or market risk by reducing our customers’ operating income or the value of their assets as well as expose us to reputational and/or litigation risk due to increased regulatory scrutiny or negative public sentiment. Physical risk can lead to increased credit risk by diminishing borrowers’ repayment capacity or impacting the value of collateral. In addition, it could pose increased operational risk to our facilities and people.

81 Bank of America


Effective management of climate risk requires coordinated governance, clearly defined roles and responsibilities and well-developed processes to identify, measure, monitor and control risks. We continue to build out and enhance our climate risk management capabilities. 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. Our Environmental and Social Risk Policy Framework (ESRPF) aligns with our Risk Framework and provides additional clarity and transparency regarding our approach to environmental and social risks, inclusive of climate risk.
Our governance framework establishes oversight of climate risk practices and strategies by the Board, supported by its Corporate Governance, ESG, and Sustainability Committee and ERC, as well as the MRC and the Global ESG Committee, both of which are management-level committees comprised of senior leaders across every major FLU and control function.
Our climate risk management efforts are overseen by the Global Climate Risk Executive who reports to the CRO. The Global Climate Risk Executive chairs the Climate Risk Steering Council, which meets monthly and shapes our approach to managing climate-related risks in line with our Risk Framework.
As outlined in our ESRPF, we are focused on supporting and financing areas critical to the transition to a low-carbon economy. Accordingly, we have a goal, publicly announced in early 2021, to achieve net zero greenhouse gas emissions in our financing activities, operations and supply chain before 2050 (Net Zero Goal). More broadly, achieving this goal will require technological advances, clearly defined roadmaps for industry sectors, public policies, and better emissions data reporting, as well as ongoing, strong and active engagement with clients, suppliers, investors, government officials and other stakeholders.
Our progress towards achieving our Net Zero Goal is based on establishing the baseline for emissions associated with our financing activities often referred to as financed emissions. Currently, we are using the Partnership for Carbon Accounting Financials methodology to assess our financed emissions. Additionally, given the urgency required to address climate change, we helped to launch the Net Zero Banking Alliance (NZBA) in April 2021, which outlines guidelines for banks to achieve net zero greenhouse gas emissions including requirements for setting interim targets. As a member of NZBA, the Corporation and more than 100 other financial institution members representing more than 40 percent of the world’s banking assets, have committed to set emission reduction targets for 2030. We plan to begin disclosure of financed emissions by 2023, and set 2030 targets for the significant majority of emissions in our portfolio.
In 2021, we also announced a goal to deploy $1 trillion by 2030 to accelerate the transition to a low-carbon, sustainable economy by providing lending, capital raising, advisory and investment services, and by developing other client-driven financial solutions. This commitment anchors a broader $1.5
trillion sustainable finance goal to support both environmental transition and social inclusive development, which spans business activities across the globe. These goals are intended to help drive business opportunities and enhance risk management related to the transition to a low-carbon economy.
For more information about climate risk, see the Bank of America website. For more information about the Corporation’s climate-related goals and commitments, including emissions associated with our operations and supply chain and progress on our sustainable finance goals, see the Corporation’s 2021 Annual Report to shareholders that will be available on the Investor Relations portion of our website in March 2022. The contents of the Corporation’s website and 2021 Annual Report to shareholders are not incorporated by reference into this Annual Report on Form 10-K.
The foregoing discussion and our discussion in the 2021 Annual Report to shareholders regarding our goals and commitments with respect to climate risk management, including environmental transition considerations, include “forward-looking statements” within the meaning of the Private Securities Litigation Reform Act of 1995. 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.
Complex Accounting Estimates
Our significant accounting principles, as described inNote 1 - Summary of Significant Accounting Principles to the Consolidated Financial Statements, are essential in understanding the MD&A. Many of our significant accounting principles require complex judgments to estimate the values of assets and liabilities. We have procedures and processes in place to facilitate making these judgments.
The more judgmental estimates are summarized in the following discussion. We have identified and described the development of the variables most important in the estimation processes that involve mathematical models to derive the estimates. In many cases, there are numerous alternative judgments that could be used in the process of determining the inputs to the models. Where alternatives exist, we have used the factors that we believe represent the most reasonable value in developing the inputs. Actual performance that differs from our estimates of the key variables could materially impact our results of operations. Separate from the possible future impact to our results of operations from input and model variables, the value of our lending portfolio and market-sensitive assets and liabilities may change subsequent to the balance sheet date, often significantly, due to the nature and magnitude of future credit and market conditions. Such credit and market conditions may change quickly and in unforeseen ways and the resulting volatility could have a significant, negative effect on future operating results. These fluctuations would not be indicative of deficiencies in our models or inputs.


77Bank of America82






Allowance for Credit Losses
The allowance for credit losses which includes the allowance for loan and lease losses and the reserve for unfunded lending commitments, represents management’s estimate of probable incurred credit losses in the Corporation’s loan and lease portfolio excluding those loans accounted for under the fair value option. The allowance for credit losses includes both quantitative and qualitative components. The qualitative component has a higher degree of management subjectivity, and includes factors such as concentrations, economic conditions and other considerations.commitments. Our process for determining the allowance for credit losses is discussed in Note 1 – Summary of Significant Accounting Principles to the Consolidated Financial Statements.
Our estimate for the allowance for loan and lease losses is sensitive to the loss rates and expected cash flows from our Consumer Real Estate and Credit Card and Other Consumer portfolio segments, as well as our U.S. small business commercial card portfolio within the Commercial portfolio segment. For each one-percent increase in the loss rates on loans collectively evaluated for impairment in our Consumer Real Estate portfolio segment, coupled with a one-percent decrease in the discounted cash flows on those loans individually evaluated for impairment within this portfolio segment, the allowance for loan and lease losses at December 31, 2019 would have increased $18 million. Within our Credit Card and Other Consumer portfolio segment and U.S. small business commercial card portfolio, for each one-percent increase in the loss rates on loans collectively evaluated for impairment coupled with a one-percent decrease in the expected cash flows on those loans individually evaluated for impairment, the allowance for loan and lease losses at December 31, 2019 would have increased $46 million.
Our allowance for loan and lease losses is sensitive to the risk ratings assigned to loans and leases within the Commercial portfolio segment (excluding the U.S. small business commercial card portfolio). Assuming a downgrade of one level in the internal risk ratings for commercial loans and leases, except loans and leases already classified as Substandard and Doubtful as defined by regulatory authorities, the allowance for loan and lease losses would have increased $2.6 billion at December 31, 2019.
The allowance for loan and lease losses as a percentage of total loans and leases at December 31, 2019 was 0.97 percent and these hypothetical increases in the allowance would raise the ratio to 1.24 percent.
These sensitivity analyses do not represent management’s expectations of the deterioration in risk ratings or the increases in loss rates but are provided as hypothetical scenarios to assess the sensitivity of the allowance for loan and lease losses to changes in key inputs. We believe the risk ratings and loss severities currently in use are appropriate and that the probability of the alternative scenarios outlined above occurring within a short period of time is remote.
The process of determining the level of the allowance for credit losses requires a high degree of judgment. It is possible that others, given the same information, may at any point in time reach different reasonable conclusions.
The processes, judgments and estimates described herein relate to the accounting standard in effect through December 31, 2019. On January 1, 2020, the Corporation adopted the new accounting standard that requires the measurement of the allowance for credit losses to be based on management’s best estimate of lifetime expected credit losses inherent in the Corporation’s relevant financial assets. The Corporation’s lifetime
expected credit losses are determined using macroeconomic forecast assumptions and management judgments applicable to and through the expected life of the loan portfolios. For more
information, see Note 15Summary of Significant Accounting PrinciplesOutstanding Loans and Leases and Allowance for Credit Losses to the Consolidated Financial Statements.
The determination of allowance for credit losses is based on numerous estimates and assumptions, which require a high degree of judgment and are often interrelated. A critical judgment in the process is the weighting of our forward-looking macroeconomic scenarios that are incorporated into our quantitative models. As any one economic outlook is inherently uncertain, the Corporation uses multiple macroeconomic scenarios in its expected credit losses (ECL) calculation, which have included a baseline scenario, which is derived from consensus estimates, downside scenarios, a tail risk scenario similar to the severely adverse scenario used in stress testing and an upside scenario. Beginning in 2020, the scenarios incorporated the potential impacts of the pandemic and, beginning in the second quarter in 2021, an additional scenario was added to account for inflationary risk and higher interest rates. Generally, as the consensus estimates improve or deteriorate, the allowance for credit losses will change in a similar direction.
There are multiple variables that drive the macroeconomic scenarios with the key variables including, but not limited to, U.S. gross domestic product (GDP) and unemployment rates. As of December 31, 2020, the weighted macroeconomic outlook for U.S. average unemployment rate was forecasted at 6.6 percent, 5.5 percent and 5.0 percent in the fourth quarters of 2021, 2022 and 2023, respectively, and the weighted macroeconomic outlook for U.S. GDP was forecasted to grow at 2.5 percent, 2.4 percent and 2.1 percent year-over-year in the fourth quarters of 2021, 2022 and 2023, respectively. As of December 31, 2021 the latest consensus estimates for the U.S. average unemployment rate for the fourth quarter of 2021 was 4.4 percent and U.S. GDP was forecasted to grow 5.2 percent year-over-year in the fourth quarter of 2021, both of which were meaningfully better than our macroeconomic outlook as of December 31, 2020 and were factored into our December 31, 2021 allowance for credit losses estimate. In addition, as of December 31, 2021, the weighted macroeconomic outlook for the U.S. average unemployment rate was forecasted at 5.2 percent and 4.7 percent in the fourth quarters of 2022 and 2023, and the weighted macroeconomic outlook for U.S. GDP was forecasted to grow 2.1 percent and 1.9 percent year-over-year in the fourth quarters of 2022 and 2023.
In addition to the above judgments and estimates, the allowance for credit losses can also be impacted by unanticipated changes in asset quality of the portfolio, such as increases or decreases in credit and/or internal risk ratings in our commercial portfolio, improvement or deterioration in borrower delinquencies or credit scores in our credit card portfolio and increases or decreases in home prices, which is a primary driver of LTVs, in our consumer real estate portfolio, all
of which have some degree of uncertainty. As the macroeconomic outlook improved in 2021, along with improvements in asset quality, the allowance for credit losses decreased to $13.8 billion from $20.7 billion at December 31, 2020.
To provide an illustration of the sensitivity of the macroeconomic scenarios and other assumptions on the estimate of our allowance for credit losses, the Corporation compared the December 31, 2021 modeled ECL from the baseline scenario and our downside scenario. Relative to the baseline scenario, the downside scenario assumed a peak U.S. unemployment rate of approximately three percentage points higher than the consensus outlook, a decline in U.S. GDP followed by a prolonged recovery and a lower home price outlook with a difference of 14 percent at the trough. This sensitivity analysis resulted in a hypothetical increase in the allowance for credit losses of approximately $5 billion.
While the sensitivity analysis may be useful to understand how changes in macroeconomic assumptions could impact our modeled ECLs, it is not meant to forecast how our allowance for credit losses is expected to change in a different macroeconomic outlook. Importantly, the analysis does not incorporate a variety of factors, including qualitative reserves and the weighting of alternate scenarios, which could have offsetting effects on the estimate. Considering the variety of factors contemplated when developing and weighting macroeconomic outlooks such as recent economic events, leading economic indicators, views of internal and third-party economists and industry trends, in addition to other qualitative factors, the Corporation believes the allowance for credit losses at December 31, 2021 is appropriate.
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
83 Bank of America


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 2120 – Fair Value Measurements and Note 2221 – Fair Value Option to the Consolidated Financial Statements.
Level 3 Assets and Liabilities
Financial assets and liabilities, and MSRs, where values are based on valuation techniques that require inputs that are both unobservable and are significant to the overall fair value measurement are classified as Level 3 under the fair value hierarchy established in applicable accounting standards. The fair value of these Level 3 financial assets and liabilities and MSRs is determined using pricing models, discounted cash flow methodologies or similar techniques for which the determination of fair value requires significant management judgment or estimation.
Level 3 financial instruments may be hedged with derivatives classified as Level 1 or 2; therefore, gains or losses associated with Level 3 financial instruments may be offset by gains or losses associated with financial instruments classified in other levels of the fair value hierarchy. The Level 3 gains and losses recorded in earnings did not have a significant impact on our liquidity or capital. We conduct a review of our fair value hierarchy classifications on
a quarterly basis. Transfers into or out of Level 3 are made if the significant inputs used in the financial models measuring the fair values of the assets and liabilities became unobservable or observable, respectively, in the current marketplace. For more information on transfers into and out of Level 3 during 2019, 2018

Bank of America 78


2021, 2020 and 2017,2019, see Note 2120 – 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 2019 – Income Taxes to the Consolidated Financial Statements for a table of significant tax attributes and
additional information. For more information, see page 1418 under 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.
We completed our annual goodwill impairment test as of June 30, 2019 for all of our reporting units that had goodwill. We performed that test2021 by assessingusing a qualitative factorsassessment to determine whether it iswas more likely than not that the fair value of each reporting unit iswas less than its respective carrying value. Factors considered in the qualitative assessments include,assessment included, among other things, macroeconomic conditions, industry and market considerations, financial performance of the respective reporting unit and other relevant entity- and reporting-unit specific considerations. If based on the results of the qualitative assessment, it is more likely than not that the fair value of a reporting unit is less than its carrying value, a quantitative assessment is performed.
Based on our qualitative assessments,assessment, we determinedhave concluded that for each reporting unit with goodwill, it was morenot “more likely than notnot” that its respectivethe reporting units fair value exceeded itsvalues were less than their carrying value, indicating there was no impairment. For more information regarding goodwill balances at June 30, 2019, see Note 8 – Goodwill and Intangible Assets to the Consolidated Financial Statements.values.
Certain Contingent Liabilities
For more information on the complex judgments associated with certain contingent liabilities, see Note 1312 – Commitments and Contingencies to the Consolidated Financial Statements.


79Bank of America84






Non-GAAP Reconciliations
Tables 5047 and 5148 provide reconciliations of certain non-GAAP financial measures to GAAP financial measures.
Table 47
Annual Reconciliations to GAAP Financial Measures (1)
(Dollars in millions, shares in thousands)202120202019
Reconciliation of average shareholders’ equity to average tangible shareholders’ equity and average tangible common shareholders’ equity   
Shareholders’ equity$273,757 $267,309 $267,889 
Goodwill(69,005)(68,951)(68,951)
Intangible assets (excluding MSRs)(2,177)(1,862)(1,721)
Related deferred tax liabilities916 821 773 
Tangible shareholders’ equity$203,491 $197,317 $197,990 
Preferred stock(23,970)(23,624)(23,036)
Tangible common shareholders’ equity$179,521 $173,693 $174,954 
Reconciliation of year-end shareholders’ equity to year-end tangible shareholders’ equity and year-end tangible common shareholders’ equity  
Shareholders’ equity$270,066 $272,924 $264,810 
Goodwill(69,022)(68,951)(68,951)
Intangible assets (excluding MSRs)(2,153)(2,151)(1,661)
Related deferred tax liabilities929 920 713 
Tangible shareholders’ equity$199,820 $202,742 $194,911 
Preferred stock(24,708)(24,510)(23,401)
Tangible common shareholders’ equity$175,112 $178,232 $171,510 
Reconciliation of year-end assets to year-end tangible assets  
Assets$3,169,495 $2,819,627 $2,434,079 
Goodwill(69,022)(68,951)(68,951)
Intangible assets (excluding MSRs)(2,153)(2,151)(1,661)
Related deferred tax liabilities929 920 713 
Tangible assets$3,099,249 $2,749,445 $2,364,180 
           
Table 50
Five-year Reconciliations to GAAP Financial Measures (1)
  
           
(Dollars in millions, shares in thousands)2019 2018 2017 2016 2015
Reconciliation of average shareholders’ equity to average tangible shareholders’ equity and average tangible common shareholders’ equity 
  
  
  
  
Shareholders’ equity$267,889
 $264,748
 $271,289
 $265,843
 $251,384
Goodwill(68,951) (68,951) (69,286) (69,750) (69,772)
Intangible assets (excluding MSRs)(1,721) (2,058) (2,652) (3,382) (4,201)
Related deferred tax liabilities773
 906
 1,463
 1,644
 1,852
Tangible shareholders’ equity$197,990
 $194,645
 $200,814
 $194,355
 $179,263
Preferred stock(23,036) (22,949) (24,188) (24,656) (21,808)
Tangible common shareholders’ equity$174,954
 $171,696
 $176,626
 $169,699
 $157,455
Reconciliation of year-end shareholders’ equity to year-end tangible shareholders’ equity and year-end tangible common shareholders’ equity 
  
  
  
  
Shareholders’ equity$264,810
 $265,325
 $267,146
 $266,195
 $255,615
Goodwill(68,951) (68,951) (68,951) (69,744) (69,761)
Intangible assets (excluding MSRs)(1,661) (1,774) (2,312) (2,989) (3,768)
Related deferred tax liabilities713
 858
 943
 1,545
 1,716
Tangible shareholders’ equity$194,911
 $195,458
 $196,826
 $195,007
 $183,802
Preferred stock(23,401) (22,326) (22,323) (25,220) (22,272)
Tangible common shareholders’ equity$171,510
 $173,132
 $174,503
 $169,787
 $161,530
Reconciliation of year-end assets to year-end tangible assets 
  
  
  
  
Assets$2,434,079
 $2,354,507
 $2,281,234
 $2,188,067
 $2,144,606
Goodwill(68,951) (68,951) (68,951) (69,744) (69,761)
Intangible assets (excluding MSRs)(1,661) (1,774) (2,312) (2,989) (3,768)
Related deferred tax liabilities713
 858
 943
 1,545
 1,716
Tangible assets$2,364,180
 $2,284,640
 $2,210,914
 $2,116,879
 $2,072,793
(1)(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.
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 27.
                 
Table 51
Quarterly Reconciliations to GAAP Financial Measures (1)
                 
  2019 Quarters 2018 Quarters
(Dollars in millions)Fourth Third Second First Fourth Third Second First
Reconciliation of average shareholders’ equity to average tangible shareholders’ equity and average tangible common shareholders’ equity 
  
  
  
  
  
  
  
Shareholders’ equity$266,900
 $270,430
 $267,975
 $266,217
 $263,698
 $264,653
 $265,181
 $265,480
Goodwill(68,951) (68,951) (68,951) (68,951) (68,951) (68,951) (68,951) (68,951)
Intangible assets (excluding MSRs)(1,678) (1,707) (1,736) (1,763) (1,857) (1,992) (2,126) (2,261)
Related deferred tax liabilities730
 752
 770
 841
 874
 896
 916
 939
Tangible shareholders’ equity$197,001
 $200,524
 $198,058
 $196,344
 $193,764
 $194,606
 $195,020
 $195,207
Preferred stock(23,461) (23,800) (22,537) (22,326) (22,326) (22,841) (23,868) (22,767)
Tangible common shareholders’ equity$173,540
 $176,724
 $175,521
 $174,018
 $171,438
 $171,765
 $171,152
 $172,440
Reconciliation of period-end shareholders’ equity to period-end tangible shareholders’ equity and period-end tangible common shareholders’ equity 
  
  
  
  
  
  
  
Shareholders’ equity$264,810
 $268,387
 $271,408
 $267,010
 $265,325
 $262,158
 $264,216
 $266,224
Goodwill(68,951) (68,951) (68,951) (68,951) (68,951) (68,951) (68,951) (68,951)
Intangible assets (excluding MSRs)(1,661) (1,690) (1,718) (1,747) (1,774) (1,908) (2,043) (2,177)
Related deferred tax liabilities713
 734
 756
 773
 858
 878
 900
 920
Tangible shareholders’ equity$194,911
 $198,480
 $201,495
 $197,085
 $195,458
 $192,177
 $194,122
 $196,016
Preferred stock(23,401) (23,606)
(24,689)
(22,326)
(22,326)
(22,326)
(23,181)
(24,672)
Tangible common shareholders’ equity$171,510

$174,874

$176,806

$174,759

$173,132

$169,851

$170,941

$171,344
Reconciliation of period-end assets to period-end tangible assets 
  
  
  
  
  
  
  
Assets$2,434,079
 $2,426,330
 $2,395,892
 $2,377,164
 $2,354,507
 $2,338,833
 $2,291,670
 $2,328,478
Goodwill(68,951) (68,951) (68,951) (68,951) (68,951) (68,951) (68,951) (68,951)
Intangible assets (excluding MSRs)(1,661) (1,690) (1,718) (1,747) (1,774) (1,908) (2,043) (2,177)
Related deferred tax liabilities713
 734
 756
 773
 858
 878
 900
 920
Tangible assets$2,364,180
 $2,356,423
 $2,325,979
 $2,307,239
 $2,284,640
 $2,268,852
 $2,221,576
 $2,258,270
(1)
Presents reconciliations of non-GAAP financial measures to GAAP financial measures. For more information on non-GAAP financial measures and ratios we use in assessing the results of the Corporation, see Supplemental Financial Data on page 27.

Table 48
Quarterly Reconciliations to GAAP Financial Measures (1)
2021 Quarters2020 Quarters
(Dollars in millions)FourthThirdSecondFirstFourthThirdSecondFirst
Reconciliation of average shareholders’ equity to average tangible shareholders’ equity and average tangible common shareholders’ equity        
Shareholders’ equity$270,883 $275,484 $274,632 $274,047 $271,020 $267,323 $266,316 $264,534 
Goodwill(69,022)(69,023)(69,023)(68,951)(68,951)(68,951)(68,951)(68,951)
Intangible assets (excluding MSRs)(2,166)(2,185)(2,212)(2,146)(2,173)(1,976)(1,640)(1,655)
Related deferred tax liabilities913 915 915 920 910 855 790 728 
Tangible shareholders’ equity$200,608 $205,191 $204,312 $203,870 $200,806 $197,251 $196,515 $194,656 
Preferred stock(24,364)(23,441)(23,684)(24,399)(24,180)(23,427)(23,427)(23,456)
Tangible common shareholders’ equity$176,244 $181,750 $180,628 $179,471 $176,626 $173,824 $173,088 $171,200 
Reconciliation of period-end shareholders’ equity to period-end tangible shareholders’ equity and period-end tangible common shareholders’ equity        
Shareholders’ equity$270,066 $272,464 $277,119 $274,000 $272,924 $268,850 $265,637 $264,918 
Goodwill(69,022)(69,023)(69,023)(68,951)(68,951)(68,951)(68,951)(68,951)
Intangible assets (excluding MSRs)(2,153)(2,172)(2,192)(2,134)(2,151)(2,185)(1,630)(1,646)
Related deferred tax liabilities929 913 915 915 920 910 789 790 
Tangible shareholders’ equity$199,820 $202,182 $206,819 $203,830 $202,742 $198,624 $195,845 $195,111 
Preferred stock(24,708)(23,441)(23,441)(24,319)(24,510)(23,427)(23,427)(23,427)
Tangible common shareholders’ equity$175,112 $178,741 $183,378 $179,511 $178,232 $175,197 $172,418 $171,684 
Reconciliation of period-end assets to period-end tangible assets        
Assets$3,169,495 $3,085,446 $3,029,894 $2,969,992 $2,819,627 $2,738,452 $2,741,688 $2,619,954 
Goodwill(69,022)(69,023)(69,023)(68,951)(68,951)(68,951)(68,951)(68,951)
Intangible assets (excluding MSRs)(2,153)(2,172)(2,192)(2,134)(2,151)(2,185)(1,630)(1,646)
Related deferred tax liabilities929 913 915 915 920 910 789 790 
Tangible assets$3,099,249 $3,015,164 $2,959,594 $2,899,822 $2,749,445 $2,668,226 $2,671,896 $2,550,147 

(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 80


Statistical Tables
Table of Contents
Page
           
Table IOutstanding Loans and Leases
           
  December 31
(Dollars in millions)2019 2018 2017 2016 2015
Consumer 
  
  
  
  
Residential mortgage$236,169
 $208,557
 $203,811
 $191,797
 $187,911
Home equity40,208
 48,286
 57,744
 66,443
 75,948
Credit card97,608
 98,338
 96,285
 92,278
 89,602
Non-U.S. credit card
 
 
 9,214
 9,975
Direct/Indirect consumer (1)
90,998
 91,166
 96,342
 95,962
 90,149
Other consumer (2)
192
 202
 166
 626
 713
Total consumer loans excluding loans accounted for under the fair value option465,175
 446,549
 454,348
 456,320
 454,298
Consumer loans accounted for under the fair value option (3)
594
 682
 928
 1,051
 1,871
Total consumer465,769
 447,231
 455,276
 457,371
 456,169
Commercial         
U.S. commercial307,048
 299,277
 284,836
 270,372
 252,771
Non-U.S. commercial104,966
 98,776
 97,792
 89,397
 91,549
Commercial real estate (4)
62,689
 60,845
 58,298
 57,355
 57,199
Commercial lease financing19,880
 22,534
 22,116
 22,375
 21,352
  494,583
 481,432
 463,042
 439,499
 422,871
U.S. small business commercial (5)
15,333
 14,565
 13,649
 12,993
 12,876
Total commercial loans excluding loans accounted for under the fair value option509,916
 495,997
 476,691
 452,492
 435,747
Commercial loans accounted for under the fair value option (3)
7,741
 3,667
 4,782
 6,034
 5,067
Total commercial517,657
 499,664
 481,473
 458,526
 440,814
Less: Loans of business held for sale (6)

 
 
 (9,214) 
Total loans and leases$983,426
 $946,895
 $936,749
 $906,683
 $896,983
(1)
Includes primarily auto and specialty lending loans and leases of $50.4 billion, $50.1 billion, $52.4 billion, $50.7 billion and $43.9 billion, U.S. securities-based lending loans of $36.7 billion, $37.0 billion, $39.8 billion, $40.1 billion and $39.8 billion and non-U.S. consumer loans of $2.8 billion, $2.9 billion, $3.0 billion, $3.0 billion and $3.9 billion at December 31, 2019, 2018, 2017, 2016 and 2015, respectively.
(2)
Substantially all of other consumer at December 31, 2019, 2018 and 2017 is consumer overdrafts. Other consumer at December 31, 2016 and 2015 also includes consumer finance loans of $465 million and $564 million, respectively.
(3)
Consumer loans accounted for under the fair value option include residential mortgage loans of $257 million, $336 million, $567 million, $710 million and $1.6 billion, and home equity loans of $337 million, $346 million, $361 million, $341 million and $250 million at December 31, 2019, 2018, 2017, 2016 and 2015, respectively. Commercial loans accounted for under the fair value option include U.S. commercial loans of $4.7 billion, $2.5 billion, $2.6 billion, $2.9 billion and $2.3 billion, and non-U.S. commercial loans of $3.1 billion, $1.1 billion, $2.2 billion, $3.1 billion and $2.8 billion at December 31, 2019, 2018, 2017, 2016 and 2015, respectively.
(4)
Includes U.S. commercial real estate loans of $59.0 billion, $56.6 billion, $54.8 billion, $54.3 billion and $53.6 billion, and non-U.S. commercial real estate loans of $3.7 billion, $4.2 billion, $3.5 billion, $3.1 billion and $3.5 billion at December 31, 2019, 2018, 2017, 2016 and 2015, respectively.
(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.


8185 Bank of America






           
Table II
Nonperforming Loans, Leases and Foreclosed Properties (1)
           
  December 31
(Dollars in millions)2019 2018 2017 2016 2015
Consumer 
  
  
  
  
Residential mortgage$1,470
 $1,893
 $2,476
 $3,056
 $4,803
Home equity536
 1,893
 2,644
 2,918
 3,337
Direct/Indirect consumer47
 56
 46
 28
 24
Other consumer
 
 
 2
 1
Total consumer (2)
2,053
 3,842
 5,166
 6,004
 8,165
Commercial 
  
  
  
  
U.S. commercial1,094
 794
 814
 1,256
 867
Non-U.S. commercial43
 80
 299
 279
 158
Commercial real estate280
 156
 112
 72
 93
Commercial lease financing32
 18
 24
 36
 12
  1,449
 1,048
 1,249
 1,643
 1,130
U.S. small business commercial50
 54
 55
 60
 82
Total commercial (3)
1,499
 1,102
 1,304
 1,703
 1,212
Total nonperforming loans and leases3,552
 4,944
 6,470
 7,707
 9,377
Foreclosed properties285
 300
 288
 377
 459
Total nonperforming loans, leases and foreclosed properties$3,837
 $5,244
 $6,758
 $8,084
 $9,836
(1)
Balances exclude foreclosed properties insured by certain government-guaranteed loans, principally FHA-insured loans, that entered foreclosure of $260 million, $488 million, $801 million, $1.2 billion and $1.4 billion at December 31, 2019, 2018, 2017, 2016 and 2015, respectively.
(2)
In 2019, $422 million in interest income was estimated to be contractually due on $2.1 billion of consumer loans and leases classified as nonperforming at December 31, 2019, as presented in the table above, plus $5.5 billion of TDRs classified as performing at December 31, 2019. Approximately $297 million of the estimated $422 million in contractual interest was received and included in interest income for 2019.
(3)
In 2019, $133 million in interest income was estimated to be contractually due on $1.5 billion of commercial loans and leases classified as nonperforming at December 31, 2019, as presented in the table above, plus $1.3 billion of TDRs classified as performing at December 31, 2019. Approximately $88 million of the estimated $133 million in contractual interest was received and included in interest income for 2019.
           
Table III 
Accruing Loans and Leases Past Due 90 Days or More (1)
           
  December 31
(Dollars in millions)2019 2018 2017 2016 2015
Consumer 
  
  
  
  
Residential mortgage (2)
$1,088
 $1,884
 $3,230
 $4,793
 $7,150
Credit card1,042
 994
 900
 782
 789
Non-U.S. credit card
 
 
 66
 76
Direct/Indirect consumer33
 38
 40
 34
 39
Other consumer
 
 
 4
 3
Total consumer2,163
 2,916
 4,170
 5,679
 8,057
Commercial 
  
  
  
  
U.S. commercial 106
 197
 144
 106
 113
Non-U.S. commercial8
 
 3
 5
 1
Commercial real estate19
 4
 4
 7
 3
Commercial lease financing20
 29
 19
 19
 15
  153
 230
 170
 137
 132
U.S. small business commercial97
 84
 75
 71
 61
Total commercial250
 314
 245
 208
 193
Total accruing loans and leases past due 90 days or more$2,413
 $3,230
 $4,415
 $5,887
 $8,250
(1)
Our policy is to classify consumer real estate-secured loans as nonperforming at 90 days past due, except the fully-insured loan portfolio and loans accounted for under the fair value option.
(2)
Balances are fully-insured loans.


Bank of America 82


         
Table IV
Selected Loan Maturity Data (1, 2)
       
         
  December 31, 2019
(Dollars in millions)
Due in One
Year or Less
 Due After One Year Through Five Years 
Due After
Five Years
 Total
U.S. commercial$76,523
 $200,298
 $50,216
 $327,037
U.S. commercial real estate13,683
 39,259
 6,023
 58,965
Non-U.S. and other (3)
47,828
 56,072
 7,875
 111,775
Total selected loans$138,034
 $295,629
 $64,114
 $497,777
Percent of total28% 59% 13% 100%
Sensitivity of selected loans to changes in interest rates for loans due after one year: 
  
  
  
Fixed interest rates 
 $21,526
 $31,383
  
Floating or adjustable interest rates 
 274,103
 32,731
  
Total 
 $295,629
 $64,114
  
(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 VAllowance for Credit Losses         
           
(Dollars in millions)2019 2018 2017 2016 2015
Allowance for loan and lease losses, January 1$9,601
 $10,393
 $11,237
 $12,234
 $14,419
Loans and leases charged off     
  
  
Residential mortgage(93) (207) (188) (403) (866)
Home equity(429) (483) (582) (752) (975)
Credit card(3,535) (3,345) (2,968) (2,691) (2,738)
Non-U.S. credit card (1)

 
 (103) (238) (275)
Direct/Indirect consumer(518) (495) (491) (392) (383)
Other consumer(249) (197) (212) (232) (224)
Total consumer charge-offs(4,824) (4,727) (4,544) (4,708) (5,461)
U.S. commercial (2)
(650) (575) (589) (567) (536)
Non-U.S. commercial(115) (82) (446) (133) (59)
Commercial real estate(31) (10) (24) (10) (30)
Commercial lease financing(26) (8) (16) (30) (19)
Total commercial charge-offs(822) (675) (1,075) (740) (644)
Total loans and leases charged off(5,646) (5,402) (5,619) (5,448) (6,105)
Recoveries of loans and leases previously charged off     
  
  
Residential mortgage140
 179
 288
 272
 393
Home equity787
 485
 369
 347
 339
Credit card587
 508
 455
 422
 424
Non-U.S. credit card (1)

 
 28
 63
 87
Direct/Indirect consumer309
 300
 277
 258
 271
Other consumer15
 15
 49
 27
 31
Total consumer recoveries1,838
 1,487
 1,466
 1,389
 1,545
U.S. commercial (3)
122
 120
 142
 175
 172
Non-U.S. commercial31
 14
 6
 13
 5
Commercial real estate2
 9
 15
 41
 35
Commercial lease financing5
 9
 11
 9
 10
Total commercial recoveries160
 152
 174
 238
 222
Total recoveries of loans and leases previously charged off1,998
 1,639
 1,640
 1,627
 1,767
Net charge-offs(3,648) (3,763) (3,979) (3,821) (4,338)
Provision for loan and lease losses3,574
 3,262
 3,381
 3,581
 3,043
Other (4)
(111) (291) (246) (514) (890)
Total allowance for loan and lease losses, December 319,416
 9,601
 10,393
 11,480
 12,234
Less: Allowance included in assets of business held for sale (5)

 
 
 (243) 
Allowance for loan and lease losses, December 319,416
 9,601
 10,393
 11,237
 12,234
Reserve for unfunded lending commitments, January 1797
 777
 762
 646
 528
Provision for unfunded lending commitments16
 20
 15
 16
 118
Other (4)

 
 
 100
 
Reserve for unfunded lending commitments, December 31813
 797
 777
 762
 646
Allowance for credit losses, December 31$10,229
 $10,398
 $11,170
 $11,999
 $12,880
(1)
Represents amounts related to the non-U.S. credit card loan portfolio, which was sold in 2017.
(2)
Includes U.S. small business commercial charge-offs of $320 million, $287 million, $258 million, $253 million and $282 million in 2019, 2018, 2017, 2016 and 2015, respectively.
(3)
Includes U.S. small business commercial recoveries of $48 million, $47 million, $43 million, $45 million and $57 million in 2019, 2018, 2017, 2016 and 2015, respectively.
(4)
Primarily represents write-offs of PCI loans, the net impact of portfolio sales, consolidations and deconsolidations, foreign currency translation adjustments, transfers to held for sale and certain other reclassifications.
(5)
Represents allowance related to the non-U.S. credit card loan portfolio, which was sold in 2017.

83Bank of America






           
Table VAllowance for Credit Losses (continued)         
           
(Dollars in millions)2019 2018 2017 2016 2015
Loan and allowance ratios (6):
         
Loans and leases outstanding at December 31 (7)
$975,091
 $942,546
 $931,039
 $908,812
 $890,045
Allowance for loan and lease losses as a percentage of total loans and leases outstanding at December 31 (7)
0.97% 1.02% 1.12% 1.26% 1.37%
Consumer allowance for loan and lease losses as a percentage of total consumer loans and leases outstanding at December 31 (8)
0.98
 1.08
 1.18
 1.36
 1.63
Commercial allowance for loan and lease losses as a percentage of total commercial loans and leases outstanding at December 31 (9)
0.96
 0.97
 1.05
 1.16
 1.11
Average loans and leases outstanding (7)
$951,583
 $927,531
 $911,988
 $892,255
 $869,065
Net charge-offs as a percentage of average loans and leases outstanding (7)
0.38% 0.41% 0.44% 0.43% 0.50%
Allowance for loan and lease losses as a percentage of total nonperforming loans and leases at December 31265
 194
 161
 149
 130
Ratio of the allowance for loan and lease losses at December 31 to net charge-offs2.58
 2.55
 2.61
 3.00
 2.82
Amounts included in allowance for loan and lease losses for loans and leases that are excluded from nonperforming loans and leases at December 31 (10)
$4,151
 $4,031
 $3,971
 $3,951
 $4,518
Allowance for loan and lease losses as a percentage of total nonperforming loans and leases, excluding the allowance for loan and lease losses for loans and leases that are excluded from nonperforming loans and leases at December 31 (10)
148% 113% 99% 98% 82%
(6)
Loan and allowance ratios for 2016 include $243 million of non-U.S. credit card allowance for loan and lease losses and $9.2 billion of ending non-U.S. credit card loans, which were sold in 2017.
(7)
Outstanding loan and lease balances and ratios do not include loans accounted for under the fair value option of $8.3 billion, $4.3 billion, $5.7 billion, $7.1 billion and $6.9 billion at December 31, 2019, 2018, 2017, 2016 and 2015, respectively. Average loans accounted for under the fair value option were $6.8 billion, $5.5 billion, $6.7 billion, $8.2 billion and $7.7 billion in 2019, 2018, 2017, 2016 and 2015, respectively.
(8)
Excludes consumer loans accounted for under the fair value option of $594 million, $682 million, $928 million, $1.1 billion and $1.9 billion at December 31, 2019, 2018, 2017, 2016 and 2015, respectively.
(9)
Excludes commercial loans accounted for under the fair value option of $7.7 billion, $3.7 billion, $4.8 billion, $6.0 billion and $5.1 billion at December 31, 2019, 2018, 2017, 2016 and 2015, respectively.
(10)
Primarily includes amounts allocated to credit card and unsecured consumer lending portfolios in Consumer Banking and, in 2016 and 2015, the non-U.S. credit card portfolio in All Other.
                     
Table VIAllocation of the Allowance for Credit Losses by Product Type
                     
 December 31
 2019 2018 2017 2016 2015
(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$325
 3.45% $422
 4.40% $701
 6.74% $1,012
 8.82% $1,500
 12.26%
Home equity221
 2.35
 506
 5.27
 1,019
 9.80
 1,738
 15.14
 2,414
 19.73
Credit card3,710
 39.39
 3,597
 37.47
 3,368
 32.41
 2,934
 25.56
 2,927
 23.93
Non-U.S. credit card
 
 
 
 
 
 243
 2.12
 274
 2.24
Direct/Indirect consumer234
 2.49
 248
 2.58
 264
 2.54
 244
 2.13
 223
 1.82
Other consumer52
 0.55
 29
 0.30
 31
 0.30
 51
 0.44
 47
 0.38
Total consumer4,542
 48.23
 4,802
 50.02
 5,383
 51.79
 6,222
 54.21
 7,385
 60.36
U.S. commercial (1)
3,015
 32.02
 3,010
 31.35
 3,113
 29.95
 3,326
 28.97
 2,964
 24.23
Non-U.S. commercial658
 6.99
 677
 7.05
 803
 7.73
 874
 7.61
 754
 6.17
Commercial real estate1,042
 11.07
 958
 9.98
 935
 9.00
 920
 8.01
 967
 7.90
Commercial lease financing159
 1.69
 154
 1.60
 159
 1.53
 138
 1.20
 164
 1.34
Total commercial4,874
 51.77
 4,799
 49.98
 5,010
 48.21
 5,258
 45.79
 4,849
 39.64
Total allowance for loan and lease losses9,416
 100.00% 9,601
 100.00% 10,393
 100.00% 11,480
 100.00% 12,234
 100.00%
Less: Allowance included in assets of business held for sale (2)

   
   
   (243)   
  
Allowance for loan and lease losses9,416
   9,601
   10,393
   11,237
   12,234
  
Reserve for unfunded lending commitments813
   797
  
 777
   762
   646
  
Allowance for credit losses$10,229
   $10,398
  
 $11,170
   $11,999
   $12,880
  
(1)
Includes allowance for loan and lease losses for U.S. small business commercial loans of $523 million, $474 million, $439 million, $416 million and $507 million at December 31, 2019, 2018, 2017, 2016 and 2015, respectively.
(2)
Represents allowance for loan and lease losses related to the non-U.S. credit card loan portfolio, which was sold in 2017.

Bank of America 84


Item 7A. Quantitative and Qualitative Disclosures about Market Risk
See Market Risk Management on page 7175 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
Page




85Bank of America86







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, 20192021 based on the framework set forth by the Committee of Sponsoring Organizations of the Treadway Commission in Internal Control – Integrated Framework (2013). Based on that assessment, management concluded that, as of December 31, 2019,2021, the Corporation’s internal control over financial reporting is effective.
The Corporation’s internal control over financial reporting as of December 31, 20192021 has been audited by PricewaterhouseCoopers, LLP, an independent registered public accounting firm, as stated in their accompanying report which expresses an unqualified opinion on the effectiveness of the Corporation’s internal control over financial reporting as of December 31, 2019.2021.
bac-20211231_g5.jpg
Brian T. Moynihan
Chairman,Chair, Chief Executive Officer and President

cfosignature4q23.jpgbac-20211231_g6.jpg
PaulAlastair M. DonofrioBorthwick
Chief Financial Officer


87Bank of America86



Report of Independent Registered Public Accounting Firm
To the Board of Directors and Shareholders of Bank of America Corporation: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"“Corporation”) as of December 31, 20192021 and December 31, 2018,2020, 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, 2019,2021, 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, 2019,2021, 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, 20192021 and December 31, 2018, 2020, and the results of itsoperations and itscash flows for each of the three years in the period ended December 31, 20192021 in conformity with accounting principles generally accepted in the United States of America. Also in our opinion, the Corporation maintained, in all material respects, effective internal control over financial reporting as of December 31, 2019,2021, based on criteria established in Internal Control - Integrated Framework (2013)issued by the COSO.
Change in Accounting Principle
As discussed in Note 5 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’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) 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 65 to the consolidated financial statements, the allowance for loan and lease losses represents management’s estimate of probable incurredthe expected credit losses in the Corporation’s loan and lease portfolio.portfolio, excluding loans and unfunded lending commitments accounted for under the fair
Bank of America 88


value option. As of December 31, 2019,2021, the allowance for loan and lease losses was $9.4$12.4 billion on total loans and leases of $975.1$971.3 billion, which excludes loans accounted for under the fair value option. For commercial and consumer card loans, the expected credit loss is typically estimated using quantitative methods that consider a variety of factors such as historical loss experience, the current credit quality of the portfolio as well as an economic outlook over the life of the loan. 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 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 and lease losses includes both quantitative andare qualitative components. The allowance for certain consumer loan portfolios considers a variety of factors including historical loss experience, estimated defaults or foreclosures based on portfolio trends, delinquencies, bankruptcies, economic conditions, credit scores and the amount of lossreserves to cover losses that are expected but, in the eventCorporation'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 default. The allowance for certain commercialthe portfolio, portfolio concentrations, the volume and severity of past due loans is calculated using loss rates delineated by risk rating and product type. In addition,nonaccrual loans, the qualitative

87Bank of America






component has a higher degreeeffect of management subjectivity, and includesexternal factors such as concentrations, economic conditionscompetition, and other considerations.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) there wasthe significant judgment and estimation by management in determining the allowance for loandeveloping lifetime economic forecast scenarios, related weightings to each scenario and lease losses,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, relating to the allowance for loan and lease losses, including the qualitative component, and (ii) the audit effort involved professionals with specialized skill and knowledge to assist in evaluating certain audit evidence.knowledge.
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.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 and lease 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 lifetime economic forecast scenarios used in the loss forecast models, (iv) testing the completeness and accuracy of certain data used in the allowance for loanestimate, and lease losses, and(v) evaluating the reasonableness of significant assumptions and judgments used by managementcertain qualitative reserves made to estimate the qualitative component ofmodel output results to determine the overall allowance for loan
and lease losses including those judgments related to the impact of concentrations, economic conditions and other considerations.losses. The procedures also included the involvement of professionals with specialized skill and knowledge to assist in evaluating the reasonablenessappropriateness of certain loss forecast models, and methodologies, evaluating the reasonableness of risk ratings used in the allowance for commercial loans,economic forecast scenarios and evaluatingrelated weightings and the reasonableness of certain judgments used by management in estimating the qualitative component of the allowance for loan and lease losses.reserves.
Valuation of Certain Level 3 Financial Instruments
As described in Notes 1 and 2120 to the consolidated financial statements, the Corporation carries certain financial instruments at fair value, which includes $10.3$10.7 billion of assets and $5.9$6.9 billion
of liabilities classified as Level 3 fair value measurements that are valued on a recurring basis and $2.3 billion of assets classified as Level 3 fair value measurements that are valued on a nonrecurring basis, for which the determination of fair value requires significant
management judgment or estimation. The Corporation determines the fair value of certain Level 3 financial instruments using quantitativepricing models, discounted cash flow methodologies, or similar techniques that utilize multiple significant unobservablerequire inputs including long-dated volatility and forward price, as applicable. As disclosed by management, estimation risk is greater for financial instruments that are either option-basedboth unobservable and are significant to the overall fair value measurement. Unobservable inputs, such as volatility or have longer maturity dates where observable market inputs are less readily available, or are unobservable, in which case,price, may be determined using quantitative-based extrapolations are used in determining fair values.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. Thisinstruments, which in turn led to a high degree of auditor judgment, subjectivity and effort in performing procedures and in evaluating audit evidence obtained, including the involvement of professionals with specialized skill and knowledge to assist in evaluating certain audit evidence.knowledge.
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.

capturea01.jpgbac-20211231_g7.jpg

Charlotte, North Carolina
February 19, 202022, 2022

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



89Bank of America88



Bank of America Corporation and Subsidiaries
Consolidated Statement of Income
(In millions, except per share information)202120202019
Net interest income 
Interest income$47,672 $51,585 $71,236 
Interest expense4,738 8,225 22,345 
Net interest income42,934 43,360 48,891 
Noninterest income 
Fees and commissions39,299 34,551 33,015 
Market making and similar activities8,691 8,355 9,034 
Other income(1,811)(738)304 
Total noninterest income46,179 42,168 42,353 
Total revenue, net of interest expense89,113 85,528 91,244 
Provision for credit losses(4,594)11,320 3,590 
Noninterest expense
Compensation and benefits36,140 32,725 31,977 
Occupancy and equipment7,138 7,141 6,588 
Information processing and communications5,769 5,222 4,646 
Product delivery and transaction related3,881 3,433 2,762 
Marketing1,939 1,701 1,934 
Professional fees1,775 1,694 1,597 
Other general operating3,089 3,297 5,396 
Total noninterest expense59,731 55,213 54,900 
Income before income taxes33,976 18,995 32,754 
Income tax expense1,998 1,101 5,324 
Net income$31,978 $17,894 $27,430 
Preferred stock dividends1,421 1,421 1,432 
Net income applicable to common shareholders$30,557 $16,473 $25,998 
Per common share information 
Earnings$3.60 $1.88 $2.77 
Diluted earnings3.57 1.87 2.75 
Average common shares issued and outstanding8,493.3 8,753.2 9,390.5 
Average diluted common shares issued and outstanding8,558.4 8,796.9 9,442.9 
      
Consolidated Statement of Income
    
(In millions, except per share information)2019 2018 2017
Net interest income     
Interest income$71,236
 $66,769
 $57,579
Interest expense22,345
 18,607
 12,340
Net interest income48,891
 48,162
 45,239
      
Noninterest income     
Fees and commissions33,015
 33,078
 33,341
Market making and similar activities9,034
 9,008
 7,102
Other income304
 772
 1,444
Total noninterest income42,353
 42,858
 41,887
Total revenue, net of interest expense91,244
 91,020
 87,126
      
Provision for credit losses3,590
 3,282
 3,396
      
Noninterest expense     
Compensation and benefits31,977
 31,880
 31,931
Occupancy and equipment6,588
 6,380
 6,264
Information processing and communications4,646
 4,555
 4,530
Product delivery and transaction related2,762
 2,857
 3,041
Marketing1,934
 1,674
 1,746
Professional fees1,597
 1,699
 1,888
Other general operating5,396
 4,109
 5,117
Total noninterest expense54,900
 53,154
 54,517
Income before income taxes32,754
 34,584
 29,213
Income tax expense5,324
 6,437
 10,981
Net income$27,430
 $28,147
 $18,232
Preferred stock dividends1,432
 1,451
 1,614
Net income applicable to common shareholders$25,998
 $26,696
 $16,618
      
Per common share information     
Earnings$2.77
 $2.64
 $1.63
Diluted earnings2.75
 2.61
 1.56
Average common shares issued and outstanding9,390.5
 10,096.5
 10,195.6
Average diluted common shares issued and outstanding9,442.9
 10,236.9
 10,778.4
Consolidated Statement of Comprehensive Income
(Dollars in millions)202120202019
Net income$31,978 $17,894 $27,430 
Other comprehensive income (loss), net-of-tax:
Net change in debt securities(2,077)4,799 5,875 
Net change in debit valuation adjustments356 (498)(963)
Net change in derivatives(2,306)826 616 
Employee benefit plan adjustments624 (98)136 
Net change in foreign currency translation adjustments(45)(52)(86)
Other comprehensive income (loss)(3,448)4,977 5,578 
Comprehensive income$28,530 $22,871 $33,008 

      
Consolidated Statement of Comprehensive Income  
      
(Dollars in millions)2019 2018 2017
Net income$27,430
 $28,147
 $18,232
Other comprehensive income (loss), net-of-tax:     
Net change in debt securities5,875
 (3,953) 61
Net change in debit valuation adjustments(963) 749
 (293)
Net change in derivatives616
 (53) 64
Employee benefit plan adjustments136
 (405) 288
Net change in foreign currency translation adjustments(86) (254) 86
Other comprehensive income (loss)5,578
 (3,916) 206
Comprehensive income$33,008
 $24,231
 $18,438

See accompanying Notes to Consolidated Financial Statements.



89Bank of America
















Bank of America Corporation and Subsidiaries
     
Consolidated Balance Sheet
  December 31
(Dollars in millions)2019 2018
Assets 
  
Cash and due from banks$30,152
 $29,063
Interest-bearing deposits with the Federal Reserve, non-U.S. central banks and other banks131,408
 148,341
Cash and cash equivalents161,560
 177,404
Time deposits placed and other short-term investments7,107
 7,494
Federal funds sold and securities borrowed or purchased under agreements to resell
   (includes $50,364 and $56,399 measured at fair value)
274,597
 261,131
Trading account assets (includes $90,946 and $119,363 pledged as collateral)
229,826
 214,348
Derivative assets40,485
 43,725
Debt securities: 
  
Carried at fair value256,467
 238,101
Held-to-maturity, at cost (fair value – $219,821 and $200,435)
215,730
 203,652
Total debt securities472,197

441,753
Loans and leases (includes $8,335 and $4,349 measured at fair value)
983,426
 946,895
Allowance for loan and lease losses(9,416) (9,601)
Loans and leases, net of allowance974,010

937,294
Premises and equipment, net10,561
 9,906
Goodwill68,951
 68,951
Loans held-for-sale (includes $3,709 and $2,942 measured at fair value)
9,158
 10,367
Customer and other receivables55,937
 65,814
Other assets (includes $15,518 and $19,739 measured at fair value)
129,690
 116,320
Total assets$2,434,079

$2,354,507
     
Liabilities 
  
Deposits in U.S. offices: 
  
Noninterest-bearing$403,305
 $412,587
Interest-bearing (includes $508 and $492 measured at fair value)
940,731
 891,636
Deposits in non-U.S. offices:   
Noninterest-bearing13,719
 14,060
Interest-bearing77,048
 63,193
Total deposits1,434,803
 1,381,476
Federal funds purchased and securities loaned or sold under agreements to repurchase
   (includes $16,008 and $28,875 measured at fair value)
165,109
 186,988
Trading account liabilities83,270
 68,220
Derivative liabilities38,229
 37,891
Short-term borrowings (includes $3,941 and $1,648 measured at fair value)
24,204
 20,189
Accrued expenses and other liabilities (includes $15,434 and $20,075 measured at fair value
   and $813 and $797 of reserve for unfunded lending commitments)
182,798
 165,026
Long-term debt (includes $34,975 and $27,689 measured at fair value)
240,856
 229,392
Total liabilities2,169,269
 2,089,182
Commitments and contingencies (Note 7 – Securitizations and Other Variable Interest Entities
   and Note 13 – Commitments and Contingencies)


  
Shareholders’ equity 
  
Preferred stock, $0.01 par value; authorized – 100,000,000 shares; issued and outstanding – 3,887,440 and 3,843,140 shares
23,401
 22,326
Common stock and additional paid-in capital, $0.01 par value; authorized – 12,800,000,000 shares;
   issued and outstanding – 8,836,148,954 and 9,669,286,370 shares
91,723
 118,896
Retained earnings156,319
 136,314
Accumulated other comprehensive income (loss)(6,633) (12,211)
Total shareholders’ equity264,810
 265,325
Total liabilities and shareholders’ equity$2,434,079
 $2,354,507
     
 Assets of consolidated variable interest entities included in total assets above (isolated to settle the liabilities of the variable interest entities)   
 Trading account assets$5,811
 $5,798
 Loans and leases38,837
 43,850
 Allowance for loan and lease losses(807) (912)
 Loans and leases, net of allowance38,030

42,938
 All other assets540
 337
 Total assets of consolidated variable interest entities$44,381
 $49,073
 Liabilities of consolidated variable interest entities included in total liabilities above 
  
 Short-term borrowings$2,175
 $742
 
Long-term debt (includes $8,717 and $10,943 of non-recourse debt)
8,718
 10,944
 
All other liabilities (includes $19 and $27 of non-recourse liabilities)
22
 30
 Total liabilities of consolidated variable interest entities$10,915
 $11,716
See accompanying Notes to Consolidated Financial Statements.

Bank of America 90


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) Shares Amount   
Balance, December 31, 2016$25,220
 10,052.6
 $147,038
 $101,225
 $(7,288) $266,195
Net income 
  
  
 18,232
   18,232
Net change in debt 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) 700.0
 2,933
 (36)   
Common stock issued under employee plans, net, and other  43.3
 932
    
 932
Common stock repurchased  (508.6) (12,814)     (12,814)
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 adjustments        749
 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 other  58.2
 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 income      27,430
   27,430
Net change in debt securities        5,875
 5,875
Net change in debit valuation adjustments        (963) (963)
Net change in derivatives        616
 616
Employee benefit plan adjustments        136
 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 other  123.3
 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
See accompanying Notes to Consolidated Financial Statements.

91Bank of America






Bank of America Corporation and Subsidiaries
      
Consolidated Statement of Cash Flows
      
(Dollars in millions)2019 2018 2017
Operating activities 
  
  
Net income$27,430
 $28,147
 $18,232
Adjustments to reconcile net income to net cash provided by operating activities: 
  
  
Provision for credit losses3,590
 3,282
 3,396
Gains on sales of debt securities(217) (154) (255)
Depreciation and amortization1,729
 2,063
 2,103
Net amortization of premium/discount on debt securities2,066
 1,824
 2,251
Deferred income taxes2,435
 3,041
 8,175
Stock-based compensation1,974
 1,729
 1,649
Impairment of equity method investment2,072
 
 
Loans held-for-sale:     
Originations and purchases(28,874) (28,071) (43,506)
Proceeds from sales and paydowns of loans originally classified as held for sale and instruments
from related securitization activities
30,191
 28,972
 40,548
Net change in:     
Trading and derivative assets/liabilities7,920
 (23,673) (14,663)
Other assets(11,113) 11,920
 (20,090)
Accrued expenses and other liabilities16,363
 13,010
 4,673
Other operating activities, net6,211
 (2,570) 7,351
Net cash provided by operating activities61,777
 39,520
 9,864
Investing activities 
  
  
Net change in:     
Time deposits placed and other short-term investments387
 3,659
 (1,292)
Federal funds sold and securities borrowed or purchased under agreements to resell(13,466) (48,384) (14,523)
Debt securities carried at fair value:     
Proceeds from sales52,006
 5,117
 73,353
Proceeds from paydowns and maturities79,114
 78,513
 93,874
Purchases(152,782) (76,640) (166,975)
Held-to-maturity debt securities:     
Proceeds from paydowns and maturities34,770
 18,789
 16,653
Purchases(37,115) (35,980) (25,088)
Loans and leases:     
Proceeds from sales of loans originally classified as held for investment and instruments
from related securitization activities
12,201
 21,365
 11,996
Purchases(5,963) (4,629) (6,846)
Other changes in loans and leases, net(46,808) (31,292) (41,104)
Other investing activities, net(2,974) (1,986) 8,411
Net cash used in investing activities(80,630) (71,468) (51,541)
Financing activities 
  
  
Net change in:     
Deposits53,327
 71,931
 48,611
Federal funds purchased and securities loaned or sold under agreements to repurchase(21,879) 10,070
 7,024
Short-term borrowings4,004
 (12,478) 8,538
Long-term debt:     
Proceeds from issuance52,420
 64,278
 53,486
Retirement(50,794) (53,046) (49,480)
Preferred stock:     
Proceeds from issuance3,643
 4,515
 
Redemption(2,568) (4,512) 
Common stock repurchased(28,144) (20,094) (12,814)
Cash dividends paid(5,934) (6,895) (5,700)
Other financing activities, net(698) (651) (397)
Net cash provided by financing activities3,377
 53,118
 49,268
Effect of exchange rate changes on cash and cash equivalents(368) (1,200) 2,105
Net increase (decrease) in cash and cash equivalents(15,844) 19,970
 9,696
Cash and cash equivalents at January 1177,404
 157,434
 147,738
Cash and cash equivalents at December 31$161,560
 $177,404
 $157,434
Supplemental cash flow disclosures     
Interest paid$22,196
 $19,087
 $12,852
Income taxes paid, net4,359
 2,470
 3,235

See accompanying Notes to Consolidated Financial Statements.
Bank of America 90


Bank of America Corporation and Subsidiaries
Consolidated Balance Sheet
December 31
(Dollars in millions)20212020
Assets
Cash and due from banks$29,222 $36,430 
Interest-bearing deposits with the Federal Reserve, non-U.S. central banks and other banks318,999 344,033 
Cash and cash equivalents348,221 380,463 
Time deposits placed and other short-term investments7,144 6,546 
Federal funds sold and securities borrowed or purchased under agreements to resell
   (includes $150,665 and $108,856 measured at fair value)
250,720 304,058 
Trading account assets (includes $103,434 and $91,510 pledged as collateral)
247,080 198,854 
Derivative assets35,344 47,179 
Debt securities: 
Carried at fair value308,073 246,601 
Held-to-maturity, at cost (fair value – $665,890 and $448,180)
674,554 438,249 
Total debt securities982,627 684,850 
Loans and leases (includes $7,819 and $6,681 measured at fair value)
979,124 927,861 
Allowance for loan and lease losses(12,387)(18,802)
Loans and leases, net of allowance966,737 909,059 
Premises and equipment, net10,833 11,000 
Goodwill69,022 68,951 
Loans held-for-sale (includes $4,455 and $1,585 measured at fair value)
15,635 9,243 
Customer and other receivables72,263 64,221 
Other assets (includes $12,144 and $15,718 measured at fair value)
163,869 135,203 
Total assets$3,169,495 $2,819,627 
Liabilities  
Deposits in U.S. offices:  
Noninterest-bearing$784,189 $650,674 
Interest-bearing (includes $408 and $481 measured at fair value)
1,165,914 1,038,341 
Deposits in non-U.S. offices:
Noninterest-bearing27,457 17,698 
Interest-bearing86,886 88,767 
Total deposits2,064,446 1,795,480 
Federal funds purchased and securities loaned or sold under agreements to repurchase
   (includes $139,641 and $135,391 measured at fair value)
192,329 170,323 
Trading account liabilities100,690 71,320 
Derivative liabilities37,675 45,526 
Short-term borrowings (includes $4,279 and $5,874 measured at fair value)
23,753 19,321 
Accrued expenses and other liabilities (includes $11,489 and $16,311 measured at fair value
   and $1,456 and $1,878 of reserve for unfunded lending commitments)
200,419 181,799 
Long-term debt (includes $29,708 and $32,200 measured at fair value)
280,117 262,934 
Total liabilities2,899,429 2,546,703 
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 – 3,939,686 and 3,931,440 shares
24,708 24,510 
Common stock and additional paid-in capital, $0.01  par value; authorized – 12,800,000,000 shares;
   issued and outstanding – 8,077,831,463 and 8,650,814,105 shares
62,398 85,982 
Retained earnings188,064 164,088 
Accumulated other comprehensive income (loss)(5,104)(1,656)
Total shareholders’ equity270,066 272,924 
Total liabilities and shareholders’ equity$3,169,495 $2,819,627 
Assets of consolidated variable interest entities included in total assets above (isolated to settle the liabilities of the variable interest entities)
Trading account assets$5,004 $5,225 
Loans and leases17,135 23,636 
Allowance for loan and lease losses(958)(1,693)
Loans and leases, net of allowance16,177 21,943 
All other assets189 1,387 
Total assets of consolidated variable interest entities$21,370 $28,555 
Liabilities of consolidated variable interest entities included in total liabilities above  
Short-term borrowings (includes $51 and $22 of non-recourse short-term borrowings)
$247 $454 
Long-term debt (includes $3,587 and $7,053 of non-recourse debt)
3,587 7,053 
All other liabilities (includes $7 and $16 of non-recourse liabilities)
7 16 
Total liabilities of consolidated variable interest entities$3,841 $7,523 
See accompanying Notes to Consolidated Financial Statements.
91 Bank of America


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, 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 
Net income31,978 31,978 
Net change in debt securities(2,077)(2,077)
Net change in debit valuation adjustments356 356 
Net change in derivatives(2,306)(2,306)
Employee benefit plan adjustments624 624 
Net change in foreign currency translation adjustments(45)(45)
Dividends declared:
Common(6,575)(6,575)
Preferred(1,421)(1,421)
Issuance of preferred stock2,169 2,169 
Redemption of preferred stock(1,971)(1,971)
Common stock issued under employee plans, net, and other42.3 1,542 (6)1,536 
Common stock repurchased(615.3)(25,126)(25,126)
Balance, December 31, 2021$24,708 8,077.8 $62,398 $188,064 $(5,104)$270,066 













See accompanying Notes to Consolidated Financial Statements.
Bank of America 92


Bank of America Corporation and Subsidiaries
Consolidated Statement of Cash Flows
(Dollars in millions)202120202019
Operating activities   
Net income$31,978 $17,894 $27,430 
Adjustments to reconcile net income to net cash provided by operating activities:   
Provision for credit losses(4,594)11,320 3,590 
Gains on sales of debt securities(22)(411)(217)
Depreciation and amortization1,898 1,843 1,729 
Net amortization of premium/discount on debt securities5,837 4,101 2,066 
Deferred income taxes(838)(1,737)2,435 
Stock-based compensation2,768 2,031 1,974 
Impairment of equity method investment  2,072 
Loans held-for-sale:
Originations and purchases(43,635)(19,657)(28,874)
Proceeds from sales and paydowns of loans originally classified as held for sale and instruments
from related securitization activities
34,684 19,049 30,191 
Net change in:
Trading and derivative assets/liabilities(22,104)16,942 7,920 
Other assets(34,455)(12,883)(11,113)
Accrued expenses and other liabilities16,639 (4,385)16,363 
Other operating activities, net4,651 3,886 6,211 
Net cash provided by (used in) operating activities(7,193)37,993 61,777 
Investing activities   
Net change in:
Time deposits placed and other short-term investments(598)561 387 
Federal funds sold and securities borrowed or purchased under agreements to resell53,338 (29,461)(13,466)
Debt securities carried at fair value:
Proceeds from sales6,893 77,524 52,006 
Proceeds from paydowns and maturities159,616 91,084 79,114 
Purchases(238,398)(194,877)(152,782)
Held-to-maturity debt securities:
Proceeds from paydowns and maturities124,880 93,835 34,770 
Purchases(362,736)(257,535)(37,115)
Loans and leases:
Proceeds from sales of loans originally classified as held for investment and instruments
from related securitization activities
10,396 13,351 12,201 
Purchases(5,164)(5,229)(5,963)
Other changes in loans and leases, net(58,039)36,571 (46,808)
Other investing activities, net(3,479)(3,489)(2,974)
Net cash used in investing activities(313,291)(177,665)(80,630)
Financing activities   
Net change in:
Deposits268,966 360,677 53,327 
Federal funds purchased and securities loaned or sold under agreements to repurchase22,006 5,214 (21,879)
Short-term borrowings4,432 (4,893)4,004 
Long-term debt:
Proceeds from issuance76,675 57,013 52,420 
Retirement(46,826)(47,948)(50,794)
Preferred stock:
Proceeds from issuance2,169 2,181 3,643 
Redemption(1,971)(1,072)(2,568)
Common stock repurchased(25,126)(7,025)(28,144)
Cash dividends paid(8,055)(7,727)(5,934)
Other financing activities, net(620)(601)(698)
Net cash provided by financing activities291,650 355,819 3,377 
Effect of exchange rate changes on cash and cash equivalents(3,408)2,756 (368)
Net increase (decrease) in cash and cash equivalents(32,242)218,903 (15,844)
Cash and cash equivalents at January 1380,463 161,560 177,404 
Cash and cash equivalents at December 31$348,221 $380,463 $161,560 
Supplemental cash flow disclosures
Interest paid$4,506 $8,662 $22,196 
Income taxes paid, net2,760 2,894 4,359 
See accompanying Notes to Consolidated Financial Statements.
93 Bank of America


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, which include the Corporation’s interests in affordable housing and renewable energy partnerships, are includedrecorded 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-periodcurrent period presentation.
In the Consolidated Statement of Income, amounts related to certain asset and liability management (ALM) activities have been reclassified from other income to market making and similar activities, which was previously referred to as trading account income. All prior periods presented reflect this change, which has no impact on the Corporation's total noninterest income or net income, and has no impact on business segment results. The amounts included in market making and similar activities related to this change in presentation are increases of $930 million, $1.1 billion and $332 million for 2019, 2018 and 2017, respectively.
New Accounting Standards
Lease Accounting
On January 1, 2019, the Corporation adopted the new accounting standards that require lessees to recognize operating leases on the balance sheet as right-of-use assets and lease liabilities based on the value of the discounted future lease payments. Lessor accounting is largely unchanged. Expanded disclosures about the nature and terms of lease agreements are required prospectively and are included in Note 9 – Leases. The Corporation elected to retain prior determinations of whether an existing contract contains a lease and how the lease should be classified. The Corporation elected to recognize leases existing on January 1, 2019 through a cumulative-effect adjustment which increased retained earnings by $165 million, with no adjustment to prior periods presented. Upon adoption, the Corporation also recognized right-of-use assets and lease liabilities of $9.7 billion.
Adoption of the standards did not have a significant effect on the Corporation’s regulatory capital measures.
Accounting for Financial Instruments -- Credit Losses
On January 1, 2020, the Corporation adopted the new accounting standard that requires the measurement of the allowance for credit losses to be based on management’s best estimate of lifetime expected credit losses inherent in the Corporation’s relevant financial assets. The Corporation’s lifetime expected credit losses are determined using macroeconomic forecast assumptions and management judgments applicable to and through the expected life of the loan portfolios, and are net of expected recoveries on loans that were previously charged off. The standard also expands credit quality disclosures beginning in the first quarter of 2020. While the standard changes the measurement of the allowance for credit losses, it does not change the Corporation’s credit risk of its lending portfolios or the ultimate losses in those portfolios. Upon adoption of the standard on January 1, 2020, the Corporation recorded a $3.3 billion, or 32 percent, increase to the allowance for credit losses. After adjusting for deferred taxes and other adoption effects, a $2.4 billion decrease was recorded in retained earnings through a cumulative-effect adjustment.
Significant Accounting Principles
Cash and Cash Equivalents
Cash and cash equivalents include cash on hand, cash items in the process of collection, cash segregated under federal and other brokerage regulations, and amounts due from correspondent banks, the Federal Reserve Bank and certain non-U.S. central banks. Certain cash balances are restricted as to withdrawal or usage by legally binding contractual agreements or regulatory requirements.
Securities Financing Agreements
Securities borrowed or purchased under agreements to resell and securities loaned or sold under agreements to repurchase (securities financing agreements) are treated as collateralized financing transactions except in instances where the transaction is required to be accounted for as individual sale and purchase transactions. Generally, these agreements are recorded at acquisition or sale price plus accrued interest. In instances where the interest except for certain securities financing agreements thatis negative, the Corporation accounts for under the fair value option. Changes in the fair value ofCorporation’s policy is to present negative interest on financial assets as interest income and negative interest on financial liabilities as interest expense. For securities financing agreements that are accounted for under the fair value option, the changes in the fair value of these securities financing agreements 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, 20192021 and 2018,2020, the fair value of this collateral was $693.0$854.8 billion and $599.0$812.4 billion, of which $593.8$782.7 billion and $508.6

93Bank of America






$758.5 billion were sold or repledged. The primary source of this collateral is securities borrowed or purchased under agreements to resell.
The Corporation also pledges company-owned securities and loans as collateral in transactions that include repurchase agreements, securities loaned, public and trust deposits, U.S. Treasury tax and loan notes, and short-term borrowings. This collateral, which in some cases can be sold or repledged by the counterparties to the transactions, is parenthetically disclosed on the Consolidated Balance Sheet.
In certain cases, the Corporation has transferred assets to consolidated VIEs where those restricted assets serve as collateral for the interests issued by the VIEs. These assets are included on the Consolidated Balance Sheet in Assets of Consolidated VIEs.
In addition, the Corporation obtains collateral in connection with its derivative contracts. Required collateral levels vary depending on the credit risk rating and the type of counterparty. Generally, the Corporation accepts collateral in the form of cash, U.S. Treasury securities and other marketable securities. Based on provisions contained in master netting agreements, the Corporation nets cash collateral received against derivative assets. The Corporation also pledges collateral on its own derivative positions which can be applied against derivative liabilities.
Trading Instruments
Financial instruments utilized in trading activities are carried at fair value. Fair value is generally based on quoted market prices for the same or similar assets and liabilities. If these market prices are not available, fair values are estimated based on dealer quotes, pricing models, discounted cash flow methodologies, or similar techniques where the determination of fair value may require significant management judgment or estimation. Realized gains and losses are recorded on a trade-date basis. Realized and unrealized gains and losses are recognized in market making and similar activities.
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
Bank of America 94


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- basedmarket-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 DerivativesAllowance for Credit Losses
The allowance for credit losses decreased $6.8 billion from December 31, 2020 to $13.8 billion at December 31, 2021, which included a $3.8 billion reserve decrease related to the commercial portfolio and Othera $3.1 billion reserve decrease related
to the consumer portfolio. The decreases were primarily driven by improvements in the macroeconomic outlook and credit quality.
Table 41 presents an allocation of the allowance for credit losses by product type at December 31, 2021and 2020.
Table 41Allocation 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)
(Dollars in millions)December 31, 2021December 31, 2020
Allowance for loan and lease losses      
Residential mortgage$351 2.83 %0.16 %$459 2.44 %0.21 %
Home equity206 1.66 0.74 399 2.12 1.16 
Credit card5,907 47.70 7.25 8,420 44.79 10.70 
Direct/Indirect consumer523 4.22 0.51 752 4.00 0.82 
Other consumer46 0.37 n/m41 0.22 n/m
Total consumer7,033 56.78 1.62 10,071 53.57 2.35 
U.S. commercial (2)
3,019 24.37 0.87 5,043 26.82 1.55 
Non-U.S. commercial975 7.87 0.86 1,241 6.60 1.37 
Commercial real estate1,292 10.43 2.05 2,285 12.15 3.79 
Commercial lease financing68 0.55 0.46 162 0.86 0.95 
Total commercial5,354 43.22 1.00 8,731 46.43 1.77 
Allowance for loan and lease losses12,387 100.00 %1.28 18,802 100.00 %2.04 
Reserve for unfunded lending commitments1,456 1,878  
Allowance for credit losses$13,843 $20,680 
(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.
(2)Includes allowance for loan and lease losses for U.S. small business commercial loans of $1.2 billion and $1.5 billion at December 31, 2021 and 2020.
n/m = not meaningful
Net charge-offs for 2021 were $2.2 billion compared to $4.1 billion in 2020 driven by decreases across most products. The provision for credit losses decreased $15.9 billion to a $4.6 billion benefit during 2021 compared to 2020. The allowance for credit losses had a reserve release of $6.8 billion for 2021, primarily driven by improvements in the macroeconomic outlook and credit quality. The provision for credit losses for the consumer portfolio, including unfunded lending commitments, decreased $6.1 billion to a benefit of $1.2 billion during 2021 compared to 2020. The provision for credit losses for the
commercial portfolio, including unfunded lending commitments, decreased $9.8 billion to a $3.4 billion benefit for 2021 compared to 2020.
Table 42 presents a rollforward of the allowance for credit losses, including certain loan and allowance ratios for 2021 and 2020. 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.
73 Bank of America


Table 42Allowance for Credit Losses
(Dollars in millions)20212020
Allowance for loan and lease losses, January 1$18,802 $12,358 
Loans and leases charged off
Residential mortgage(34)(40)
Home equity(44)(58)
Credit card(2,411)(2,967)
Direct/Indirect consumer(297)(372)
Other consumer(292)(307)
Total consumer charge-offs(3,078)(3,744)
U.S. commercial (1)
(626)(1,163)
Non-U.S. commercial(47)(168)
Commercial real estate(46)(275)
Commercial lease financing (69)
Total commercial charge-offs(719)(1,675)
Total loans and leases charged off(3,797)(5,419)
Recoveries of loans and leases previously charged off
Residential mortgage62 70 
Home equity163 131 
Credit card688 618 
Direct/Indirect consumer296 250 
Other consumer22 23 
Total consumer recoveries1,231 1,092 
U.S. commercial (2)
298 178 
Non-U.S. commercial12 13 
Commercial real estate12 
Commercial lease financing1 10 
Total commercial recoveries323 206 
Total recoveries of loans and leases previously charged off1,554 1,298 
Net charge-offs(2,243)(4,121)
Provision for loan and lease losses(4,173)10,565 
Other1 — 
Allowance for loan and lease losses, December 3112,387 18,802 
Reserve for unfunded lending commitments, January 11,878 1,123 
Provision for unfunded lending commitments(421)755 
Other(1)— 
Reserve for unfunded lending commitments, December 311,456 1,878 
Allowance for credit losses, December 31$13,843 $20,680 
Loan and allowance ratios (3) :
Loans and leases outstanding at December 31$971,305 $921,180 
Allowance for loan and lease losses as a percentage of total loans and leases outstanding at December 311.28 %2.04 %
Consumer allowance for loan and lease losses as a percentage of total consumer loans and leases outstanding at December 311.62 2.35 
Commercial allowance for loan and lease losses as a percentage of total commercial loans and leases outstanding at December 311.00 1.77 
Average loans and leases outstanding$913,354 $974,281 
Annualized net charge-offs as a percentage of average loans and leases outstanding0.25 %0.42 %
Allowance for loan and lease losses as a percentage of total nonperforming loans and leases at December 31271 380 
Ratio of the allowance for loan and lease losses at December 31 to net charge-offs5.52 4.56 
Amounts included in allowance for loan and lease losses for loans and leases that are excluded from nonperforming loans and leases at December 31 (4)
$7,027 $9,854 
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 (4)
117 %181 %
(1)Includes U.S. small business commercial charge-offs of $425 million in 2021 compared to $321 million in 2020.
(2)Includes U.S. small business commercial recoveries of $74 million for 2021 compared to $54 million in 2020.
(3)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.
(4)Primarily includes amounts related to credit card and unsecured consumer lending portfolios in Consumer Banking.
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Market Risk Management
Market risk is the risk that changes in market conditions may adversely impact the value of assets or liabilities, or otherwise negatively impact earnings. This risk is inherent in the financial instruments associated with our operations, primarily within our Global Markets segment. We are also exposed to these risks in other areas of the Corporation (e.g., our ALM activities). In the event of market stress, these risks could have a material impact on our results. For more information, see Interest Rate Risk Management Activitiesfor the Banking Book on page 79.
DerivativesWe have been affected, and may continue to be affected, by market stress resulting from the pandemic that began in the first quarter of 2020. For more information, see Part 1. Item 1A. Risk Factors – Coronavirus Disease on page 8.
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 80.
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 49.
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 43 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.
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In addition, Table 43 presents our fair value option portfolio, which includes substantially all of the funded and unfunded exposures for which we elect the fair value option, and their corresponding hedges. Additionally, market risk VaR for trading activities as presented in Table 43 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 43 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 43 presents year-end, average, high and low daily trading VaR for 2021 and 2020 using a 99 percent confidence level. The amounts disclosed in Table 43 and Table 44 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 decreased for 2021 compared to 2020 primarily due to an increase in diversification across asset classes.
Table 43Market Risk VaR for Trading Activities
20212020
(Dollars in millions)Year
End
Average
High (1)
Low (1)
Year
End
Average
High (1)
Low (1)
Foreign exchange$11 $12 $21 $5 $$$25 $
Interest rate54 40 80 16 30 19 39 
Credit73 69 84 53 79 58 91 25 
Equity21 24 35 19 20 24 162 12 
Commodities6 8 28 4 12 
Portfolio diversification(114)(100)  (72)(61)— — 
Total covered positions portfolio51 53 85 34 69 53 171 27 
Impact from less liquid exposures (2)
8 20   52 27 — — 
Total covered positions and less liquid trading positions portfolio59 73 125 46 121 80 169 30 
Fair value option loans51 50 65 31 52 52 84 
Fair value option hedges15 16 20 11 11 13 17 
Fair value option portfolio diversification(27)(32)  (17)(24)— — 
Total fair value option portfolio39 34 53 23 46 41 86 
Portfolio diversification(24)(10)  (4)(15)— — 
Total market-based portfolio$74 $97 169 54 $163 $106 171 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.
(2)Impact is net of diversification effects between the covered positions and less liquid trading positions portfolios.
The graph below presents the daily covered positions and less liquid trading positions portfolio VaR for 2021, corresponding to the data in Table 43.

bac-20211231_g3.jpg
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Additional VaR statistics produced within our single VaR model are provided in Table 44 at the same level of detail as in Table 43. 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 44 presents average trading VaR statistics at 99 percent and 95 percent confidence levels for 2021 and 2020.
Table 44Average Market Risk VaR for Trading Activities – 99 percent and 95 percent VaR Statistics
20212020
(Dollars in millions)99 percent95 percent99 percent95 percent
Foreign exchange$12 $8 $$
Interest rate40 20 19 
Credit69 21 58 18 
Equity24 12 24 13 
Commodities8 4 
Portfolio diversification(100)(39)(61)(26)
Total covered positions portfolio53 26 53 21 
Impact from less liquid exposures20 2 27 
Total covered positions and less liquid trading positions portfolio73 28 80 23 
Fair value option loans50 12 52 13 
Fair value option hedges16 9 13 
Fair value option portfolio diversification(32)(9)(24)(8)
Total fair value option portfolio34 12 41 12 
Portfolio diversification(10)(7)(15)(6)
Total market-based portfolio$97 $33 $106 $29 
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 2021, there were two 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 2021 and 2020. During 2021, positive trading-related revenue was recorded for 97 percent of the trading days, of which 80 percent were daily trading gains of over $25 million, and the largest loss was $45 million. This compares to 2020 where 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.
bac-20211231_g4.jpg

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Trading Portfolio Stress Testing
Because the very nature of a VaR model suggests results can exceed our estimates and it is dependent on a limited historical window, we also stress test our portfolio using scenario analysis. This analysis estimates the change in the value of our trading portfolio that may result from abnormal market movements.
A set of scenarios, categorized as either historical or hypothetical, are computed daily for the overall trading portfolio and individual businesses. These scenarios include shocks to underlying market risk factors that may be well beyond the shocks found in the historical data used to calculate VaR. Historical scenarios simulate the impact of the market moves that occurred during a period of extended historical market stress. Generally, a multi-week period representing the most severe point during a crisis is selected for each historical scenario. Hypothetical scenarios provide estimated portfolio impacts from potential future market stress events. Scenarios are reviewed and updated in response to changing positions and new economic or political information. In addition, new or ad hoc scenarios are developed to address specific potential market events or particular vulnerabilities in the portfolio. The stress tests are reviewed on a regular basis and the results are presented to senior management.
Stress testing for the trading portfolio is integrated with enterprise-wide stress testing and incorporated into the limits framework. The macroeconomic scenarios used for enterprise-wide stress testing purposes differ from the typical trading portfolio scenarios in that they have a longer time horizon and the results are forecasted over multiple periods for use in consolidated capital and liquidity planning. For more information, see Managing Risk on page 46.
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 45 presents the spot and 12-month forward rates used in our baseline forecasts at December 31, 2021 and 2020.
Table 45Forward Rates
December 31, 2021
 Federal
Funds
Three-month
LIBOR
10-Year
Swap
Spot rates0.25 %0.21 %1.58 %
12-month forward rates1.00 1.07 1.84 
December 31, 2020
Spot rates0.25 %0.24 %0.93 %
12-month forward rates0.25 0.19 1.06 
Table 46 shows the pretax impact to forecasted net interest income over the next 12 months from December 31, 2021 and 2020 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 2021, the overall decrease in asset sensitivity of our balance sheet to Up-rate and Down-rate scenarios was primarily due to ALM activity and an increase in long-end rates. 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 50.
Table 46Estimated Banking Book Net Interest Income Sensitivity to Curve Changes
Short
Rate (bps)
Long
Rate (bps)
December 31
(Dollars in millions)20212020
Parallel Shifts
+100 bps
instantaneous shift
+100+100$6,542 $10,468 
-25 bps
instantaneous shift
-25 -25 (2,092)(2,766)
Flatteners  
Short-end
instantaneous change
+100— 4,982 6,321 
Long-end
instantaneous change
— -25 (735)(1,686)
Steepeners  
Short-end
instantaneous change
-25 — (1,344)(1,084)
Long-end
instantaneous change
— +1001,646 4,333 
The sensitivity analysis in Table 46 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 46 assumes no change in
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deposit portfolio size or mix from the baseline forecast in alternate rate environments. In higher rate scenarios, any customer activity resulting in the replacement of low-cost or noninterest-bearing deposits with higher yielding deposits or market-based funding would reduce our benefit in those scenarios.
Interest Rate and Foreign Exchange Derivative Contracts
We use interest rate and foreign exchange derivative contracts in our ALM activities to manage our interest rate and foreign exchange risks. Specifically, we use those derivatives to manage both the variability in cash flows and changes in fair value of various assets and liabilities arising from those risks. Our interest rate derivative contracts are generally non-leveraged swaps tied to various benchmark interest rates and foreign exchange basis swaps, options, futures and forwards, and our foreign exchange contracts include cross-currency interest rate swaps, foreign currency futures contracts, foreign currency forward contracts and options.
The derivatives used in our ALM activities can be split into two broad categories: designated accounting hedges and other risk management derivatives. Designated accounting hedges are primarily used to manage our exposure to interest rates as described in the Interest Rate Risk Management for the Banking Book section and are included in the sensitivities presented in Table 46. The Corporation also uses foreign currency derivatives in accounting hedges to manage substantially all of the foreign exchange risk of our foreign operations. By hedging the foreign exchange risk of our foreign operations, the Corporation's market risk exposure in this area is insignificant.
Risk management derivatives are predominantly used to hedge foreign exchange risks related to various foreign currency-denominated assets and liabilities and eliminate substantially all foreign currency exposures in the cash flows of the Corporation’s non-trading foreign currency-denominated financial instruments. These foreign exchange derivatives are sensitive to other market risk exposures such as cross-currency basis spreads and interest rate risk. However, as these features are not a significant component of these foreign exchange derivatives, the market risk related to this exposure is insignificant. For more information on the accounting for derivatives, see Note 3 – Derivatives to the Consolidated Financial Statements.
Mortgage Banking Risk Management
We originate, fund and service mortgage loans, which subject us to credit, liquidity and interest rate risks, among others. We determine whether loans will be held for investment or held for sale at the time of commitment and manage credit and liquidity risks by selling or securitizing a portion of the loans we originate.
Interest rate risk and market risk can be substantial in the mortgage business. Changes in interest rates and other market factors impact the volume of mortgage originations. Changes in interest rates also impact the value of interest rate lock commitments (IRLCs) and the related residential first mortgage LHFS between the date of the IRLC and the date the loans are
sold to the secondary market. An increase in mortgage interest rates typically leads to a decrease in the value of these instruments. Conversely, when there is an increase in interest rates, the value of the MSRs will increase driven by lower prepayment expectations. Because the interest rate risks of these hedged items offset, we combine them into one overall hedged item with one combined economic hedge portfolio consisting of derivative contracts and securities.
During 2021, 2020 and 2019, we recorded gains of $39 million, $321 million and $291 million. 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). We are subject to comprehensive regulation under federal and state laws, rules and regulations in the U.S. and the laws of the various jurisdictions in which we operate, including those related to financial crimes and anti-money laundering, market conduct, trading activities, fair lending, privacy, data protection and unfair, deceptive or abusive acts or practices.
Operational risk is the risk of loss resulting from inadequate or failed processes or systems, people or external events, and includes legal risk. Operational risk may occur anywhere in the Corporation, including third-party business processes, and is not limited to operations functions. The Corporation faces a number of key operational risks including third-party risk, model risk, conduct risk, technology risk, information security risk and data risk. Operational risk can result in financial losses and reputational impacts and 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 49.
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 and 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. Collectively, these efforts are important to strengthen their compliance and operational resiliency, which is the ability to deliver critical operations through disruption.

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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 GRM, works with Global Compliance and Operational Risk, the FLUs and control functions in the identification of testing needs and test design, and is accountable for test execution, reporting and analysis of results. Corporate Audit provides an 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 and reflect Global Compliance and Operational Risk’s responsibilities for conducting independent oversight of the Corporation’s compliance and operational risk management activities. The Board provides oversight of compliance risk through its Audit Committee and the ERC, and operational risk through its 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' operations, systems or data. The Corporation seeks to mitigate information security risk and associated reputational and compliance risk by employing a multi-layered and intelligence-led Global Information Security Program, which is focused on preparing for, preventing, detecting, mitigating, responding to and recovering from cyber threats and incidents and ensuring the Corporation’s processes operate effectively and mitigate the aforementioned risks.
The Global Information Security Program is supported by three lines of defense. The Global Information Security Team within the first line of defense is responsible for the day-to-day management of the Global Information Security Program, which includes defining policies and procedures to safeguard the Corporation’s information systems and data, conducting vulnerability and third-party information security assessments, information security event management (e.g., responding to ransomware and distributed denial of service attacks), evaluation of external cyber intelligence, supporting industry cybersecurity efforts and working with governmental agencies, as well as developing employee training to support adherence to the Corporation’s policies and procedures. As the second line of defense, Global Compliance and Operational Risk independently assesses, monitors and tests information security risk across the Corporation as well as the effectiveness of the Global Information Security Program. Corporate Audit serves as the third line of defense, conducting additional independent review and validation of the first line processes and functions.

Through established governance structures, we have processes to help facilitate appropriate and effective oversight of information security risk. These routines enable our three lines of defense and management to debate information security risks and monitor control performance to allow for further escalation to executive management, management and Board-level committees or to the Board, as appropriate. The Board is actively engaged in the oversight of Bank of America’s Global Information Security Program, primarily through the ERC.
Reputational Risk Management
Reputational risk is the risk that negative perception of the Corporation may adversely impact 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 embedded throughout its business and risk management processes. We proactively monitor and identify potential reputational risk events and have processes established to mitigate reputational risks in a timely manner. 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. 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 Legal and Risk, that is responsible for the oversight of reputational risk, including 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 rising average global temperatures and sea-level rise. 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. These risks can impact both financial and nonfinancial risk types. The impacts of transition risk can lead to and amplify credit risk or market risk by reducing our customers’ operating income or the value of their assets as well as expose us to reputational and/or litigation risk due to increased regulatory scrutiny or negative public sentiment. Physical risk can lead to increased credit risk by diminishing borrowers’ repayment capacity or impacting the value of collateral. In addition, it could pose increased operational risk to our facilities and people.

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Effective management of climate risk requires coordinated governance, clearly defined roles and responsibilities and well-developed processes to identify, measure, monitor and control risks. We continue to build out and enhance our climate risk management capabilities. 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. Our Environmental and Social Risk Policy Framework (ESRPF) aligns with our Risk Framework and provides additional clarity and transparency regarding our approach to environmental and social risks, inclusive of climate risk.
Our governance framework establishes oversight of climate risk practices and strategies by the Board, supported by its Corporate Governance, ESG, and Sustainability Committee and ERC, as well as the MRC and the Global ESG Committee, both of which are management-level committees comprised of senior leaders across every major FLU and control function.
Our climate risk management efforts are overseen by the Global Climate Risk Executive who reports to the CRO. The Global Climate Risk Executive chairs the Climate Risk Steering Council, which meets monthly and shapes our approach to managing climate-related risks in line with our Risk Framework.
As outlined in our ESRPF, we are focused on supporting and financing areas critical to the transition to a low-carbon economy. Accordingly, we have a goal, publicly announced in early 2021, to achieve net zero greenhouse gas emissions in our financing activities, operations and supply chain before 2050 (Net Zero Goal). More broadly, achieving this goal will require technological advances, clearly defined roadmaps for industry sectors, public policies, and better emissions data reporting, as well as ongoing, strong and active engagement with clients, suppliers, investors, government officials and other stakeholders.
Our progress towards achieving our Net Zero Goal is based on establishing the baseline for emissions associated with our financing activities often referred to as financed emissions. Currently, we are using the Partnership for Carbon Accounting Financials methodology to assess our financed emissions. Additionally, given the urgency required to address climate change, we helped to launch the Net Zero Banking Alliance (NZBA) in April 2021, which outlines guidelines for banks to achieve net zero greenhouse gas emissions including requirements for setting interim targets. As a member of NZBA, the Corporation and more than 100 other financial institution members representing more than 40 percent of the world’s banking assets, have committed to set emission reduction targets for 2030. We plan to begin disclosure of financed emissions by 2023, and set 2030 targets for the significant majority of emissions in our portfolio.
In 2021, we also announced a goal to deploy $1 trillion by 2030 to accelerate the transition to a low-carbon, sustainable economy by providing lending, capital raising, advisory and investment services, and by developing other client-driven financial solutions. This commitment anchors a broader $1.5
trillion sustainable finance goal to support both environmental transition and social inclusive development, which spans business activities across the globe. These goals are intended to help drive business opportunities and enhance risk management related to the transition to a low-carbon economy.
For more information about climate risk, see the Bank of America website. For more information about the Corporation’s climate-related goals and commitments, including emissions associated with our operations and supply chain and progress on our sustainable finance goals, see the Corporation’s 2021 Annual Report to shareholders that will be available on the Investor Relations portion of our website in March 2022. The contents of the Corporation’s website and 2021 Annual Report to shareholders are not incorporated by reference into this Annual Report on Form 10-K.
The foregoing discussion and our discussion in the 2021 Annual Report to shareholders regarding our goals and commitments with respect to climate risk management, including environmental transition considerations, include “forward-looking statements” within the meaning of the Private Securities Litigation Reform Act of 1995. 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.
Complex Accounting Estimates
Our significant accounting principles, as described in Note 1 – Summary of Significant Accounting Principles to the Consolidated Financial Statements, are essential in understanding the MD&A. Many of our significant accounting principles require complex judgments to estimate the values of assets and liabilities. We have procedures and processes in place to facilitate making these judgments.
The more judgmental estimates are summarized in the following discussion. We have identified and described the development of the variables most important in the estimation processes that involve mathematical models to derive the estimates. In many cases, there are numerous alternative judgments that could be used in the process of determining the inputs to the models. Where alternatives exist, we have used the factors that we believe represent the most reasonable value in developing the inputs. Actual performance that differs from our estimates of the key variables could materially impact our results of operations. Separate from the possible future impact to our results of operations from input and model variables, the value of our lending portfolio and market-sensitive assets and liabilities may change subsequent to the balance sheet date, often significantly, due to the nature and magnitude of future credit and market conditions. Such credit and market conditions may change quickly and in unforeseen ways and the resulting volatility could have a significant, negative effect on future operating results. These fluctuations would not be indicative of deficiencies in our models or inputs.

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Allowance for Credit Losses
The allowance for credit losses includes the allowance for loan and lease losses and the reserve for unfunded lending commitments. Our process for determining the allowance for credit losses is discussed in Note 1 – Summary of Significant Accounting Principlesand Note 5 – Outstanding Loans and Leases and Allowance for Credit Losses to the Consolidated Financial Statements.
The determination of allowance for credit losses is based on numerous estimates and assumptions, which require a high degree of judgment and are often interrelated. A critical judgment in the process is the weighting of our forward-looking macroeconomic scenarios that are incorporated into our quantitative models. As any one economic outlook is inherently uncertain, the Corporation uses multiple macroeconomic scenarios in its expected credit losses (ECL) calculation, which have included a baseline scenario, which is derived from consensus estimates, downside scenarios, a tail risk scenario similar to the severely adverse scenario used in stress testing and an upside scenario. Beginning in 2020, the scenarios incorporated the potential impacts of the pandemic and, beginning in the second quarter in 2021, an additional scenario was added to account for inflationary risk and higher interest rates. Generally, as the consensus estimates improve or deteriorate, the allowance for credit losses will change in a similar direction.
There are multiple variables that drive the macroeconomic scenarios with the key variables including, but not limited to, U.S. gross domestic product (GDP) and unemployment rates. As of December 31, 2020, the weighted macroeconomic outlook for U.S. average unemployment rate was forecasted at 6.6 percent, 5.5 percent and 5.0 percent in the fourth quarters of 2021, 2022 and 2023, respectively, and the weighted macroeconomic outlook for U.S. GDP was forecasted to grow at 2.5 percent, 2.4 percent and 2.1 percent year-over-year in the fourth quarters of 2021, 2022 and 2023, respectively. As of December 31, 2021 the latest consensus estimates for the U.S. average unemployment rate for the fourth quarter of 2021 was 4.4 percent and U.S. GDP was forecasted to grow 5.2 percent year-over-year in the fourth quarter of 2021, both of which were meaningfully better than our macroeconomic outlook as of December 31, 2020 and were factored into our December 31, 2021 allowance for credit losses estimate. In addition, as of December 31, 2021, the weighted macroeconomic outlook for the U.S. average unemployment rate was forecasted at 5.2 percent and 4.7 percent in the fourth quarters of 2022 and 2023, and the weighted macroeconomic outlook for U.S. GDP was forecasted to grow 2.1 percent and 1.9 percent year-over-year in the fourth quarters of 2022 and 2023.
In addition to the above judgments and estimates, the allowance for credit losses can also be impacted by unanticipated changes in asset quality of the portfolio, such as increases or decreases in credit and/or internal risk ratings in our commercial portfolio, improvement or deterioration in borrower delinquencies or credit scores in our credit card portfolio and increases or decreases in home prices, which is a primary driver of LTVs, in our consumer real estate portfolio, all
of which have some degree of uncertainty. As the macroeconomic outlook improved in 2021, along with improvements in asset quality, the allowance for credit losses decreased to $13.8 billion from $20.7 billion at December 31, 2020.
To provide an illustration of the sensitivity of the macroeconomic scenarios and other assumptions on the estimate of our allowance for credit losses, the Corporation compared the December 31, 2021 modeled ECL from the baseline scenario and our downside scenario. Relative to the baseline scenario, the downside scenario assumed a peak U.S. unemployment rate of approximately three percentage points higher than the consensus outlook, a decline in U.S. GDP followed by a prolonged recovery and a lower home price outlook with a difference of 14 percent at the trough. This sensitivity analysis resulted in a hypothetical increase in the allowance for credit losses of approximately $5 billion.
While the sensitivity analysis may be useful to understand how changes in macroeconomic assumptions could impact our modeled ECLs, it is not meant to forecast how our allowance for credit losses is expected to change in a different macroeconomic outlook. Importantly, the analysis does not incorporate a variety of factors, including qualitative reserves and the weighting of alternate scenarios, which could have offsetting effects on the estimate. Considering the variety of factors contemplated when developing and weighting macroeconomic outlooks such as recent economic events, leading economic indicators, views of internal and third-party economists and industry trends, in addition to other qualitative factors, the Corporation believes the allowance for credit losses at December 31, 2021 is appropriate.
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
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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 liabilities became unobservable or observable, respectively, in the current marketplace. For more information on transfers into and out of Level 3 during 2021, 2020 and 2019, 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 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 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 18 under 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, 2021 by using a qualitative assessment to determine whether it was more likely than not that the fair value of each reporting unit was less than its respective carrying value. Factors considered in the qualitative assessment included, 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. Based on our qualitative assessment, we have concluded that it was not “more likely than not” that the reporting units fair values were less than their carrying values.
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 47 and 48 provide reconciliations of certain non-GAAP financial measures to GAAP financial measures.
Table 47
Annual Reconciliations to GAAP Financial Measures (1)
(Dollars in millions, shares in thousands)202120202019
Reconciliation of average shareholders’ equity to average tangible shareholders’ equity and average tangible common shareholders’ equity   
Shareholders’ equity$273,757 $267,309 $267,889 
Goodwill(69,005)(68,951)(68,951)
Intangible assets (excluding MSRs)(2,177)(1,862)(1,721)
Related deferred tax liabilities916 821 773 
Tangible shareholders’ equity$203,491 $197,317 $197,990 
Preferred stock(23,970)(23,624)(23,036)
Tangible common shareholders’ equity$179,521 $173,693 $174,954 
Reconciliation of year-end shareholders’ equity to year-end tangible shareholders’ equity and year-end tangible common shareholders’ equity  
Shareholders’ equity$270,066 $272,924 $264,810 
Goodwill(69,022)(68,951)(68,951)
Intangible assets (excluding MSRs)(2,153)(2,151)(1,661)
Related deferred tax liabilities929 920 713 
Tangible shareholders’ equity$199,820 $202,742 $194,911 
Preferred stock(24,708)(24,510)(23,401)
Tangible common shareholders’ equity$175,112 $178,232 $171,510 
Reconciliation of year-end assets to year-end tangible assets  
Assets$3,169,495 $2,819,627 $2,434,079 
Goodwill(69,022)(68,951)(68,951)
Intangible assets (excluding MSRs)(2,153)(2,151)(1,661)
Related deferred tax liabilities929 920 713 
Tangible assets$3,099,249 $2,749,445 $2,364,180 
(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 48
Quarterly Reconciliations to GAAP Financial Measures (1)
2021 Quarters2020 Quarters
(Dollars in millions)FourthThirdSecondFirstFourthThirdSecondFirst
Reconciliation of average shareholders’ equity to average tangible shareholders’ equity and average tangible common shareholders’ equity        
Shareholders’ equity$270,883 $275,484 $274,632 $274,047 $271,020 $267,323 $266,316 $264,534 
Goodwill(69,022)(69,023)(69,023)(68,951)(68,951)(68,951)(68,951)(68,951)
Intangible assets (excluding MSRs)(2,166)(2,185)(2,212)(2,146)(2,173)(1,976)(1,640)(1,655)
Related deferred tax liabilities913 915 915 920 910 855 790 728 
Tangible shareholders’ equity$200,608 $205,191 $204,312 $203,870 $200,806 $197,251 $196,515 $194,656 
Preferred stock(24,364)(23,441)(23,684)(24,399)(24,180)(23,427)(23,427)(23,456)
Tangible common shareholders’ equity$176,244 $181,750 $180,628 $179,471 $176,626 $173,824 $173,088 $171,200 
Reconciliation of period-end shareholders’ equity to period-end tangible shareholders’ equity and period-end tangible common shareholders’ equity        
Shareholders’ equity$270,066 $272,464 $277,119 $274,000 $272,924 $268,850 $265,637 $264,918 
Goodwill(69,022)(69,023)(69,023)(68,951)(68,951)(68,951)(68,951)(68,951)
Intangible assets (excluding MSRs)(2,153)(2,172)(2,192)(2,134)(2,151)(2,185)(1,630)(1,646)
Related deferred tax liabilities929 913 915 915 920 910 789 790 
Tangible shareholders’ equity$199,820 $202,182 $206,819 $203,830 $202,742 $198,624 $195,845 $195,111 
Preferred stock(24,708)(23,441)(23,441)(24,319)(24,510)(23,427)(23,427)(23,427)
Tangible common shareholders’ equity$175,112 $178,741 $183,378 $179,511 $178,232 $175,197 $172,418 $171,684 
Reconciliation of period-end assets to period-end tangible assets        
Assets$3,169,495 $3,085,446 $3,029,894 $2,969,992 $2,819,627 $2,738,452 $2,741,688 $2,619,954 
Goodwill(69,022)(69,023)(69,023)(68,951)(68,951)(68,951)(68,951)(68,951)
Intangible assets (excluding MSRs)(2,153)(2,172)(2,192)(2,134)(2,151)(2,185)(1,630)(1,646)
Related deferred tax liabilities929 913 915 915 920 910 789 790 
Tangible assets$3,099,249 $3,015,164 $2,959,594 $2,899,822 $2,749,445 $2,668,226 $2,671,896 $2,550,147 
(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.
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Item 7A. Quantitative and Qualitative Disclosures about Market Risk
See Market Risk Management on page 75 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
Page
Note 5 – Outstanding Loans and Leases and Allowance for Credit Losses

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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, 2021 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, 2021, the Corporation’s internal control over financial reporting is effective.
The Corporation’s internal control over financial reporting as of December 31, 2021 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, 2021.
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Brian T. Moynihan
Chair, Chief Executive Officer and President

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Alastair M. Borthwick
Chief Financial Officer

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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, 2021 and 2020, 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, 2021, 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, 2021, 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, 2021 and 2020, and the results of its operations and its cash flows for each of the three years in the period ended December 31, 2021 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, 2021, based on criteria established in Internal Control - Integrated Framework (2013) issued by the COSO.
Change in Accounting Principle
As discussed in Note 5 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 the expected credit losses in the Corporation’s loan and lease portfolio, excluding loans and unfunded lending commitments accounted for under the fair
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value option. As of December 31, 2021, the allowance for loan and lease losses was $12.4 billion on total loans and leases of $971.3 billion, which excludes loans accounted for under the fair value option. For commercial and consumer card loans, the expected credit loss is typically estimated using quantitative methods that consider a variety of factors such as historical loss experience, the current credit quality of the portfolio as well as an economic outlook over the life of the loan. 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 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 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. 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.
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 and lease 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 lifetime economic forecast scenarios used in the loss forecast models, (iv) testing the completeness and accuracy of data used in the estimate, and (v) evaluating the reasonableness of certain qualitative reserves made to the model output results to determine the overall allowance for loan
and lease 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 $10.7 billion of assets and $6.9 billion of liabilities classified as Level 3 fair value measurements that are valued on a recurring basis and $2.3 billion of assets classified as Level 3 fair value measurements that are valued 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, subjectivity and effort in performing procedures and in evaluating audit evidence obtained, including the involvement of professionals with specialized skill and knowledge.
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 significant unobservable inputs.

bac-20211231_g7.jpg

Charlotte, North Carolina
February 22, 2022

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


89 Bank of America


Bank of America Corporation and Subsidiaries
Consolidated Statement of Income
(In millions, except per share information)202120202019
Net interest income 
Interest income$47,672 $51,585 $71,236 
Interest expense4,738 8,225 22,345 
Net interest income42,934 43,360 48,891 
Noninterest income 
Fees and commissions39,299 34,551 33,015 
Market making and similar activities8,691 8,355 9,034 
Other income(1,811)(738)304 
Total noninterest income46,179 42,168 42,353 
Total revenue, net of interest expense89,113 85,528 91,244 
Provision for credit losses(4,594)11,320 3,590 
Noninterest expense
Compensation and benefits36,140 32,725 31,977 
Occupancy and equipment7,138 7,141 6,588 
Information processing and communications5,769 5,222 4,646 
Product delivery and transaction related3,881 3,433 2,762 
Marketing1,939 1,701 1,934 
Professional fees1,775 1,694 1,597 
Other general operating3,089 3,297 5,396 
Total noninterest expense59,731 55,213 54,900 
Income before income taxes33,976 18,995 32,754 
Income tax expense1,998 1,101 5,324 
Net income$31,978 $17,894 $27,430 
Preferred stock dividends1,421 1,421 1,432 
Net income applicable to common shareholders$30,557 $16,473 $25,998 
Per common share information 
Earnings$3.60 $1.88 $2.77 
Diluted earnings3.57 1.87 2.75 
Average common shares issued and outstanding8,493.3 8,753.2 9,390.5 
Average diluted common shares issued and outstanding8,558.4 8,796.9 9,442.9 
Consolidated Statement of Comprehensive Income
(Dollars in millions)202120202019
Net income$31,978 $17,894 $27,430 
Other comprehensive income (loss), net-of-tax:
Net change in debt securities(2,077)4,799 5,875 
Net change in debit valuation adjustments356 (498)(963)
Net change in derivatives(2,306)826 616 
Employee benefit plan adjustments624 (98)136 
Net change in foreign currency translation adjustments(45)(52)(86)
Other comprehensive income (loss)(3,448)4,977 5,578 
Comprehensive income$28,530 $22,871 $33,008 


















See accompanying Notes to Consolidated Financial Statements.
Bank of America 90


Bank of America Corporation and Subsidiaries
Consolidated Balance Sheet
December 31
(Dollars in millions)20212020
Assets
Cash and due from banks$29,222 $36,430 
Interest-bearing deposits with the Federal Reserve, non-U.S. central banks and other banks318,999 344,033 
Cash and cash equivalents348,221 380,463 
Time deposits placed and other short-term investments7,144 6,546 
Federal funds sold and securities borrowed or purchased under agreements to resell
   (includes $150,665 and $108,856 measured at fair value)
250,720 304,058 
Trading account assets (includes $103,434 and $91,510 pledged as collateral)
247,080 198,854 
Derivative assets35,344 47,179 
Debt securities: 
Carried at fair value308,073 246,601 
Held-to-maturity, at cost (fair value – $665,890 and $448,180)
674,554 438,249 
Total debt securities982,627 684,850 
Loans and leases (includes $7,819 and $6,681 measured at fair value)
979,124 927,861 
Allowance for loan and lease losses(12,387)(18,802)
Loans and leases, net of allowance966,737 909,059 
Premises and equipment, net10,833 11,000 
Goodwill69,022 68,951 
Loans held-for-sale (includes $4,455 and $1,585 measured at fair value)
15,635 9,243 
Customer and other receivables72,263 64,221 
Other assets (includes $12,144 and $15,718 measured at fair value)
163,869 135,203 
Total assets$3,169,495 $2,819,627 
Liabilities  
Deposits in U.S. offices:  
Noninterest-bearing$784,189 $650,674 
Interest-bearing (includes $408 and $481 measured at fair value)
1,165,914 1,038,341 
Deposits in non-U.S. offices:
Noninterest-bearing27,457 17,698 
Interest-bearing86,886 88,767 
Total deposits2,064,446 1,795,480 
Federal funds purchased and securities loaned or sold under agreements to repurchase
   (includes $139,641 and $135,391 measured at fair value)
192,329 170,323 
Trading account liabilities100,690 71,320 
Derivative liabilities37,675 45,526 
Short-term borrowings (includes $4,279 and $5,874 measured at fair value)
23,753 19,321 
Accrued expenses and other liabilities (includes $11,489 and $16,311 measured at fair value
   and $1,456 and $1,878 of reserve for unfunded lending commitments)
200,419 181,799 
Long-term debt (includes $29,708 and $32,200 measured at fair value)
280,117 262,934 
Total liabilities2,899,429 2,546,703 
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 – 3,939,686 and 3,931,440 shares
24,708 24,510 
Common stock and additional paid-in capital, $0.01  par value; authorized – 12,800,000,000 shares;
   issued and outstanding – 8,077,831,463 and 8,650,814,105 shares
62,398 85,982 
Retained earnings188,064 164,088 
Accumulated other comprehensive income (loss)(5,104)(1,656)
Total shareholders’ equity270,066 272,924 
Total liabilities and shareholders’ equity$3,169,495 $2,819,627 
Assets of consolidated variable interest entities included in total assets above (isolated to settle the liabilities of the variable interest entities)
Trading account assets$5,004 $5,225 
Loans and leases17,135 23,636 
Allowance for loan and lease losses(958)(1,693)
Loans and leases, net of allowance16,177 21,943 
All other assets189 1,387 
Total assets of consolidated variable interest entities$21,370 $28,555 
Liabilities of consolidated variable interest entities included in total liabilities above  
Short-term borrowings (includes $51 and $22 of non-recourse short-term borrowings)
$247 $454 
Long-term debt (includes $3,587 and $7,053 of non-recourse debt)
3,587 7,053 
All other liabilities (includes $7 and $16 of non-recourse liabilities)
7 16 
Total liabilities of consolidated variable interest entities$3,841 $7,523 
See accompanying Notes to Consolidated Financial Statements.
91 Bank of America


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, 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 
Net income31,978 31,978 
Net change in debt securities(2,077)(2,077)
Net change in debit valuation adjustments356 356 
Net change in derivatives(2,306)(2,306)
Employee benefit plan adjustments624 624 
Net change in foreign currency translation adjustments(45)(45)
Dividends declared:
Common(6,575)(6,575)
Preferred(1,421)(1,421)
Issuance of preferred stock2,169 2,169 
Redemption of preferred stock(1,971)(1,971)
Common stock issued under employee plans, net, and other42.3 1,542 (6)1,536 
Common stock repurchased(615.3)(25,126)(25,126)
Balance, December 31, 2021$24,708 8,077.8 $62,398 $188,064 $(5,104)$270,066 













See accompanying Notes to Consolidated Financial Statements.
Bank of America 92


Bank of America Corporation and Subsidiaries
Consolidated Statement of Cash Flows
(Dollars in millions)202120202019
Operating activities   
Net income$31,978 $17,894 $27,430 
Adjustments to reconcile net income to net cash provided by operating activities:   
Provision for credit losses(4,594)11,320 3,590 
Gains on sales of debt securities(22)(411)(217)
Depreciation and amortization1,898 1,843 1,729 
Net amortization of premium/discount on debt securities5,837 4,101 2,066 
Deferred income taxes(838)(1,737)2,435 
Stock-based compensation2,768 2,031 1,974 
Impairment of equity method investment  2,072 
Loans held-for-sale:
Originations and purchases(43,635)(19,657)(28,874)
Proceeds from sales and paydowns of loans originally classified as held for sale and instruments
from related securitization activities
34,684 19,049 30,191 
Net change in:
Trading and derivative assets/liabilities(22,104)16,942 7,920 
Other assets(34,455)(12,883)(11,113)
Accrued expenses and other liabilities16,639 (4,385)16,363 
Other operating activities, net4,651 3,886 6,211 
Net cash provided by (used in) operating activities(7,193)37,993 61,777 
Investing activities   
Net change in:
Time deposits placed and other short-term investments(598)561 387 
Federal funds sold and securities borrowed or purchased under agreements to resell53,338 (29,461)(13,466)
Debt securities carried at fair value:
Proceeds from sales6,893 77,524 52,006 
Proceeds from paydowns and maturities159,616 91,084 79,114 
Purchases(238,398)(194,877)(152,782)
Held-to-maturity debt securities:
Proceeds from paydowns and maturities124,880 93,835 34,770 
Purchases(362,736)(257,535)(37,115)
Loans and leases:
Proceeds from sales of loans originally classified as held for investment and instruments
from related securitization activities
10,396 13,351 12,201 
Purchases(5,164)(5,229)(5,963)
Other changes in loans and leases, net(58,039)36,571 (46,808)
Other investing activities, net(3,479)(3,489)(2,974)
Net cash used in investing activities(313,291)(177,665)(80,630)
Financing activities   
Net change in:
Deposits268,966 360,677 53,327 
Federal funds purchased and securities loaned or sold under agreements to repurchase22,006 5,214 (21,879)
Short-term borrowings4,432 (4,893)4,004 
Long-term debt:
Proceeds from issuance76,675 57,013 52,420 
Retirement(46,826)(47,948)(50,794)
Preferred stock:
Proceeds from issuance2,169 2,181 3,643 
Redemption(1,971)(1,072)(2,568)
Common stock repurchased(25,126)(7,025)(28,144)
Cash dividends paid(8,055)(7,727)(5,934)
Other financing activities, net(620)(601)(698)
Net cash provided by financing activities291,650 355,819 3,377 
Effect of exchange rate changes on cash and cash equivalents(3,408)2,756 (368)
Net increase (decrease) in cash and cash equivalents(32,242)218,903 (15,844)
Cash and cash equivalents at January 1380,463 161,560 177,404 
Cash and cash equivalents at December 31$348,221 $380,463 $161,560 
Supplemental cash flow disclosures
Interest paid$4,506 $8,662 $22,196 
Income taxes paid, net2,760 2,894 4,359 
See accompanying Notes to Consolidated Financial Statements.
93 Bank of America


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, which include the Corporation’s interests in affordable housing and renewable energy partnerships, are recorded 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.
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. In instances where the interest is negative, the Corporation’s policy is to present negative interest on financial assets as interest income and negative interest on financial liabilities as interest expense. For securities financing agreements that are accounted for under the fair value option, the changes in the fair value of these securities financing agreements 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, 2021 and 2020, the fair value of this collateral was $854.8 billion and $812.4 billion, of which $782.7 billion and $758.5 billion were sold or repledged. The primary source of this collateral is securities borrowed or purchased under agreements to resell.
The Corporation also pledges company-owned securities and loans as collateral in transactions that include repurchase agreements, securities loaned, public and trust deposits, U.S. Treasury tax and loan notes, and short-term borrowings. This collateral, which in some cases can be sold or repledged by the counterparties to the transactions, is parenthetically disclosed on the Consolidated Balance Sheet.
In certain cases, the Corporation has transferred assets to consolidated VIEs where those restricted assets serve as collateral for the interests issued by the VIEs. These assets are included on the Consolidated Balance Sheet in Assets of Consolidated VIEs.
In addition, the Corporation obtains collateral in connection with its derivative contracts. Required collateral levels vary depending on the credit risk rating and the type of counterparty. Generally, the Corporation accepts collateral in the form of cash, U.S. Treasury securities and other marketable securities. Based on provisions contained in master netting agreements, the Corporation nets cash collateral received against derivative assets. The Corporation also pledges collateral on its own derivative positions which can be applied against derivative liabilities.
Trading Instruments
Financial instruments utilized in trading activities are carried at fair value. Fair value is generally based on quoted market prices for the same or similar assets and liabilities. If these market prices are not available, fair values are estimated based on dealer quotes, pricing models, discounted cash flow methodologies, or similar techniques where the determination of fair value may require significant management judgment or estimation. Realized gains and losses are recorded on a trade-date basis. Realized and unrealized gains and losses are recognized in market making and similar activities.
Derivatives and Hedging Activities
Derivatives are entered into on behalf of customers, for trading or to support risk management activities. Derivatives used for otherin risk management activities include derivatives that are included in derivative assets or derivative liabilities. Derivatives used in other risk management activities have not beenboth 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 changeshedge market risks in the fair value of the Corporation’s assets and liabilitiesrelationships 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

Bank of America 94


assessingnot designated in qualifying accounting hedge effectiveness are recorded in the same income statement line itemrelationships (referred to as the hedged item.
Net investment hedges are used to manage theother risk management activities). The Corporation manages interest rate and foreign currency exchange rate sensitivity arising from a net investment in a foreign operation. Changes inpredominantly through the spot pricesuse of derivatives that are designated as net investment hedges of foreign operations are recorded as a component of accumulated OCI. The remaining components of thesederivatives. Derivatives utilized by the Corporation include swaps, futures and forward settlement contracts, and option contracts.
All derivatives are excluded in assessing hedge effectiveness and are recorded in market making and similar activities.
Securities
Debt securities are reported on the Consolidated Balance Sheet at their trade date. Their classificationfair 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 dependentbased on the purposequoted 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 securities were acquired. Debt securities purchased for use in the Corporation’s trading activities are reported in trading account assets atdetermination of fair value with unrealized gainsmay require significant management judgment or estimation.
Valuations of derivative assets and losses included in market making and similar activities. Substantially all other debt securities purchased are used inliabilities reflect the Corporation’s ALM activities and are reported on the Consolidated Balance Sheet as either debt securities carried at fair value or as held-to-maturity (HTM) debt securities. Debt securities carried at fair value are either available-for-sale (AFS) securities with unrealized gains and losses net-of-tax included in accumulated OCI or carried at fair value with unrealized gains and losses reported in other income. HTM debt securities, which are certain debt securities that management has the intent and ability to hold to maturity, are reported at amortized cost.
The Corporation regularly evaluates each AFS and HTM debt security where the value has declined below amortized cost to assess whether the decline in fair value is other than temporary. In determining whether an impairment is other than temporary, the Corporation considers the severity and duration of the decline in fair value, the length of time expected for recovery, the financial condition of the issuer, and other qualitative factors, as well as whether the Corporation either plans to sell the security or it is more likely than not that it will be required to sell the security before recovery of the amortized cost. For AFS debt securities the Corporation intends to hold, an analysis is performed to determine how much of the decline in fair value is related to the issuer’s credit and how much is related to market factors (e.g., interest rates). If any of the decline in fair value is due to credit, an other-than-temporary impairment (OTTI) loss is recognized in the Consolidated Statement of Income for that amount. If any of the decline in fair value is related to market factors, that amount is recognized in accumulated OCI. In certain instances, the credit loss may exceed the total decline in fair value, in which case, the difference is due to market factors and is recognized as an unrealized gain in accumulated OCI. If the Corporation intends to sell or believes it is more likely than not that it will be required to sell the debt security, it is written down to fair value as an OTTI loss.
Interest on debt securities, including amortization of premiums and accretion of discounts, is included in interest income. Premiums and discounts are amortized or accreted to interest income at a constant effective yield over the contractual lives of the securities. Realized gains and losses from the sales of debt securities are determined using the specific identification method.
Equity securities with readily determinable fair values that are not held for trading purposes are carried at fair value with unrealized gains and losses included in other income. Equity securities that do not have readily determinable fair values are recorded at cost less impairment, if any, plus or minus qualifying observable price changes. These securities are reported in other assets.
Loans and Leases
Loans, with the exception of loans accounted for under the fair value option, are measured at historical cost and reported at their outstanding principal balances net of any unearned income, charge-offs, unamortized deferred fees and costs on originated loans, and for purchased loans, net of any unamortized premiums or discounts. Loan origination fees and certain direct origination costs are deferred and recognized as adjustments to interest income over the lives of the related loans. Unearned income, discounts and premiums are amortized to interest income using a level yield methodology. The Corporation elects to account for certain consumer and commercial loans under the fair value option with interest reported in interest income and changes in fair value reported in market making and similar activities or other income.
Under applicable accounting guidance, for reporting purposes, the loan and lease portfolio is categorized by portfolio segment and, within each portfolio segment, by class of financing receivables. A portfolio segment is defined as the level at which an entity develops and documents a systematic methodology to determine the allowance for credit losses, and a class of financing receivables is defined as the level of disaggregation of portfolio segments based on the initial measurement attribute, risk characteristics and methods for assessing risk. The Corporation’s 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 overinstrument including counterparty credit risk. These values also take into account 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.Corporation’s own credit standing.
Allowance for Credit Losses
The allowance for credit losses decreased $6.8 billion from December 31, 2020 to $13.8 billion at December 31, 2021, which included a $3.8 billion reserve decrease related to the commercial portfolio and a $3.1 billion reserve decrease related
to the consumer portfolio. The decreases were primarily driven by improvements in the macroeconomic outlook and credit quality.
Table 41 presents an allocation of the allowance for credit losses by product type at December 31, 2021and 2020.
Table 41Allocation 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)
(Dollars in millions)December 31, 2021December 31, 2020
Allowance for loan and lease losses      
Residential mortgage$351 2.83 %0.16 %$459 2.44 %0.21 %
Home equity206 1.66 0.74 399 2.12 1.16 
Credit card5,907 47.70 7.25 8,420 44.79 10.70 
Direct/Indirect consumer523 4.22 0.51 752 4.00 0.82 
Other consumer46 0.37 n/m41 0.22 n/m
Total consumer7,033 56.78 1.62 10,071 53.57 2.35 
U.S. commercial (2)
3,019 24.37 0.87 5,043 26.82 1.55 
Non-U.S. commercial975 7.87 0.86 1,241 6.60 1.37 
Commercial real estate1,292 10.43 2.05 2,285 12.15 3.79 
Commercial lease financing68 0.55 0.46 162 0.86 0.95 
Total commercial5,354 43.22 1.00 8,731 46.43 1.77 
Allowance for loan and lease losses12,387 100.00 %1.28 18,802 100.00 %2.04 
Reserve for unfunded lending commitments1,456 1,878  
Allowance for credit losses$13,843 $20,680 
(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.
(2)Includes allowance for loan and lease losses for U.S. small business commercial loans of $1.2 billion and $1.5 billion at December 31, 2021 and 2020.
n/m = not meaningful
Net charge-offs for 2021 were $2.2 billion compared to $4.1 billion in 2020 driven by decreases across most products. The provision for credit losses decreased $15.9 billion to a $4.6 billion benefit during 2021 compared to 2020. The allowance for credit losses had a reserve release of $6.8 billion for 2021, primarily driven by improvements in the macroeconomic outlook and credit quality. The provision for credit losses for the consumer portfolio, including unfunded lending commitments, decreased $6.1 billion to a benefit of $1.2 billion during 2021 compared to 2020. The provision for credit losses for the
commercial portfolio, including unfunded lending commitments, decreased $9.8 billion to a $3.4 billion benefit for 2021 compared to 2020.
Table 42 presents a rollforward of the allowance for credit losses, including certain loan and allowance ratios for 2021 and 2020. 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 42Allowance for Credit Losses
(Dollars in millions)20212020
Allowance for loan and lease losses, January 1$18,802 $12,358 
Loans and leases charged off
Residential mortgage(34)(40)
Home equity(44)(58)
Credit card(2,411)(2,967)
Direct/Indirect consumer(297)(372)
Other consumer(292)(307)
Total consumer charge-offs(3,078)(3,744)
U.S. commercial (1)
(626)(1,163)
Non-U.S. commercial(47)(168)
Commercial real estate(46)(275)
Commercial lease financing (69)
Total commercial charge-offs(719)(1,675)
Total loans and leases charged off(3,797)(5,419)
Recoveries of loans and leases previously charged off
Residential mortgage62 70 
Home equity163 131 
Credit card688 618 
Direct/Indirect consumer296 250 
Other consumer22 23 
Total consumer recoveries1,231 1,092 
U.S. commercial (2)
298 178 
Non-U.S. commercial12 13 
Commercial real estate12 
Commercial lease financing1 10 
Total commercial recoveries323 206 
Total recoveries of loans and leases previously charged off1,554 1,298 
Net charge-offs(2,243)(4,121)
Provision for loan and lease losses(4,173)10,565 
Other1 — 
Allowance for loan and lease losses, December 3112,387 18,802 
Reserve for unfunded lending commitments, January 11,878 1,123 
Provision for unfunded lending commitments(421)755 
Other(1)— 
Reserve for unfunded lending commitments, December 311,456 1,878 
Allowance for credit losses, December 31$13,843 $20,680 
Loan and allowance ratios (3) :
Loans and leases outstanding at December 31$971,305 $921,180 
Allowance for loan and lease losses as a percentage of total loans and leases outstanding at December 311.28 %2.04 %
Consumer allowance for loan and lease losses as a percentage of total consumer loans and leases outstanding at December 311.62 2.35 
Commercial allowance for loan and lease losses as a percentage of total commercial loans and leases outstanding at December 311.00 1.77 
Average loans and leases outstanding$913,354 $974,281 
Annualized net charge-offs as a percentage of average loans and leases outstanding0.25 %0.42 %
Allowance for loan and lease losses as a percentage of total nonperforming loans and leases at December 31271 380 
Ratio of the allowance for loan and lease losses at December 31 to net charge-offs5.52 4.56 
Amounts included in allowance for loan and lease losses for loans and leases that are excluded from nonperforming loans and leases at December 31 (4)
$7,027 $9,854 
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 (4)
117 %181 %
(1)Includes U.S. small business commercial charge-offs of $425 million in 2021 compared to $321 million in 2020.
(2)Includes U.S. small business commercial recoveries of $74 million for 2021 compared to $54 million in 2020.
(3)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.
(4)Primarily includes amounts related to credit card and unsecured consumer lending portfolios in Consumer Banking.
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Market Risk Management
Market risk is the risk that changes in market conditions may adversely impact the value of assets or liabilities, or otherwise negatively impact earnings. This risk is inherent in the financial instruments associated with our operations, primarily within our Global Markets segment. We are also exposed to these risks in other areas of the Corporation (e.g., our ALM activities). In the event of market stress, these risks could have a material impact on our results. For more information, see Interest Rate Risk Management for the Banking Book on page 79.
We have been affected, and may continue to be affected, by market stress resulting from the pandemic that began in the first quarter of 2020. For more information, see Part 1. Item 1A. Risk Factors – Coronavirus Disease on page 8.
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 80.
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 49.
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 43 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.
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In addition, Table 43 presents our fair value option portfolio, which includes substantially all of the funded and unfunded exposures for which we elect the fair value option, and their corresponding hedges. Additionally, market risk VaR for trading activities as presented in Table 43 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 43 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 43 presents year-end, average, high and low daily trading VaR for 2021 and 2020 using a 99 percent confidence level. The amounts disclosed in Table 43 and Table 44 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 decreased for 2021 compared to 2020 primarily due to an increase in diversification across asset classes.
Table 43Market Risk VaR for Trading Activities
20212020
(Dollars in millions)Year
End
Average
High (1)
Low (1)
Year
End
Average
High (1)
Low (1)
Foreign exchange$11 $12 $21 $5 $$$25 $
Interest rate54 40 80 16 30 19 39 
Credit73 69 84 53 79 58 91 25 
Equity21 24 35 19 20 24 162 12 
Commodities6 8 28 4 12 
Portfolio diversification(114)(100)  (72)(61)— — 
Total covered positions portfolio51 53 85 34 69 53 171 27 
Impact from less liquid exposures (2)
8 20   52 27 — — 
Total covered positions and less liquid trading positions portfolio59 73 125 46 121 80 169 30 
Fair value option loans51 50 65 31 52 52 84 
Fair value option hedges15 16 20 11 11 13 17 
Fair value option portfolio diversification(27)(32)  (17)(24)— — 
Total fair value option portfolio39 34 53 23 46 41 86 
Portfolio diversification(24)(10)  (4)(15)— — 
Total market-based portfolio$74 $97 169 54 $163 $106 171 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.
(2)Impact is net of diversification effects between the covered positions and less liquid trading positions portfolios.
The graph below presents the daily covered positions and less liquid trading positions portfolio VaR for 2021, corresponding to the data in Table 43.

bac-20211231_g3.jpg
77 Bank of America


Additional VaR statistics produced within our single VaR model are provided in Table 44 at the same level of detail as in Table 43. 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 44 presents average trading VaR statistics at 99 percent and 95 percent confidence levels for 2021 and 2020.
Table 44Average Market Risk VaR for Trading Activities – 99 percent and 95 percent VaR Statistics
20212020
(Dollars in millions)99 percent95 percent99 percent95 percent
Foreign exchange$12 $8 $$
Interest rate40 20 19 
Credit69 21 58 18 
Equity24 12 24 13 
Commodities8 4 
Portfolio diversification(100)(39)(61)(26)
Total covered positions portfolio53 26 53 21 
Impact from less liquid exposures20 2 27 
Total covered positions and less liquid trading positions portfolio73 28 80 23 
Fair value option loans50 12 52 13 
Fair value option hedges16 9 13 
Fair value option portfolio diversification(32)(9)(24)(8)
Total fair value option portfolio34 12 41 12 
Portfolio diversification(10)(7)(15)(6)
Total market-based portfolio$97 $33 $106 $29 
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 2021, there were two 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 2021 and 2020. During 2021, positive trading-related revenue was recorded for 97 percent of the trading days, of which 80 percent were daily trading gains of over $25 million, and the largest loss was $45 million. This compares to 2020 where 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.
bac-20211231_g4.jpg

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Trading Portfolio Stress Testing
Because the very nature of a VaR model suggests results can exceed our estimates and it is dependent on a limited historical window, we also stress test our portfolio using scenario analysis. This analysis estimates the change in the value of our trading portfolio that may result from abnormal market movements.
A set of scenarios, categorized as either historical or hypothetical, are computed daily for the overall trading portfolio and individual businesses. These scenarios include shocks to underlying market risk factors that may be well beyond the shocks found in the historical data used to calculate VaR. Historical scenarios simulate the impact of the market moves that occurred during a period of extended historical market stress. Generally, a multi-week period representing the most severe point during a crisis is selected for each historical scenario. Hypothetical scenarios provide estimated portfolio impacts from potential future market stress events. Scenarios are reviewed and updated in response to changing positions and new economic or political information. In addition, new or ad hoc scenarios are developed to address specific potential market events or particular vulnerabilities in the portfolio. The stress tests are reviewed on a regular basis and the results are presented to senior management.
Stress testing for the trading portfolio is integrated with enterprise-wide stress testing and incorporated into the limits framework. The macroeconomic scenarios used for enterprise-wide stress testing purposes differ from the typical trading portfolio scenarios in that they have a longer time horizon and the results are forecasted over multiple periods for use in consolidated capital and liquidity planning. For more information, see Managing Risk on page 46.
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 45 presents the spot and 12-month forward rates used in our baseline forecasts at December 31, 2021 and 2020.
Table 45Forward Rates
December 31, 2021
 Federal
Funds
Three-month
LIBOR
10-Year
Swap
Spot rates0.25 %0.21 %1.58 %
12-month forward rates1.00 1.07 1.84 
December 31, 2020
Spot rates0.25 %0.24 %0.93 %
12-month forward rates0.25 0.19 1.06 
Table 46 shows the pretax impact to forecasted net interest income over the next 12 months from December 31, 2021 and 2020 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 2021, the overall decrease in asset sensitivity of our balance sheet to Up-rate and Down-rate scenarios was primarily due to ALM activity and an increase in long-end rates. 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 50.
Table 46Estimated Banking Book Net Interest Income Sensitivity to Curve Changes
Short
Rate (bps)
Long
Rate (bps)
December 31
(Dollars in millions)20212020
Parallel Shifts
+100 bps
instantaneous shift
+100+100$6,542 $10,468 
-25 bps
instantaneous shift
-25 -25 (2,092)(2,766)
Flatteners  
Short-end
instantaneous change
+100— 4,982 6,321 
Long-end
instantaneous change
— -25 (735)(1,686)
Steepeners  
Short-end
instantaneous change
-25 — (1,344)(1,084)
Long-end
instantaneous change
— +1001,646 4,333 
The sensitivity analysis in Table 46 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 46 assumes no change in
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deposit portfolio size or mix from the baseline forecast in alternate rate environments. In higher rate scenarios, any customer activity resulting in the replacement of low-cost or noninterest-bearing deposits with higher yielding deposits or market-based funding would reduce our benefit in those scenarios.
Interest Rate and Foreign Exchange Derivative Contracts
We use interest rate and foreign exchange derivative contracts in our ALM activities to manage our interest rate and foreign exchange risks. Specifically, we use those derivatives to manage both the variability in cash flows and changes in fair value of various assets and liabilities arising from those risks. Our interest rate derivative contracts are generally non-leveraged swaps tied to various benchmark interest rates and foreign exchange basis swaps, options, futures and forwards, and our foreign exchange contracts include cross-currency interest rate swaps, foreign currency futures contracts, foreign currency forward contracts and options.
The derivatives used in our ALM activities can be split into two broad categories: designated accounting hedges and other risk management derivatives. Designated accounting hedges are primarily used to manage our exposure to interest rates as described in the Interest Rate Risk Management for the Banking Book section and are included in the sensitivities presented in Table 46. The Corporation also uses foreign currency derivatives in accounting hedges to manage substantially all of the foreign exchange risk of our foreign operations. By hedging the foreign exchange risk of our foreign operations, the Corporation's market risk exposure in this area is insignificant.
Risk management derivatives are predominantly used to hedge foreign exchange risks related to various foreign currency-denominated assets and liabilities and eliminate substantially all foreign currency exposures in the cash flows of the Corporation’s non-trading foreign currency-denominated financial instruments. These foreign exchange derivatives are sensitive to other market risk exposures such as cross-currency basis spreads and interest rate risk. However, as these features are not a significant component of these foreign exchange derivatives, the market risk related to this exposure is insignificant. For more information on the accounting for derivatives, see Note 3 – Derivatives to the Consolidated Financial Statements.
Mortgage Banking Risk Management
We originate, fund and service mortgage loans, which subject us to credit, liquidity and interest rate risks, among others. We determine whether loans will be held for investment or held for sale at the time of commitment and manage credit and liquidity risks by selling or securitizing a portion of the loans we originate.
Interest rate risk and market risk can be substantial in the mortgage business. Changes in interest rates and other market factors impact the volume of mortgage originations. Changes in interest rates also impact the value of interest rate lock commitments (IRLCs) and the related residential first mortgage LHFS between the date of the IRLC and the date the loans are
sold to the secondary market. An increase in mortgage interest rates typically leads to a decrease in the value of these instruments. Conversely, when there is an increase in interest rates, the value of the MSRs will increase driven by lower prepayment expectations. Because the interest rate risks of these hedged items offset, we combine them into one overall hedged item with one combined economic hedge portfolio consisting of derivative contracts and securities.
During 2021, 2020 and 2019, we recorded gains of $39 million, $321 million and $291 million. 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). We are subject to comprehensive regulation under federal and state laws, rules and regulations in the U.S. and the laws of the various jurisdictions in which we operate, including those related to financial crimes and anti-money laundering, market conduct, trading activities, fair lending, privacy, data protection and unfair, deceptive or abusive acts or practices.
Operational risk is the risk of loss resulting from inadequate or failed processes or systems, people or external events, and includes legal risk. Operational risk may occur anywhere in the Corporation, including third-party business processes, and is not limited to operations functions. The Corporation faces a number of key operational risks including third-party risk, model risk, conduct risk, technology risk, information security risk and data risk. Operational risk can result in financial losses and reputational impacts and 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 49.
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 and 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. Collectively, these efforts are important to strengthen their compliance and operational resiliency, which is the ability to deliver critical operations through disruption.

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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 GRM, works with Global Compliance and Operational Risk, the FLUs and control functions in the identification of testing needs and test design, and is accountable for test execution, reporting and analysis of results. Corporate Audit provides an 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 and reflect Global Compliance and Operational Risk’s responsibilities for conducting independent oversight of the Corporation’s compliance and operational risk management activities. The Board provides oversight of compliance risk through its Audit Committee and the ERC, and operational risk through its 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' operations, systems or data. The Corporation seeks to mitigate information security risk and associated reputational and compliance risk by employing a multi-layered and intelligence-led Global Information Security Program, which is focused on preparing for, preventing, detecting, mitigating, responding to and recovering from cyber threats and incidents and ensuring the Corporation’s processes operate effectively and mitigate the aforementioned risks.
The Global Information Security Program is supported by three lines of defense. The Global Information Security Team within the first line of defense is responsible for the day-to-day management of the Global Information Security Program, which includes defining policies and procedures to safeguard the Corporation’s information systems and data, conducting vulnerability and third-party information security assessments, information security event management (e.g., responding to ransomware and distributed denial of service attacks), evaluation of external cyber intelligence, supporting industry cybersecurity efforts and working with governmental agencies, as well as developing employee training to support adherence to the Corporation’s policies and procedures. As the second line of defense, Global Compliance and Operational Risk independently assesses, monitors and tests information security risk across the Corporation as well as the effectiveness of the Global Information Security Program. Corporate Audit serves as the third line of defense, conducting additional independent review and validation of the first line processes and functions.

Through established governance structures, we have processes to help facilitate appropriate and effective oversight of information security risk. These routines enable our three lines of defense and management to debate information security risks and monitor control performance to allow for further escalation to executive management, management and Board-level committees or to the Board, as appropriate. The Board is actively engaged in the oversight of Bank of America’s Global Information Security Program, primarily through the ERC.
Reputational Risk Management
Reputational risk is the risk that negative perception of the Corporation may adversely impact 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 embedded throughout its business and risk management processes. We proactively monitor and identify potential reputational risk events and have processes established to mitigate reputational risks in a timely manner. 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. 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 Legal and Risk, that is responsible for the oversight of reputational risk, including 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 rising average global temperatures and sea-level rise. 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. These risks can impact both financial and nonfinancial risk types. The impacts of transition risk can lead to and amplify credit risk or market risk by reducing our customers’ operating income or the value of their assets as well as expose us to reputational and/or litigation risk due to increased regulatory scrutiny or negative public sentiment. Physical risk can lead to increased credit risk by diminishing borrowers’ repayment capacity or impacting the value of collateral. In addition, it could pose increased operational risk to our facilities and people.

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Effective management of climate risk requires coordinated governance, clearly defined roles and responsibilities and well-developed processes to identify, measure, monitor and control risks. We continue to build out and enhance our climate risk management capabilities. 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. Our Environmental and Social Risk Policy Framework (ESRPF) aligns with our Risk Framework and provides additional clarity and transparency regarding our approach to environmental and social risks, inclusive of climate risk.
Our governance framework establishes oversight of climate risk practices and strategies by the Board, supported by its Corporate Governance, ESG, and Sustainability Committee and ERC, as well as the MRC and the Global ESG Committee, both of which are management-level committees comprised of senior leaders across every major FLU and control function.
Our climate risk management efforts are overseen by the Global Climate Risk Executive who reports to the CRO. The Global Climate Risk Executive chairs the Climate Risk Steering Council, which meets monthly and shapes our approach to managing climate-related risks in line with our Risk Framework.
As outlined in our ESRPF, we are focused on supporting and financing areas critical to the transition to a low-carbon economy. Accordingly, we have a goal, publicly announced in early 2021, to achieve net zero greenhouse gas emissions in our financing activities, operations and supply chain before 2050 (Net Zero Goal). More broadly, achieving this goal will require technological advances, clearly defined roadmaps for industry sectors, public policies, and better emissions data reporting, as well as ongoing, strong and active engagement with clients, suppliers, investors, government officials and other stakeholders.
Our progress towards achieving our Net Zero Goal is based on establishing the baseline for emissions associated with our financing activities often referred to as financed emissions. Currently, we are using the Partnership for Carbon Accounting Financials methodology to assess our financed emissions. Additionally, given the urgency required to address climate change, we helped to launch the Net Zero Banking Alliance (NZBA) in April 2021, which outlines guidelines for banks to achieve net zero greenhouse gas emissions including requirements for setting interim targets. As a member of NZBA, the Corporation and more than 100 other financial institution members representing more than 40 percent of the world’s banking assets, have committed to set emission reduction targets for 2030. We plan to begin disclosure of financed emissions by 2023, and set 2030 targets for the significant majority of emissions in our portfolio.
In 2021, we also announced a goal to deploy $1 trillion by 2030 to accelerate the transition to a low-carbon, sustainable economy by providing lending, capital raising, advisory and investment services, and by developing other client-driven financial solutions. This commitment anchors a broader $1.5
trillion sustainable finance goal to support both environmental transition and social inclusive development, which spans business activities across the globe. These goals are intended to help drive business opportunities and enhance risk management related to the transition to a low-carbon economy.
For more information about climate risk, see the Bank of America website. For more information about the Corporation’s climate-related goals and commitments, including emissions associated with our operations and supply chain and progress on our sustainable finance goals, see the Corporation’s 2021 Annual Report to shareholders that will be available on the Investor Relations portion of our website in March 2022. The contents of the Corporation’s website and 2021 Annual Report to shareholders are not incorporated by reference into this Annual Report on Form 10-K.
The foregoing discussion and our discussion in the 2021 Annual Report to shareholders regarding our goals and commitments with respect to climate risk management, including environmental transition considerations, include “forward-looking statements” within the meaning of the Private Securities Litigation Reform Act of 1995. 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.
Complex Accounting Estimates
Our significant accounting principles, as described in Note 1 – Summary of Significant Accounting Principles to the Consolidated Financial Statements, are essential in understanding the MD&A. Many of our significant accounting principles require complex judgments to estimate the values of assets and liabilities. We have procedures and processes in place to facilitate making these judgments.
The more judgmental estimates are summarized in the following discussion. We have identified and described the development of the variables most important in the estimation processes that involve mathematical models to derive the estimates. In many cases, there are numerous alternative judgments that could be used in the process of determining the inputs to the models. Where alternatives exist, we have used the factors that we believe represent the most reasonable value in developing the inputs. Actual performance that differs from our estimates of the key variables could materially impact our results of operations. Separate from the possible future impact to our results of operations from input and model variables, the value of our lending portfolio and market-sensitive assets and liabilities may change subsequent to the balance sheet date, often significantly, due to the nature and magnitude of future credit and market conditions. Such credit and market conditions may change quickly and in unforeseen ways and the resulting volatility could have a significant, negative effect on future operating results. These fluctuations would not be indicative of deficiencies in our models or inputs.

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Allowance for Credit Losses
The allowance for credit losses includes the allowance for loan and lease losses and the reserve for unfunded lending commitments,commitments. Our process for determining the allowance for credit losses is discussed in Note 1 – Summary of Significant Accounting Principlesand Note 5 – Outstanding Loans and Leases and Allowance for Credit Losses to the Consolidated Financial Statements.
The determination of allowance for credit losses is based on numerous estimates and assumptions, which require a high degree of judgment and are often interrelated. A critical judgment in the process is the weighting of our forward-looking macroeconomic scenarios that are incorporated into our quantitative models. As any one economic outlook is inherently uncertain, the Corporation uses multiple macroeconomic scenarios in its expected credit losses (ECL) calculation, which have included a baseline scenario, which is derived from consensus estimates, downside scenarios, a tail risk scenario similar to the severely adverse scenario used in stress testing and an upside scenario. Beginning in 2020, the scenarios incorporated the potential impacts of the pandemic and, beginning in the second quarter in 2021, an additional scenario was added to account for inflationary risk and higher interest rates. Generally, as the consensus estimates improve or deteriorate, the allowance for credit losses will change in a similar direction.
There are multiple variables that drive the macroeconomic scenarios with the key variables including, but not limited to, U.S. gross domestic product (GDP) and unemployment rates. As of December 31, 2020, the weighted macroeconomic outlook for U.S. average unemployment rate was forecasted at 6.6 percent, 5.5 percent and 5.0 percent in the fourth quarters of 2021, 2022 and 2023, respectively, and the weighted macroeconomic outlook for U.S. GDP was forecasted to grow at 2.5 percent, 2.4 percent and 2.1 percent year-over-year in the fourth quarters of 2021, 2022 and 2023, respectively. As of December 31, 2021 the latest consensus estimates for the U.S. average unemployment rate for the fourth quarter of 2021 was 4.4 percent and U.S. GDP was forecasted to grow 5.2 percent year-over-year in the fourth quarter of 2021, both of which were meaningfully better than our macroeconomic outlook as of December 31, 2020 and were factored into our December 31, 2021 allowance for credit losses estimate. In addition, as of December 31, 2021, the weighted macroeconomic outlook for the U.S. average unemployment rate was forecasted at 5.2 percent and 4.7 percent in the fourth quarters of 2022 and 2023, and the weighted macroeconomic outlook for U.S. GDP was forecasted to grow 2.1 percent and 1.9 percent year-over-year in the fourth quarters of 2022 and 2023.
In addition to the above judgments and estimates, the allowance for credit losses can also be impacted by unanticipated changes in asset quality of the portfolio, such as increases or decreases in credit and/or internal risk ratings in our commercial portfolio, improvement or deterioration in borrower delinquencies or credit scores in our credit card portfolio and increases or decreases in home prices, which is a primary driver of LTVs, in our consumer real estate portfolio, all
of which have some degree of uncertainty. As the macroeconomic outlook improved in 2021, along with improvements in asset quality, the allowance for credit losses decreased to $13.8 billion from $20.7 billion at December 31, 2020.
To provide an illustration of the sensitivity of the macroeconomic scenarios and other assumptions on the estimate of our allowance for credit losses, the Corporation compared the December 31, 2021 modeled ECL from the baseline scenario and our downside scenario. Relative to the baseline scenario, the downside scenario assumed a peak U.S. unemployment rate of approximately three percentage points higher than the consensus outlook, a decline in U.S. GDP followed by a prolonged recovery and a lower home price outlook with a difference of 14 percent at the trough. This sensitivity analysis resulted in a hypothetical increase in the allowance for credit losses of approximately $5 billion.
While the sensitivity analysis may be useful to understand how changes in macroeconomic assumptions could impact our modeled ECLs, it is not meant to forecast how our allowance for credit losses is expected to change in a different macroeconomic outlook. Importantly, the analysis does not incorporate a variety of factors, including qualitative reserves and the weighting of alternate scenarios, which could have offsetting effects on the estimate. Considering the variety of factors contemplated when developing and weighting macroeconomic outlooks such as recent economic events, leading economic indicators, views of internal and third-party economists and industry trends, in addition to other qualitative factors, the Corporation believes the allowance for credit losses at December 31, 2021 is appropriate.
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
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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 liabilities became unobservable or observable, respectively, in the current marketplace. For more information on transfers into and out of Level 3 during 2021, 2020 and 2019, 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 18 under 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, 2021 by using a qualitative assessment to determine whether it was more likely than not that the fair value of each reporting unit was less than its respective carrying value. Factors considered in the qualitative assessment included, 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. Based on our qualitative assessment, we have concluded that it was not “more likely than not” that the reporting units fair values were less than their carrying values.
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 47 and 48 provide reconciliations of certain non-GAAP financial measures to GAAP financial measures.
Table 47
Annual Reconciliations to GAAP Financial Measures (1)
(Dollars in millions, shares in thousands)202120202019
Reconciliation of average shareholders’ equity to average tangible shareholders’ equity and average tangible common shareholders’ equity   
Shareholders’ equity$273,757 $267,309 $267,889 
Goodwill(69,005)(68,951)(68,951)
Intangible assets (excluding MSRs)(2,177)(1,862)(1,721)
Related deferred tax liabilities916 821 773 
Tangible shareholders’ equity$203,491 $197,317 $197,990 
Preferred stock(23,970)(23,624)(23,036)
Tangible common shareholders’ equity$179,521 $173,693 $174,954 
Reconciliation of year-end shareholders’ equity to year-end tangible shareholders’ equity and year-end tangible common shareholders’ equity  
Shareholders’ equity$270,066 $272,924 $264,810 
Goodwill(69,022)(68,951)(68,951)
Intangible assets (excluding MSRs)(2,153)(2,151)(1,661)
Related deferred tax liabilities929 920 713 
Tangible shareholders’ equity$199,820 $202,742 $194,911 
Preferred stock(24,708)(24,510)(23,401)
Tangible common shareholders’ equity$175,112 $178,232 $171,510 
Reconciliation of year-end assets to year-end tangible assets  
Assets$3,169,495 $2,819,627 $2,434,079 
Goodwill(69,022)(68,951)(68,951)
Intangible assets (excluding MSRs)(2,153)(2,151)(1,661)
Related deferred tax liabilities929 920 713 
Tangible assets$3,099,249 $2,749,445 $2,364,180 
(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 48
Quarterly Reconciliations to GAAP Financial Measures (1)
2021 Quarters2020 Quarters
(Dollars in millions)FourthThirdSecondFirstFourthThirdSecondFirst
Reconciliation of average shareholders’ equity to average tangible shareholders’ equity and average tangible common shareholders’ equity        
Shareholders’ equity$270,883 $275,484 $274,632 $274,047 $271,020 $267,323 $266,316 $264,534 
Goodwill(69,022)(69,023)(69,023)(68,951)(68,951)(68,951)(68,951)(68,951)
Intangible assets (excluding MSRs)(2,166)(2,185)(2,212)(2,146)(2,173)(1,976)(1,640)(1,655)
Related deferred tax liabilities913 915 915 920 910 855 790 728 
Tangible shareholders’ equity$200,608 $205,191 $204,312 $203,870 $200,806 $197,251 $196,515 $194,656 
Preferred stock(24,364)(23,441)(23,684)(24,399)(24,180)(23,427)(23,427)(23,456)
Tangible common shareholders’ equity$176,244 $181,750 $180,628 $179,471 $176,626 $173,824 $173,088 $171,200 
Reconciliation of period-end shareholders’ equity to period-end tangible shareholders’ equity and period-end tangible common shareholders’ equity        
Shareholders’ equity$270,066 $272,464 $277,119 $274,000 $272,924 $268,850 $265,637 $264,918 
Goodwill(69,022)(69,023)(69,023)(68,951)(68,951)(68,951)(68,951)(68,951)
Intangible assets (excluding MSRs)(2,153)(2,172)(2,192)(2,134)(2,151)(2,185)(1,630)(1,646)
Related deferred tax liabilities929 913 915 915 920 910 789 790 
Tangible shareholders’ equity$199,820 $202,182 $206,819 $203,830 $202,742 $198,624 $195,845 $195,111 
Preferred stock(24,708)(23,441)(23,441)(24,319)(24,510)(23,427)(23,427)(23,427)
Tangible common shareholders’ equity$175,112 $178,741 $183,378 $179,511 $178,232 $175,197 $172,418 $171,684 
Reconciliation of period-end assets to period-end tangible assets        
Assets$3,169,495 $3,085,446 $3,029,894 $2,969,992 $2,819,627 $2,738,452 $2,741,688 $2,619,954 
Goodwill(69,022)(69,023)(69,023)(68,951)(68,951)(68,951)(68,951)(68,951)
Intangible assets (excluding MSRs)(2,153)(2,172)(2,192)(2,134)(2,151)(2,185)(1,630)(1,646)
Related deferred tax liabilities929 913 915 915 920 910 789 790 
Tangible assets$3,099,249 $3,015,164 $2,959,594 $2,899,822 $2,749,445 $2,668,226 $2,671,896 $2,550,147 
(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.
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Item 7A. Quantitative and Qualitative Disclosures about Market Risk
See Market Risk Management on page 75 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
Page
Note 5 – Outstanding Loans and Leases and Allowance for Credit Losses

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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, 2021 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, 2021, the Corporation’s internal control over financial reporting is effective.
The Corporation’s internal control over financial reporting as of December 31, 2021 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, 2021.
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Brian T. Moynihan
Chair, Chief Executive Officer and President

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Alastair M. Borthwick
Chief Financial Officer

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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, 2021 and 2020, 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, 2021, 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, 2021, 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, 2021 and 2020, and the results of its operations and its cash flows for each of the three years in the period ended December 31, 2021 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, 2021, based on criteria established in Internal Control - Integrated Framework (2013) issued by the COSO.
Change in Accounting Principle
As discussed in Note 5 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 probable incurredthe expected credit losses in the Corporation’s loan and lease portfolio, excluding loans and unfunded lending commitments accounted for under the fair
Bank of America 88


value option. As of December 31, 2021, the allowance for loan and lease losses was $12.4 billion on total loans and leases of $971.3 billion, which excludes loans accounted for under the fair value option. For commercial and consumer card loans, the expected credit loss is typically estimated using quantitative methods that consider a variety of factors such as historical loss experience, the current credit quality of the portfolio as well as an economic outlook over the life of the loan. 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 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 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. 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.
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 and lease 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 lifetime economic forecast scenarios used in the loss forecast models, (iv) testing the completeness and accuracy of data used in the estimate, and (v) evaluating the reasonableness of certain qualitative reserves made to the model output results to determine the overall allowance for loan
and lease 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 $10.7 billion of assets and $6.9 billion of liabilities classified as Level 3 fair value measurements that are valued on a recurring basis and $2.3 billion of assets classified as Level 3 fair value measurements that are valued 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, subjectivity and effort in performing procedures and in evaluating audit evidence obtained, including the involvement of professionals with specialized skill and knowledge.
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 significant unobservable inputs.

bac-20211231_g7.jpg

Charlotte, North Carolina
February 22, 2022

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


89 Bank of America


Bank of America Corporation and Subsidiaries
Consolidated Statement of Income
(In millions, except per share information)202120202019
Net interest income 
Interest income$47,672 $51,585 $71,236 
Interest expense4,738 8,225 22,345 
Net interest income42,934 43,360 48,891 
Noninterest income 
Fees and commissions39,299 34,551 33,015 
Market making and similar activities8,691 8,355 9,034 
Other income(1,811)(738)304 
Total noninterest income46,179 42,168 42,353 
Total revenue, net of interest expense89,113 85,528 91,244 
Provision for credit losses(4,594)11,320 3,590 
Noninterest expense
Compensation and benefits36,140 32,725 31,977 
Occupancy and equipment7,138 7,141 6,588 
Information processing and communications5,769 5,222 4,646 
Product delivery and transaction related3,881 3,433 2,762 
Marketing1,939 1,701 1,934 
Professional fees1,775 1,694 1,597 
Other general operating3,089 3,297 5,396 
Total noninterest expense59,731 55,213 54,900 
Income before income taxes33,976 18,995 32,754 
Income tax expense1,998 1,101 5,324 
Net income$31,978 $17,894 $27,430 
Preferred stock dividends1,421 1,421 1,432 
Net income applicable to common shareholders$30,557 $16,473 $25,998 
Per common share information 
Earnings$3.60 $1.88 $2.77 
Diluted earnings3.57 1.87 2.75 
Average common shares issued and outstanding8,493.3 8,753.2 9,390.5 
Average diluted common shares issued and outstanding8,558.4 8,796.9 9,442.9 
Consolidated Statement of Comprehensive Income
(Dollars in millions)202120202019
Net income$31,978 $17,894 $27,430 
Other comprehensive income (loss), net-of-tax:
Net change in debt securities(2,077)4,799 5,875 
Net change in debit valuation adjustments356 (498)(963)
Net change in derivatives(2,306)826 616 
Employee benefit plan adjustments624 (98)136 
Net change in foreign currency translation adjustments(45)(52)(86)
Other comprehensive income (loss)(3,448)4,977 5,578 
Comprehensive income$28,530 $22,871 $33,008 


















See accompanying Notes to Consolidated Financial Statements.
Bank of America 90


Bank of America Corporation and Subsidiaries
Consolidated Balance Sheet
December 31
(Dollars in millions)20212020
Assets
Cash and due from banks$29,222 $36,430 
Interest-bearing deposits with the Federal Reserve, non-U.S. central banks and other banks318,999 344,033 
Cash and cash equivalents348,221 380,463 
Time deposits placed and other short-term investments7,144 6,546 
Federal funds sold and securities borrowed or purchased under agreements to resell
   (includes $150,665 and $108,856 measured at fair value)
250,720 304,058 
Trading account assets (includes $103,434 and $91,510 pledged as collateral)
247,080 198,854 
Derivative assets35,344 47,179 
Debt securities: 
Carried at fair value308,073 246,601 
Held-to-maturity, at cost (fair value – $665,890 and $448,180)
674,554 438,249 
Total debt securities982,627 684,850 
Loans and leases (includes $7,819 and $6,681 measured at fair value)
979,124 927,861 
Allowance for loan and lease losses(12,387)(18,802)
Loans and leases, net of allowance966,737 909,059 
Premises and equipment, net10,833 11,000 
Goodwill69,022 68,951 
Loans held-for-sale (includes $4,455 and $1,585 measured at fair value)
15,635 9,243 
Customer and other receivables72,263 64,221 
Other assets (includes $12,144 and $15,718 measured at fair value)
163,869 135,203 
Total assets$3,169,495 $2,819,627 
Liabilities  
Deposits in U.S. offices:  
Noninterest-bearing$784,189 $650,674 
Interest-bearing (includes $408 and $481 measured at fair value)
1,165,914 1,038,341 
Deposits in non-U.S. offices:
Noninterest-bearing27,457 17,698 
Interest-bearing86,886 88,767 
Total deposits2,064,446 1,795,480 
Federal funds purchased and securities loaned or sold under agreements to repurchase
   (includes $139,641 and $135,391 measured at fair value)
192,329 170,323 
Trading account liabilities100,690 71,320 
Derivative liabilities37,675 45,526 
Short-term borrowings (includes $4,279 and $5,874 measured at fair value)
23,753 19,321 
Accrued expenses and other liabilities (includes $11,489 and $16,311 measured at fair value
   and $1,456 and $1,878 of reserve for unfunded lending commitments)
200,419 181,799 
Long-term debt (includes $29,708 and $32,200 measured at fair value)
280,117 262,934 
Total liabilities2,899,429 2,546,703 
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 – 3,939,686 and 3,931,440 shares
24,708 24,510 
Common stock and additional paid-in capital, $0.01  par value; authorized – 12,800,000,000 shares;
   issued and outstanding – 8,077,831,463 and 8,650,814,105 shares
62,398 85,982 
Retained earnings188,064 164,088 
Accumulated other comprehensive income (loss)(5,104)(1,656)
Total shareholders’ equity270,066 272,924 
Total liabilities and shareholders’ equity$3,169,495 $2,819,627 
Assets of consolidated variable interest entities included in total assets above (isolated to settle the liabilities of the variable interest entities)
Trading account assets$5,004 $5,225 
Loans and leases17,135 23,636 
Allowance for loan and lease losses(958)(1,693)
Loans and leases, net of allowance16,177 21,943 
All other assets189 1,387 
Total assets of consolidated variable interest entities$21,370 $28,555 
Liabilities of consolidated variable interest entities included in total liabilities above  
Short-term borrowings (includes $51 and $22 of non-recourse short-term borrowings)
$247 $454 
Long-term debt (includes $3,587 and $7,053 of non-recourse debt)
3,587 7,053 
All other liabilities (includes $7 and $16 of non-recourse liabilities)
7 16 
Total liabilities of consolidated variable interest entities$3,841 $7,523 
See accompanying Notes to Consolidated Financial Statements.
91 Bank of America


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, 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 
Net income31,978 31,978 
Net change in debt securities(2,077)(2,077)
Net change in debit valuation adjustments356 356 
Net change in derivatives(2,306)(2,306)
Employee benefit plan adjustments624 624 
Net change in foreign currency translation adjustments(45)(45)
Dividends declared:
Common(6,575)(6,575)
Preferred(1,421)(1,421)
Issuance of preferred stock2,169 2,169 
Redemption of preferred stock(1,971)(1,971)
Common stock issued under employee plans, net, and other42.3 1,542 (6)1,536 
Common stock repurchased(615.3)(25,126)(25,126)
Balance, December 31, 2021$24,708 8,077.8 $62,398 $188,064 $(5,104)$270,066 













See accompanying Notes to Consolidated Financial Statements.
Bank of America 92


Bank of America Corporation and Subsidiaries
Consolidated Statement of Cash Flows
(Dollars in millions)202120202019
Operating activities   
Net income$31,978 $17,894 $27,430 
Adjustments to reconcile net income to net cash provided by operating activities:   
Provision for credit losses(4,594)11,320 3,590 
Gains on sales of debt securities(22)(411)(217)
Depreciation and amortization1,898 1,843 1,729 
Net amortization of premium/discount on debt securities5,837 4,101 2,066 
Deferred income taxes(838)(1,737)2,435 
Stock-based compensation2,768 2,031 1,974 
Impairment of equity method investment  2,072 
Loans held-for-sale:
Originations and purchases(43,635)(19,657)(28,874)
Proceeds from sales and paydowns of loans originally classified as held for sale and instruments
from related securitization activities
34,684 19,049 30,191 
Net change in:
Trading and derivative assets/liabilities(22,104)16,942 7,920 
Other assets(34,455)(12,883)(11,113)
Accrued expenses and other liabilities16,639 (4,385)16,363 
Other operating activities, net4,651 3,886 6,211 
Net cash provided by (used in) operating activities(7,193)37,993 61,777 
Investing activities   
Net change in:
Time deposits placed and other short-term investments(598)561 387 
Federal funds sold and securities borrowed or purchased under agreements to resell53,338 (29,461)(13,466)
Debt securities carried at fair value:
Proceeds from sales6,893 77,524 52,006 
Proceeds from paydowns and maturities159,616 91,084 79,114 
Purchases(238,398)(194,877)(152,782)
Held-to-maturity debt securities:
Proceeds from paydowns and maturities124,880 93,835 34,770 
Purchases(362,736)(257,535)(37,115)
Loans and leases:
Proceeds from sales of loans originally classified as held for investment and instruments
from related securitization activities
10,396 13,351 12,201 
Purchases(5,164)(5,229)(5,963)
Other changes in loans and leases, net(58,039)36,571 (46,808)
Other investing activities, net(3,479)(3,489)(2,974)
Net cash used in investing activities(313,291)(177,665)(80,630)
Financing activities   
Net change in:
Deposits268,966 360,677 53,327 
Federal funds purchased and securities loaned or sold under agreements to repurchase22,006 5,214 (21,879)
Short-term borrowings4,432 (4,893)4,004 
Long-term debt:
Proceeds from issuance76,675 57,013 52,420 
Retirement(46,826)(47,948)(50,794)
Preferred stock:
Proceeds from issuance2,169 2,181 3,643 
Redemption(1,971)(1,072)(2,568)
Common stock repurchased(25,126)(7,025)(28,144)
Cash dividends paid(8,055)(7,727)(5,934)
Other financing activities, net(620)(601)(698)
Net cash provided by financing activities291,650 355,819 3,377 
Effect of exchange rate changes on cash and cash equivalents(3,408)2,756 (368)
Net increase (decrease) in cash and cash equivalents(32,242)218,903 (15,844)
Cash and cash equivalents at January 1380,463 161,560 177,404 
Cash and cash equivalents at December 31$348,221 $380,463 $161,560 
Supplemental cash flow disclosures
Interest paid$4,506 $8,662 $22,196 
Income taxes paid, net2,760 2,894 4,359 
See accompanying Notes to Consolidated Financial Statements.
93 Bank of America


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, which include the Corporation’s interests in affordable housing and renewable energy partnerships, are recorded 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.
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. In instances where the interest is negative, the Corporation’s policy is to present negative interest on financial assets as interest income and negative interest on financial liabilities as interest expense. For securities financing agreements that are accounted for under the fair value option, the changes in the fair value of these securities financing agreements 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, 2021 and 2020, the fair value of this collateral was $854.8 billion and $812.4 billion, of which $782.7 billion and $758.5 billion were sold or repledged. The primary source of this collateral is securities borrowed or purchased under agreements to resell.
The Corporation also pledges company-owned securities and loans as collateral in transactions that include repurchase agreements, securities loaned, public and trust deposits, U.S. Treasury tax and loan notes, and short-term borrowings. This collateral, which in some cases can be sold or repledged by the counterparties to the transactions, is parenthetically disclosed on the Consolidated Balance Sheet.
In certain cases, the Corporation has transferred assets to consolidated VIEs where those restricted assets serve as collateral for the interests issued by the VIEs. These assets are included on the Consolidated Balance Sheet in Assets of Consolidated VIEs.
In addition, the Corporation obtains collateral in connection with its derivative contracts. Required collateral levels vary depending on the credit risk rating and the type of counterparty. Generally, the Corporation accepts collateral in the form of cash, U.S. Treasury securities and other marketable securities. Based on provisions contained in master netting agreements, the Corporation nets cash collateral received against derivative assets. The Corporation also pledges collateral on its own derivative positions which can be applied against derivative liabilities.
Trading Instruments
Financial instruments utilized in trading activities are carried at fair value. Fair value is generally based on quoted market prices for the same or similar assets and liabilities. If these market prices are not available, fair values are estimated based on dealer quotes, pricing models, discounted cash flow methodologies, or similar techniques where the determination of fair value may require significant management judgment or estimation. Realized gains and losses are recorded on a trade-date basis. Realized and unrealized gains and losses are recognized in market making and similar activities.
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
Bank of America 94


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 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 expected credit losses (ECL), except for debt securities that are
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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 credit losses includes both quantitative and qualitative components. The qualitative component has a higher degree of management subjectivity, and includes factors such as concentrations, economic conditions and other considerations. The allowance for loan and lease losses represents the estimated probable credit 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 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 lending commitments is reported in the Consolidated Statement of Income at the amount necessary to adjust the allowance for credit instruments based on utilization assumptions. Lending-related credit exposures deemedlosses to be uncollectible, excludingthe current estimate of ECL.
For loans carried at fair value, are charged off against these accounts.

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The Corporation performs periodic and systematic detailed reviews of its lending portfolios to identify credit risks and to assessleases, 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,ECL 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
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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 loan-to-value (LTV) or, in the case of a subordinated lien, refreshed combined LTV (CLTV), borrower credit score, months since origination and
geography, all of which are further broken down by present collection status (whether the loan is current, delinquent, in
default, or in bankruptcy). The severity or loss given default is estimated based on the refreshed LTV for first-lien mortgages or CLTV for subordinated liens. The estimates are based on the Corporation’s historical experience with the loan portfolio, adjusted to reflect an assessment of environmental factors not yet reflected in the historical data 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 qualitative estimates which are maintained to cover uncertainties that affect the Corporation’s estimate of probable losses including domestic and global economic uncertainty and large single-name defaults.default.
For individually 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 part of the allowance for loan and
lease losses unless these are secured consumer loans that are solely dependent on collateral for repayment, in which case the amount that exceeds the fair value of the collateral is charged off.
Generally, the Corporation initially estimates 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 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.
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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 and LHFS are not reported as nonperforming. When a nonaccrual loan is deemed uncollectible, it is charged off against the allowance for credit losses. If the charged-off amount is later recovered, the amount is reversed through the allowance for credit losses at the recovery date. Charge-offs are reported net of recoveries (net charge-offs). If recoveries for the period are greater than charge-offs, net charge-offs are reported as a negative amount.
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

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property-secured loans (including auto loans) are charged off to collateral value no later than the end of the month in which the account becomes 120 days past due, or upon repossession of an auto or, for loans in bankruptcy, within 60 days of receipt of notification of filing. Credit card and other unsecured customer loans are charged off no later than the end of the month in which the account becomes 180 days past due, within 60 days after receipt of notification of death or bankruptcy, or upon confirmation of fraud.
Commercial loans and leases, excluding business card loans, that are past due 90 days or more as to principal or interest, or where reasonable doubt exists as to timely collection, including loans that are individually identified as being impaired, are generally placed on nonaccrual status and classified as nonperforming unless well-secured and in the process of collection.
Business card loans are charged off in the same manner as consumer credit card loans. Other commercial loans and leases are generally charged off when all or a portion of the principal amount is determined to be uncollectible.
The entire balance of a consumer loan or commercial loan or lease is contractually delinquent if the minimum payment is not received by the specified due date on the customer’s billing statement. Interest and fees continue to accrue on past due loans and leases until the date the loan is placed on nonaccrual status, if applicable. Accrued interest receivable is reversed when loans and leases are placed on nonaccrual status. Interest collections on nonaccruing loans and leases for which the ultimate collectability of principal is uncertain are applied as principal reductions; otherwise, such collections are credited to income when received. Loans and leases may be restored to accrual status when all principal and interest is current and full repayment of the remaining contractual principal and interest is expected.
Troubled Debt Restructurings
Consumer and commercial loans and leases whose contractual terms have been restructured in a manner that grants a concession to a borrower experiencing financial difficulties are classified as TDRs. Concessions could include a reduction in the interest rate to a rate that is below market on the loan, payment extensions, forgiveness of principal, forbearance or other actions designed to maximize collections. Loans that are carried at fair value and LHFS are not classified as TDRs.
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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 Coronavirus Disease 2019 (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 expired on January 1, 2022. 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 with interest recorded in interest income and changes in fair value recorded in other income. Loan origination costs related to LHFS that the Corporation accounts for under the fair value option are recognized in noninterest expense when incurred.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, 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 zero. For all other assets, the Corporation performs qualitative analyses, including consideration of historical losses and current economic conditions, to estimate any ECL which are then included in a valuation account that is recorded as a contra-asset against the amortized cost basis of the financial asset.
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.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
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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

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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. IfThe 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 is performed to measure potential impairment.
This step involves calculating an implied fair value ofa goodwill which isimpairment loss would be recognized for the excess of the fair value ofamount by which 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 not have the power to direct the most significant activities of a residential mortgage agency trust except in certain circumstances in which the Corporation holds substantially all of the issued securities and has the unilateral right to liquidate the trust. The power to direct the most significant activities of a commercial mortgage securitization trust is typically held by the special servicer or by the party holding specific subordinate securities which embody certain controlling rights. The Corporation consolidates a whole-loan securitization trust if it has the power to direct the most significant activities and also holds securities issued by the trust or has other contractual arrangements, other than standard representations and warranties, that could potentially be significant to the trust.
The Corporation may also transfer trading account securities and AFS securities into municipal bond or resecuritization trusts. The Corporation consolidates a municipal bond or resecuritization trust if it has control over the ongoing activities of the trust such as the remarketing of the trust’s liabilities or, if there are no ongoing activities, sole discretion over the design of the trust, including the identification of securities to be transferred in and the structure of securities to be issued, and also retains securities or has liquidity or other commitments that could potentially be significant to the trust. The Corporation does not consolidate a municipal bond or resecuritization trust if one or a limited number of third-party investors share responsibility for the design of the trust or have control over the significant activities of the trust through liquidation or other substantive rights.
Other VIEs used by the Corporation include collateralized debt obligations (CDOs), investment vehicles created on behalf of customers and other investment vehicles. The Corporation does not routinely serve as collateral manager for CDOs and, therefore, does not typically have the power to direct the activities that most significantly impact the economic performance of a CDO. However, following an event of default, if the Corporation is a majority holder of senior securities issued by a CDO and acquires the power to manage its assets, the Corporation consolidates the CDO.
The Corporation consolidates a customer or other investment vehicle if it has control over the initial design of the vehicle or manages the assets in the vehicle and also absorbs potentially significant gains or losses through an investment in the vehicle, derivative contracts or other arrangements. The Corporation does not consolidate an investment vehicle if a single investor controlled the initial design of the vehicle or manages the assets in the vehicles or if the Corporation does not have a variable interest that could potentially be significant to the vehicle.
Retained interests in securitized assets are initially recorded at fair value. In addition, the Corporation may invest in debt securities issued by unconsolidated VIEs. Fair values of these debt securities, which are classified as trading account assets, debt securities carried at fair value or HTM securities, are based primarily on quoted market prices in active or inactive markets. Generally, quoted market prices for retained residual interests
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are not available; therefore, the Corporation estimates fair values based on the present value of the associated expected future cash flows.
Fair Value
The Corporation measures the fair values of its assets and liabilities, where applicable, in accordance with accounting guidance that requires an entity to base fair value on exit price. Under this guidance, an entity is required to maximize the use of observable inputs and minimize the use of unobservable inputs in measuring fair value. Under applicable accounting standards, fair value measurements are categorized into one of three levels

Bank of America 98


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 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 fees earned from 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 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
101 Bank of America


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.

99Bank of America






Brokerage fees include income earned from transaction-based services that are performed as part of investment management services and are based on a fixed price per unit or as a percentage of the total transaction amount. Brokerage fees also include distribution fees and sales commissions that are primarily in the Global Wealth & Investment Management (GWIM) segment and are earned over time. In addition, primarily in the Global Markets segment, brokerage fees are earned when the Corporation fills customer orders to buy or sell various financial products or when it acknowledges, affirms, settles and clears transactions and/or submits trade information to the appropriate clearing broker. Certain customers pay brokerage, clearing and/or exchange fees imposed by relevant regulatory bodies or exchanges in order to execute or clear trades. These fees are recorded net and are not reflected in the transaction price, as the Corporation is an agent for those services.
Investment Banking Income
Investment banking income includes underwriting income and financial advisory services income. Underwriting consists of fees earned for the placement of a customer’s debt or equity securities. The revenue is generally earned based on a percentage of the fixed number of shares or principal placed. Once the number of shares or notes is determined and the service is completed, the underwriting fees are recognized. The Corporation incurs certain out-of-pocket expenses, such as legal costs, in performing these services. These expenses are recovered through the revenue the Corporation earns from the customer and are included in operating expenses. Syndication fees represent fees earned as the agent or lead lender responsible for structuring, arranging and administering a loan syndication.
Financial advisory services consist of fees earned for assisting clients with transactions related to mergers and acquisitions and financial restructurings. Revenue varies depending on the size of the transaction and scope of services performed and is generally contingent on successful completion of the transaction. Revenue is typically recognized once the transaction is completed and all services have been rendered. Additionally, the Corporation may earn a fixed fee in merger and acquisition transactions to provide a fairness opinion, with the fees recognized when the opinion is delivered to the client.
Other Revenue Measurement and Recognition Policies
The Corporation did not disclose the value of any open performance obligations at December 31, 2019,2021, 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 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. At December 31, 2021 and 2020, the Corporation had approximately 67,000 and 332,000 PPP loans with a carrying value of $4.7 billion and $22.7 billion. As compensation for originating the loans, the Corporation received lender processing fees from the SBA, which were capitalized, along with the loan origination costs, and are being 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 are recognized as interest income in that period.





Bank of America 100102



NOTE 2 Net Interest Income and Noninterest Income
The table below presents the Corporation’s net interest income and noninterest income disaggregated by revenue source for 2019, 20182021, 2020 and 2017.2019. For more information, see Note 1 – Summary of Significant Accounting PrinciplesPrinciples. . For a disaggregation of noninterest income by business segment and All Other, see Note 2423 – Business Segment Information.
(Dollars in millions)202120202019
Net interest income
Interest income
Loans and leases$29,282 $34,029 $43,086 
Debt securities12,376 9,790 11,806 
Federal funds sold and securities borrowed or purchased under agreements to resell (1)
(90)903 4,843 
Trading account assets3,770 4,128 5,196 
Other interest income2,334 2,735 6,305 
Total interest income47,672 51,585 71,236 
Interest expense
Deposits537 1,943 7,188 
Short-term borrowings (1)
(358)987 7,208 
Trading account liabilities1,128 974 1,249 
Long-term debt3,431 4,321 6,700 
Total interest expense4,738 8,225 22,345 
Net interest income$42,934 $43,360 $48,891 
Noninterest income
Fees and commissions
Card income
Interchange fees (2)
$4,560 $3,954 $3,834 
Other card income1,658 1,702 1,963 
Total card income6,218 5,656 5,797 
Service charges
Deposit-related fees6,271 5,991 6,588 
Lending-related fees1,233 1,150 1,086 
Total service charges7,504 7,141 7,674 
Investment and brokerage services
Asset management fees12,729 10,708 10,241 
Brokerage fees3,961 3,866 3,661 
Total investment and brokerage services16,690 14,574 13,902 
Investment banking fees
Underwriting income5,077 4,698 2,998 
Syndication fees1,499 861 1,184 
Financial advisory services2,311 1,621 1,460 
Total investment banking fees8,887 7,180 5,642 
Total fees and commissions39,299 34,551 33,015 
Market making and similar activities8,691 8,355 9,034 
Other income (loss)(1,811)(738)304 
Total noninterest income$46,179 $42,168 $42,353 
(1)For more information on negative interest, see Note 1 – Summary of Significant Accounting Principles.
(2)Gross interchange fees and merchant income were $11.5 billion, $9.2 billion and $10.0 billion for 2021, 2020 and 2019, respectively, and are presented net of $6.9 billion, $5.5 billion and $6.2 billion of expenses for rewards and partner payments as well as certain other card costs for the same periods.
      
(Dollars in millions)2019 2018 2017
Net interest income     
Interest income     
Loans and leases$43,086
 $40,811
 $36,221
Debt securities11,806
 11,724
 10,471
Federal funds sold and securities borrowed or purchased under agreements to resell4,843
 3,176
 2,390
Trading account assets5,196
 4,811
 4,474
Other interest income6,305
 6,247
 4,023
Total interest income71,236

66,769

57,579
      
Interest expense     
Deposits7,188
 4,495
 1,931
Short-term borrowings7,208
 5,839
 3,538
Trading account liabilities1,249
 1,358
 1,204
Long-term debt6,700
 6,915
 5,667
Total interest expense22,345

18,607

12,340
Net interest income$48,891

$48,162

$45,239
      
Noninterest income     
Fees and commissions     
Card income     
Interchange fees (1)
$3,834
 $3,866
 $3,777
Other card income1,963
 1,958
 1,899
Total card income5,797
 5,824

5,676
Service charges     
Deposit-related fees6,588
 6,667
 6,708
Lending-related fees1,086
 1,100
 1,110
Total service charges7,674
 7,767

7,818
Investment and brokerage services     
Asset management fees10,241
 10,189
 9,310
Brokerage fees3,661
 3,971
 4,526
Total investment and brokerage services13,902
 14,160

13,836
Investment banking fees     
Underwriting income2,998
 2,722
 2,821
Syndication fees1,184
 1,347
 1,499
Financial advisory services1,460
 1,258
 1,691
Total investment banking fees5,642
 5,327

6,011
Total fees and commissions33,015

33,078

33,341
Market making and similar activities9,034
 9,008
 7,102
Other income304
 772
 1,444
Total noninterest income$42,353
 $42,858

$41,887
(1)
Gross interchange fees were $10.0 billion, $9.5 billion and $8.8 billion for 2019, 2018 and 2017, respectively, and are presented net of $6.2 billion, $5.6 billion and $5.1 billion of expenses for rewards and partner payments for the same periods.

101103 Bank of America







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, 20192021 and 2018.2020. 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, 2021
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$18,068.1 $150.5 $8.9 $159.4 $156.4 $4.4 $160.8 
Futures and forwards2,243.2 1.1  1.1 1.0  1.0 
Written options1,616.1    28.8  28.8 
Purchased options1,673.6 33.1  33.1    
Foreign exchange contracts 
Swaps1,420.9 28.6 0.2 28.8 30.5 0.2 30.7 
Spot, futures and forwards4,087.2 37.1 0.3 37.4 37.7 0.2 37.9 
Written options287.2    4.1  4.1 
Purchased options267.6 4.1  4.1    
Equity contracts 
Swaps443.8 12.3  12.3 14.5  14.5 
Futures and forwards113.3 0.5  0.5 1.7  1.7 
Written options737.7    58.5  58.5 
Purchased options657.0 55.9  55.9    
Commodity contracts  
Swaps47.7 3.1  3.1 6.0  6.0 
Futures and forwards101.5 2.3  2.3 0.3 1.1 1.4 
Written options44.4    2.6  2.6 
Purchased options38.3 3.2  3.2    
Credit derivatives (2)
   
Purchased credit derivatives:   
Credit default swaps297.0 1.9  1.9 4.3  4.3 
Total return swaps/options85.3 0.2  0.2 1.1  1.1 
Written credit derivatives:  
Credit default swaps279.8 4.2  4.2 1.6  1.6 
Total return swaps/options85.3 0.9  0.9 0.5  0.5 
Gross derivative assets/liabilities$339.0 $9.4 $348.4 $349.6 $5.9 $355.5 
Less: Legally enforceable master netting agreements  (282.3)  (282.3)
Less: Cash collateral received/paid   (30.8)  (35.5)
Total derivative assets/liabilities   $35.3   $37.7 
              
   December 31, 2019
   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$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.
(1)
(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 $2.3 billion and $258.4 billion at December 31, 2021.
Represents the total contract/notional amount of derivative assets and liabilities outstanding.
(2)
The net derivative asset (liability) and notional amount of written credit derivatives for which the Corporation held purchased credit derivatives with identical underlying referenced names were $2.8 billion and $309.7 billion at December 31, 2019.

Bank of America 102104


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 — 3.6 
Written options1,530.5 — — — 40.5 — 40.5 
Purchased options1,545.8 45.3 — 45.3 — — — 
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 — 53.4 54.5 0.5 55.0 
Written options289.6 — — — 4.8 — 4.8 
Purchased options279.3 5.0 — 5.0 — — — 
Equity contracts       
Swaps320.2 13.3 — 13.3 14.5 — 14.5 
Futures and forwards106.2 0.3 — 0.3 1.4 — 1.4 
Written options599.1 — — — 48.8 — 48.8 
Purchased options541.2 52.6 — 52.6 — — — 
Commodity contracts       
Swaps36.4 1.9 — 1.9 4.4 — 4.4 
Futures and forwards63.6 2.0 — 2.0 1.0 — 1.0 
Written options24.6 — — — 1.4 — 1.4 
Purchased options24.7 1.5 — 1.5 — — — 
Credit derivatives (2)
       
Purchased credit derivatives:       
Credit default swaps322.7 2.3 — 2.3 4.4 — 4.4 
Total return swaps/options63.6 0.2 — 0.2 1.0 — 1.0 
Written credit derivatives:      
Credit default swaps301.5 4.4 — 4.4 1.9 — 1.9 
Total return swaps/options68.6 0.6 — 0.6 0.4 — 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 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, 2018
   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$15,977.9
 $141.0
 $3.2
 $144.2
 $138.9
 $2.0
 $140.9
Futures and forwards3,656.6
 4.7
 
 4.7
 5.0
 
 5.0
Written options1,584.9
 
 
 
 28.6
 
 28.6
Purchased options1,614.0
 30.8
 
 30.8
 
 
 
Foreign exchange contracts   
  
  
  
  
  
Swaps1,704.8
 38.8
 1.4
 40.2
 42.2
 2.3
 44.5
Spot, futures and forwards4,276.0
 39.8
 0.4
 40.2
 39.3
 0.3
 39.6
Written options256.7
 
 
 
 5.0
 
 5.0
Purchased options240.4
 4.6
 
 4.6
 
 
 
Equity contracts 
  
  
  
  
  
  
Swaps253.6
 7.7
 
 7.7
 8.4
 
 8.4
Futures and forwards100.0
 2.1
 
 2.1
 0.3
 
 0.3
Written options597.1
 
 
 
 27.5
 
 27.5
Purchased options549.4
 36.0
 
 36.0
 
 
 
Commodity contracts 
  
  
  
  
  
  
Swaps43.1
 2.7
 
 2.7
 4.5
 
 4.5
Futures and forwards51.7
 3.2
 
 3.2
 0.5
 
 0.5
Written options27.5
 
 
 
 2.2
 
 2.2
Purchased options23.4
 1.7
 
 1.7
 
 
 
Credit derivatives (2)
 
  
  
  
  
  
  
Purchased credit derivatives: 
  
  
  
  
  
  
Credit default swaps408.1
 5.3
 
 5.3
 4.9
 
 4.9
Total return swaps/options84.5
 0.4
 
 0.4
 1.0
 
 1.0
Written credit derivatives: 
  
  
  
    
  
Credit default swaps371.9
 4.4
 
 4.4
 4.3
 
 4.3
Total return swaps/options87.3
 0.6
 
 0.6
 0.6
 
 0.6
Gross derivative assets/liabilities 
 $323.8
 $5.0
 $328.8
 $313.2
 $4.6
 $317.8
Less: Legally enforceable master netting agreements 
  
  
 (252.7)  
  
 (252.7)
Less: Cash collateral received/paid 
  
  
 (32.4)  
  
 (27.2)
Total derivative assets/liabilities 
  
  
 $43.7
  
  
 $37.9
(1)
Represents the total contract/notional amount of derivative assets and liabilities outstanding.
(2)
The net derivative asset (liability) and notional amount of written credit derivatives for which the Corporation held purchased credit derivatives with identical underlying referenced names were $(185) million and $342.8 billion at December 31, 2018.
Offsetting of Derivatives
The Corporation enters into International Swaps and Derivatives Association, Inc. (ISDA) master netting agreements or similar agreements with substantially all of the Corporation’s derivative counterparties. Where legally enforceable, these master netting agreements give the Corporation, in the event of default by the counterparty, the right to liquidate securities held as collateral and to offset receivables and payables with the same counterparty. For purposes of the Consolidated Balance Sheet, the Corporation offsets derivative assets and liabilities and cash collateral held with the same counterparty where it has such a legally enforceable master netting agreement.
The following table presents derivative instruments included in derivative assets and liabilities on the Consolidated Balance
Sheet at December 31, 20192021 and 20182020 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 1110 Federal Funds Sold or Purchased, Securities Financing Agreements, Short-term Borrowings and Restricted Cash.

103105 Bank of America






        
Offsetting of Derivatives (1)
       
        
 
Derivative
Assets
 Derivative Liabilities 
Derivative
Assets
 Derivative Liabilities
(Dollars in billions)December 31, 2019 December 31, 2018
Interest rate contracts 
  
  
  
Over-the-counter$203.1
 $196.6
 $174.2
 $169.4
Exchange-traded0.1
 0.1
 
 
Over-the-counter cleared6.0
 5.3
 4.8
 4.0
Foreign exchange contracts       
Over-the-counter69.2
 73.1
 82.5
 86.3
Over-the-counter cleared0.5
 0.5
 0.9
 0.9
Equity contracts       
Over-the-counter21.3
 17.8
 24.6
 14.6
Exchange-traded26.4
 22.8
 16.1
 15.1
Commodity contracts       
Over-the-counter2.8
 4.2
 3.5
 4.5
Exchange-traded0.8
 0.8
 1.0
 0.9
Over-the-counter cleared
 0.1
 
 
Credit derivatives       
Over-the-counter6.4
 6.6
 7.7
 8.2
Over-the-counter cleared2.5
 2.2
 2.5
 2.3
Total gross derivative assets/liabilities, before netting       
Over-the-counter302.8
 298.3
 292.5
 283.0
Exchange-traded27.3
 23.7
 17.1
 16.0
Over-the-counter cleared9.0
 8.1
 8.2
 7.2
Less: Legally enforceable master netting agreements and cash collateral received/paid       
Over-the-counter(274.7) (269.3) (264.4) (259.2)
Exchange-traded(21.5) (21.5) (13.5) (13.5)
Over-the-counter cleared(8.1) (8.1) (7.2) (7.2)
Derivative assets/liabilities, after netting34.8
 31.2
 32.7
 26.3
Other gross derivative assets/liabilities (2)
5.7
 7.0
 11.0
 11.6
Total derivative assets/liabilities40.5
 38.2
 43.7
 37.9
Less: Financial instruments collateral (3)
(14.6) (16.1) (16.3) (8.6)
Total net derivative assets/liabilities$25.9
 $22.1
 $27.4
 $29.3
(1)


Offsetting of Derivatives (1)
Derivative
Assets
Derivative
 Liabilities
Derivative
Assets
Derivative
 Liabilities
(Dollars in billions)December 31, 2021December 31, 2020
Interest rate contracts    
Over-the-counter$171.3 $166.3 $247.7 $243.5 
Exchange-traded0.2  — — 
Over-the-counter cleared22.6 22.5 10.2 9.1 
Foreign exchange contracts
Over-the-counter67.9 70.5 92.2 96.5 
Over-the-counter cleared1.1 1.1 1.4 1.3 
Equity contracts
Over-the-counter29.2 32.9 31.3 28.3 
Exchange-traded38.3 38.4 32.3 31.0 
Commodity contracts
Over-the-counter6.1 7.6 3.5 5.0 
Exchange-traded1.4 1.3 0.7 0.7 
Over-the-counter cleared0.1 0.1 — — 
Credit derivatives
Over-the-counter5.2 5.3 5.2 5.6 
Over-the-counter cleared1.8 1.8 2.2 1.9 
Total gross derivative assets/liabilities, before netting
Over-the-counter279.7 282.6 379.9 378.9 
Exchange-traded39.9 39.7 33.0 31.7 
Over-the-counter cleared25.6 25.5 13.8 12.3 
Less: Legally enforceable master netting agreements and cash collateral received/paid
Over-the-counter(250.3)(254.6)(345.7)(347.2)
Exchange-traded(37.8)(37.8)(29.5)(29.5)
Over-the-counter cleared(25.0)(25.4)(12.2)(11.8)
Derivative assets/liabilities, after netting32.1 30.0 39.3 34.4 
Other gross derivative assets/liabilities (2)
3.2 7.7 7.9 11.1 
Total derivative assets/liabilities35.3 37.7 47.2 45.5 
Less: Financial instruments collateral (3)
(11.8)(10.6)(16.1)(16.6)
Total net derivative assets/liabilities$23.5 $27.1 $31.1 $28.9 
(1)Over-the-counter derivatives include bilateral transactions between the Corporation and a particular counterparty. Over-the-counter 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. Exchange-traded derivatives include listed options transacted on an exchange.
(2)
Consists of derivatives entered into under master netting agreements where the enforceability of these agreements is uncertain under bankruptcy laws in some countries or industries.
(3)
Amounts are limited to the derivative asset/liability balance and, accordingly, do not include excess collateral received/pledged. Financial instruments collateral includes securities collateral received or pledged and cash securities held and posted at third-party custodians that are not offset on the Consolidated Balance Sheet but shown as a reduction to derive net derivative assets and liabilities.
ALM and Risk Management Derivatives
The Corporation’s ALM and risk management activities include the use of derivatives to mitigate risk to the Corporation including derivatives designated in qualifying hedge accounting relationships and derivatives used in other risk management activities. Interest rate, foreign exchange, equity, commodity and credit contracts are utilized in the Corporation's ALM and risk management activities.
The Corporation maintains an overall interest rate risk management strategy that incorporates the use of interest rate contracts, which are generally non-leveraged generic interest rate and basis swaps, options, futures and forwards, to minimize significant fluctuations in earnings caused by interest rate volatility. The Corporation’s goal is to manage interest rate sensitivity and volatility so that movements in interest rates do not significantly adversely affect earnings or capital. As a result of interest rate fluctuations, hedged fixed-rate assets and liabilities appreciate or depreciate in fair value. Gains or losses on the derivative instruments that are linked to the hedged fixed-rate assets and liabilities are expected to substantially offset this unrealized appreciation or depreciation.
Market risk, including interest rate risk, can be substantial in the mortgage business. Market risk in the mortgage business is the risk that values of mortgage assets or revenues will be adversely affected by changes in market conditions such as interest rate movements. To mitigate the interest rate risk in mortgage banking production income, the Corporation utilizes
forward loan sale commitments and other derivative instruments, including purchased options, and certain debt securities. The
Corporation also utilizes derivatives such as interest rate options, interest rate swaps, forward settlement contracts and eurodollar futures to hedge certain market risks of MSRs.
The Corporation uses foreign exchange contracts to manage the foreign exchange risk associated with certain foreign currency-denominated assets and liabilities, as well as the Corporation’s investments in non-U.S. subsidiaries. Exposure to loss on these contracts will increase or decrease over their respective lives as currency exchange and interest rates fluctuate.
The Corporation purchases credit derivatives to manage credit risk related to certain funded and unfunded credit exposures. Credit derivatives include credit default swaps (CDS), total return swaps and swaptions. These derivatives are recorded on the Consolidated Balance Sheet at fair value with changes in fair value recorded in other income.
Derivatives Designated as Accounting Hedges
The Corporation uses various types of interest rate and foreign exchange derivative contracts to protect against changes in the fair value of its assets and liabilities due to fluctuations in interest rates and exchange rates (fair value hedges). The Corporation also uses these types of contracts to protect against changes in the cash flows of its assets and liabilities,
Bank of America 106


and other forecasted transactions (cash flow hedges). The Corporation hedges its net investment in consolidated non-U.S. operations determined to have functional currencies other than the U.S. dollar using forward exchange contracts and cross-currency basis swaps, and by issuing foreign currency-denominated debt (net investment hedges).

Bank of America 104


Fair Value Hedges
The table below summarizes information related to fair value hedges for 2021, 2020 and 2019.
Gains and Losses on Derivatives Designated as Fair Value Hedges
DerivativeHedged Item
(Dollars in millions)202120202019202120202019
Interest rate risk on long-term debt (1)
$(7,018)$7,091 $6,113 $6,838 $(7,220)$(6,110)
Interest rate and foreign currency risk on long-term debt (2)
(90)783 119 79 (783)(101)
Interest rate risk on available-for-sale securities (3)
5,203 (44)(102)(5,167)49 98 
Total$(1,905)$7,830 $6,130 $1,750 $(7,954)$(6,113)
(1)Amounts are recorded in interest expense in the Consolidated Statement of Income.
(2)For 2021, 2020 and 2019, 2018the derivative amount includes gains (losses) of $(73) million, $701 million and 2017.
            
Gains and Losses on Derivatives Designated as Fair Value Hedges      
            
 Derivative Hedged Item
(Dollars in millions)2019 2018 2017 2019 2018 2017
Interest rate risk on long-term debt (1)
$6,113
 $(1,538) $(1,537) $(6,110) $1,429
 $1,045
Interest rate and foreign currency risk on long-term debt (2)
119
 (1,187) 1,811
 (101) 1,079
 (1,767)
Interest rate risk on available-for-sale securities (3)
(102) (52) (67) 98
 50
 35
Total$6,130
 $(2,777) $207
 $(6,113) $2,558
 $(687)

$73 million in interest expense, $0, $73 million and $28 million in market making and similar activities, and $(17) million, $9 million and $18 million in accumulated OCI, respectively. Line item totals are in the Consolidated Statement of Income and on the Consolidated Balance Sheet.
(1)
(3)Amounts are recorded in interest income in the Consolidated Statement of Income.
Amounts are recorded in interest expense in the Consolidated Statement of Income.
(2)
In 2019, 2018 and 2017, the derivative amount includes gains (losses) of $73 million, $(116) million and $(365) million in interest expense, $28 million, $(992) million and $2.2 billion in market making and similar activities, and $18 million and $(79) million in accumulated OCI, respectively. Line item totals are in the Consolidated Statement of Income and in the Consolidated Balance Sheet.
(3)
Amounts are recorded in interest income in the Consolidated Statement of Income.
The table below summarizes the carrying value of hedged assets and liabilities that are designated and qualifying in fair value hedging relationships along with the cumulative amount of fair value hedging adjustments included in the carrying value that have been recorded in the current hedging relationships. These fair value hedging adjustments are open basis adjustments that are not subject to amortization as long as the hedging relationship remains designated.
Designated Fair Value Hedged Assets and Liabilities
December 31, 2021December 31, 2020
(Dollars in millions)Carrying Value
Cumulative
Fair Value
 Adjustments (1)
Carrying Value
Cumulative
Fair Value
 Adjustments (1)
Long-term debt (2)
$181,745 $3,987 $150,556 $8,910 
Available-for-sale debt securities (2, 3, 4)
209,038 (2,294)116,252 114 
Trading account assets (5)
2,067 32 427 15 
        
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, 2019 December 31, 2018
Long-term debt (2)
$(162,389) $(8,685) $(138,682) $(2,117)
Available-for-sale debt securities (2)
1,654
 64
 981
 (29)
(1)Increase (decrease) to carrying value.
(1)
(2)At December 31, 2021 and 2020, the cumulative fair value adjustments remaining on long-term debt and available-for-sale debt securities from discontinued hedging relationships resulted in an increase in the related liability of $1.5 billion and $3.7 billion and a decrease in the related asset of $1.0 billion and $69 million, which are being amortized over the remaining contractual life of the de-designated hedged items.
(3)These amounts include the amortized cost 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, 2021 and 2020, the amortized cost of the closed portfolios used in these hedging relationships was $21.1 billion and $34.6 billion, of which $6.9 billion and $7.0 billion was designated in the last-of-layer hedging relationship. At December 31, 2021, the cumulative adjustment associated with these hedging relationships was a decrease of $172 million. At December 31, 2020, the cumulative adjustment was insignificant.
(4)Carrying value represents amortized cost.
(5)Represents hedging activities related to certain commodities inventory.
For assets, increase (decrease) to carrying value and for liabilities, (increase) decrease to carrying value.
(2)
At December 31, 2019 and 2018, the cumulative fair value adjustments remaining on long-term debt and AFS debt securities from discontinued hedging relationships resulted in a decrease in the related liability of $1.3 billion and $1.6 billion and an increase (decrease) in the related asset of $8 million and $(29) million, which are being amortized over the remaining contractual life of the de-designated hedged items.
Cash Flow and Net Investment Hedges
The following table below summarizes certain information related to cash flow hedges and net investment hedges for 2019, 20182021, 2020 and 2017.2019. Of the $400 million$1.9 billion after-tax net loss ($526 million2.5 billion pretax) on derivatives in accumulated OCI at December 31, 2019, $682021, gains of $477 million after-tax ($90630 million pretax) isrelated to both open and terminated cash flow 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. 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 1615 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)202120202019202120202019
Cash flow hedges
Interest rate risk on variable-rate assets (1)
$(2,686)$763 $671 $148 $(7)$(104)
Price risk on forecasted MBS purchases (1)
(249)241 — 26 — 
Price risk on certain compensation plans (2)
93 85 34 55 12 (2)
Total$(2,842)$1,089 $705 $229 $14 $(106)
Net investment hedges
Foreign exchange risk (3)
$1,451 $(834)$22 $23 $$366 
            
Gains and Losses on Derivatives Designated as Cash Flow and Net Investment Hedges   
            
 
Gains (Losses) in
 Accumulated OCI on Derivatives
 
Gains (Losses) in Income
Reclassified from Accumulated OCI
(Dollars in millions, amounts pretax)2019 2018 2017 2019 2018 2017
Cash flow hedges           
Interest rate risk on variable-rate assets (1)
$671
 $(159) $(109) $(104) $(165) $(327)
Price risk on certain compensation plans (2)
34
 4
 59
 (2) 27
 148
Total$705
 $(155) $(50) $(106) $(138) $(179)
Net investment hedges 
  
  
  
  
  
Foreign exchange risk (3)
$22
 $989
 $(1,588) $366
 $411
 $1,782

(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 $(123) million, $(11) million and $154 million in 2021, 2020 and 2019, respectively.
(1)107 Bank of America
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 of $154 million, $47 million and $120 million in 2019, 2018 and 2017, respectively.
Other Risk Management Derivatives
Other risk management derivatives are used by the Corporation to reduce certain risk exposures by economically hedging various assets and liabilities. The following table below presents gains (losses) on these derivatives for 2019, 20182021, 2020 and 2017.2019. 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)202120202019
Interest rate risk on mortgage activities (1, 2)
$(18)$611 $388 
Credit risk on loans (2)
(25)(68)(58)
Interest rate and foreign currency risk on asset and liability management activities (3)
1,757 (2,971)1,112 
Price risk on certain compensation plans (4)
917 700 943 
(1)Includes hedges of interest rate risk on MSRs and IRLCs to originate mortgage loans that will be held for sale.
(2)Gains (losses) on these derivatives are recorded in other income.
105Bank of America(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.






      
Gains and Losses on Other Risk Management Derivatives
      
(Dollars in millions)2019 2018 2017
Interest rate risk on mortgage activities (1, 2)
$315
 $(107) $8
Credit risk on loans (2)
(58) 9
 (6)
Interest rate and foreign currency risk on ALM activities (3)
1,112
 3,278
 (1,318)
Price risk on certain compensation plans (4)
943
 (495) 704

(1)
Primarily related to hedges of interest rate risk on MSRs and IRLCs to originate mortgage loans that will be held for sale. The net gains on IRLCs, which are not included in the table but are considered derivative instruments, were $73 million, $47 million and $220 million in 2019, 2018 and 2017, respectively.
(2)
Gains (losses) on these derivatives are recorded in other income.
(3)
Gains (losses) on these derivatives are recorded in market making and similar activities. Prior-period amounts have been updated to conform to the current-period presentation.
(4)
Gains (losses) on these derivatives are recorded in compensation and benefits expense.
Transfers of Financial Assets with Risk Retained through Derivatives
The Corporation enters into certain transactions involving the transfer of financial assets that are accounted for as sales where substantially all of the economic exposure to the transferred financial assets is retained through derivatives (e.g., interest rate and/or credit), but the Corporation does not retain control over the assets transferred. As ofAt December 31, 20192021 and 2018,2020, the Corporation had transferred $5.2$4.8 billion and $5.8$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 $5.2$4.8 billion and $5.8$5.2 billion at the transfer dates. At December 31, 20192021 and 2018,2020, the fair value of the transferred securities was $5.3$5.0 billion and $5.5 billion.
Sales and Trading Revenue
The Corporation enters into trading derivatives to facilitate client transactions and to manage risk exposures arising from trading account assets and liabilities. It is the Corporation’s policy to include these derivative instruments in its trading activities, which include derivatives and non-derivative cash instruments. The resulting risk from these derivatives is managed on a portfolio basis as part of the Corporation’s Global Markets business segment. The related sales and trading revenue generated within Global Markets is recorded in various income statement line items, including market making and similar activities and net interest income as well as other revenue categories.
Sales and trading revenue includes changes in the fair value and realized gains and losses on the sales of trading and other assets, net interest income, and fees primarily from commissions on equity securities. Revenue is generated by the difference in the client price for an instrument and the price at which the trading desk can execute the trade in the dealer market. For equity securities, commissions related to purchases and sales are recorded in the “Other” column in the Sales and Trading Revenue table. Changes in the fair value of these securities are included in market making and similar activities. For debt securities, revenue, with the exception of interest associated with the debt securities, is typically included in market making and similar activities. Unlike commissions for equity securities, the initial revenue related to broker-dealer
services for debt securities is typically included in the pricing of the instrument rather than being charged through separate fee arrangements. Therefore, this revenue is recorded in market making and similar activities as part of the initial mark to fair value. For derivatives, the majority of revenue is included in market making and similar activities. In
transactions where the Corporation acts as agent, which include exchange-traded futures and options, fees are recorded in other income.
The following table 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 2019, 20182021, 2020 and 2017.2019. This table includes debit valuation adjustment (DVA) and funding valuation adjustment (FVA) gains (losses). Global Markets results in Note 2423 – 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)2021
Interest rate risk$523 $1,794 $217 $2,534 
Foreign exchange risk1,505 (80)14 1,439 
Equity risk4,581 (5)1,834 6,410 
Credit risk1,390 1,684 556 3,630 
Other risk (2)
759 (128)124 755 
Total sales and trading revenue$8,758 $3,265 $2,745 $14,768 
2020
Interest rate risk$2,236 $2,279 $229 $4,744 
Foreign exchange risk1,486 (19)1,469 
Equity risk3,656 (77)1,801 5,380 
Credit risk783 1,758 331 2,872 
Other risk (2)
308 44 356 
Total sales and trading revenue$8,469 $3,945 $2,407 $14,821 
2019
Interest rate risk$1,046 $1,697 $113 $2,856 
Foreign exchange risk1,293 61 56 1,410 
Equity risk3,563 (634)1,569 4,498 
Credit risk1,040 1,928 519 3,487 
Other risk (2)
120 70 54 244 
Total sales and trading revenue$7,062 $3,122 $2,311 $12,495 
        
Sales and Trading Revenue
        
 Market making and similar activities 
Net Interest
Income
 
Other (1)
 Total
(Dollars in millions)2019
Interest rate risk$916
 $1,831
 $121
 $2,868
Foreign exchange risk1,300
 54
 43
 1,397
Equity risk3,565
 (638) 1,574
 4,501
Credit risk1,158
 1,800
 511
 3,469
Other risk123
 75
 57
 255
Total sales and trading revenue$7,062
 $3,122
 $2,306
 $12,490
        
 2018
Interest rate risk$784
 $1,696
 $259
 $2,739
Foreign exchange risk1,486
 11
 14
 1,511
Equity risk3,874
 (662) 1,644
 4,856
Credit risk1,063
 1,861
 588
 3,512
Other risk50
 202
 53
 305
Total sales and trading revenue$7,257
 $3,108

$2,558
 $12,923
        
 2017
Interest rate risk$429
 $1,846
 $248
 $2,523
Foreign exchange risk1,409
 12
 9
 1,430
Equity risk2,598
 (427) 1,904
 4,075
Credit risk1,685
 1,945
 578
 4,208
Other risk79
 170
 75
 324
Total sales and trading revenue$6,200
 $3,546
 $2,814
 $12,560
(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, $1.9 billion and $1.7 billion in 2021, 2020 and 2019, respectively.
(1)
(2)Includes commodity risk.
Represents amounts in investment and brokerage services and other income that are recorded in Global Markets and included in the definition of sales and trading revenue. Includes investment and brokerage services revenue of $1.7 billion, $1.7 billion and $2.0 billion in 2019, 2018 and 2017, respectively.
Credit Derivatives
The Corporation enters into credit derivatives primarily to facilitate client transactions and to manage credit risk exposures. Credit derivatives derive value based on an underlying third-party referenced obligation or a portfolio of referenced obligations and generally require the Corporation, as the seller of credit protection, to make payments to a buyer upon the occurrence of a predefined credit event. Such credit events generally include bankruptcy of the referenced credit entity and failure to pay under the obligation, as well as acceleration of indebtedness and payment repudiation or moratorium. For credit derivatives based on a portfolio of referenced credits or credit indices, the Corporation may not be required to make payment until a specified amount of loss has
Bank of America 108


occurred and/or may only be required to make payment up to a specified amount.
Credit derivatives are classified as investment and non-investment grade based on the credit quality of the underlying referenced obligation. The Corporation considers ratings of BBB- or higher as investment grade. Non-investment grade includes non-

Bank of America 106


ratednon-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, 20192021 and 20182020 are summarized in the following table.table below.
          
Credit Derivative Instruments         
          
 
Less than
One Year
 
One to
Three Years
 
Three to
Five Years
 
Over Five
Years
 Total
 December 31, 2019
(Dollars in millions)Carrying Value
Credit default swaps: 
  
  
  
  
Investment grade$
 $5
 $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$
 $3
 $1
 $639
 $643
Non-investment grade6
 2
 1
 1,125
 1,134
Total credit-related notes$6
 $5
 $2
 $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
          
 December 31, 2018
 Carrying Value
Credit default swaps:         
Investment grade$2
 $44
 $436
 $488
 $970
Non-investment grade132
 636
 914
 1,691
 3,373
Total134
 680
 1,350
 2,179
 4,343
Total return swaps/options: 
  
  
  
  
Investment grade105
 
 
 
 105
Non-investment grade472
 21
 
 
 493
Total577
 21
 
 
 598
Total credit derivatives$711
 $701
 $1,350
 $2,179
 $4,941
Credit-related notes: 
  
  
  
  
Investment grade$
 $
 $4
 $532
 $536
Non-investment grade1
 1
 1
 1,500
 1,503
Total credit-related notes$1
 $1
 $5
 $2,032
 $2,039
 Maximum Payout/Notional
Credit default swaps:         
Investment grade$53,758
 $95,699
 $95,274
 $20,054
 $264,785
Non-investment grade24,297
 33,881
 34,530
 14,426
 107,134
Total78,055
 129,580
 129,804
 34,480
 371,919
Total return swaps/options: 
  
  
  
  
Investment grade60,042
 822
 59
 72
 60,995
Non-investment grade24,524
 1,649
 39
 70
 26,282
Total84,566
 2,471
 98
 142
 87,277
Total credit derivatives$162,621
 $132,051
 $129,902
 $34,622
 $459,196

Credit Derivative Instruments
Less than
One Year
One to
Three Years
Three to
Five Years
Over Five
Years
Total
December 31, 2021
(Dollars in millions)Carrying Value
Credit default swaps:     
Investment grade$ $5 $79 $49 $133 
Non-investment grade34 250 453 769 1,506 
Total34 255 532 818 1,639 
Total return swaps/options:     
Investment grade35 388   423 
Non-investment grade105  16  121 
Total140 388 16  544 
Total credit derivatives$174 $643 $548 $818 $2,183 
Credit-related notes:     
Investment grade$ $ $36 $412 $448 
Non-investment grade5  9 1,334 1,348 
Total credit-related notes$5 $ $45 $1,746 $1,796 
 Maximum Payout/Notional
Credit default swaps:     
Investment grade$34,503 $66,334 $73,444 $17,844 $192,125 
Non-investment grade16,119 29,233 34,356 7,961 87,669 
Total50,622 95,567 107,800 25,805 279,794 
Total return swaps/options:     
Investment grade49,626 11,494 78  61,198 
Non-investment grade22,621 717 642 73 24,053 
Total72,247 12,211 720 73 85,251 
Total credit derivatives$122,869 $107,778 $108,520 $25,878 $365,045 
December 31, 2020
Carrying Value
Credit default swaps:
Investment grade$— $$35 $94 $130 
Non-investment grade26 233 364 1,163 1,786 
Total26 234 399 1,257 1,916 
Total return swaps/options:     
Investment grade21 — — 25 
Non-investment grade345 — — — 345 
Total366 — — 370 
Total credit derivatives$392 $238 $399 $1,257 $2,286 
Credit-related notes:     
Investment grade$— $— $— $572 $572 
Non-investment grade64 10 947 1,023 
Total credit-related notes$64 $$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 — 32,099 
Non-investment grade36,128 364 27 36,524 
Total67,089 1,425 104 68,623 
Total credit derivatives$114,227 $105,926 $123,300 $26,679 $370,132 
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)
109 Bank of America


and credit-linked note vehicles. These instruments are primarily classified as trading securities. The carrying value of these
instruments equals the Corporation’s maximum exposure to loss. The Corporation is not obligated to make any payments to the entities under the terms of the securities owned.
Credit-related Contingent Features and Collateral
The Corporation executes the majority of its derivative contracts in the OTC market with large, international financial institutions, including broker-dealers and, to a lesser degree, with a variety of non-financial companies. A significant majority of the derivative transactions are executed on a daily margin basis. Therefore, events such as a credit rating downgrade (depending on the ultimate rating level) or a breach of credit covenants would typically require an increase in the amount of collateral required of the counterparty, where applicable, and/or allow the Corporation to

107Bank of America






take additional protective measures such as early termination of all trades. Further, as previously discussed on page 103,105, 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.
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, 20192021 and 2018,2020, the Corporation held cash and securities collateral of $84.3$91.4 billion and $81.6$96.5 billion and posted cash and securities collateral of $69.1$79.3 billion and $56.5$88.6 billion in the normal course of business under derivative agreements, excluding cross-product margining agreements where clients are permitted to margin on a net basis for both derivative and secured financing arrangements.
In connection with certain OTC derivative contracts and other trading agreements, the Corporation can be required to provide additional collateral or to terminate transactions with certain counterparties in the event of a downgrade of the senior debt ratings of the Corporation or certain subsidiaries. The amount of
additional collateral required depends on the contract and is usually a fixed incremental amount and/or the market value of the exposure.
At December 31, 2019,2021, the amount of collateral, calculated based on the terms of the contracts, that the Corporation and certain subsidiaries could be required to post to counterparties but had not yet posted to counterparties was $2.3 billion, including $913 million$1.4 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, 20192021 and 2018,2020, 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, 20192021 if the rating agencies had downgraded their long-term senior debt ratings for the Corporation or certain subsidiaries by one incremental notch and by an additional second incremental notch.
    
Additional Collateral Required to be Posted Upon Downgrade at December 31, 2019
    
(Dollars in millions)
One
incremental notch
 
Second
incremental notch
Bank of America Corporation$480
 $491
Bank of America, N.A. and subsidiaries (1)
222
 353
(1)
Included in Bank of America Corporation collateral requirements in this table.
The following table also presents the derivative liabilities that would be subject to unilateral termination by counterparties andupon downgrade of the amounts of collateral that would have been contractually required at December 31, 2019 if theCorporation's or certain subsidiaries' long-term senior debt ratings for theratings.
Additional Collateral Required to be Posted and Derivative Liabilities Subject to Unilateral Termination Upon Downgrade
at December 31, 2021
(Dollars in millions)One
incremental
 notch
Second
incremental
 notch
Additional collateral required to be posted upon downgrade
Bank of America Corporation$316 $823 
Bank of America, N.A. and subsidiaries (1)
75 646 
Derivative liabilities subject to unilateral termination upon downgrade
Derivative liabilities$32 $994 
Collateral posted25 634 
(1)Included in Bank of America Corporation or certain subsidiaries had been lower by one incremental notch and by an additional second incremental notch.
    
Derivative Liabilities Subject to Unilateral Termination Upon Downgrade at December 31, 2019
    
(Dollars in millions)
One
incremental notch
 
Second
incremental notch
Derivative liabilities$57
 $783
Collateral posted42
 411

collateral requirements in this table.
Valuation Adjustments on Derivatives
The Corporation records credit risk valuation adjustments on derivatives in order to properly reflect the credit quality of the counterparties and its own credit quality. The Corporation calculates valuation adjustments on derivatives based on a modeled expected exposure that incorporates current market risk factors. The exposure also takes into consideration credit mitigants such as enforceable master netting agreements and collateral. CDS spread data is used to estimate the default probabilities and severities that are applied to the exposures. Where no observable credit default data is available for counterparties, the Corporation uses proxies and other market data to estimate default probabilities and severity.
Valuation adjustments on derivatives are affected by changes in market spreads, non-credit related market factors such as interest rates and foreign exchange rates that affect the expected exposure, and other 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 counterpartyThe table below presents 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 foreign exchange and interest rate swaps. In certain instances, the net-of-hedge amounts in the table below move in the same direction as the gross amount or may move in the opposite direction. This movement is a consequence of the complex interaction of the risks being hedged, resulting in limitations in the ability to perfectly hedge all of the market exposures at all times.
The table below presents CVA,, DVA and FVA gains (losses) on derivatives (excluding the effect of any related hedge activities), which are recorded in market making and similar activities, on a grossfor 2021, 2020 and net of hedge basis for 2019, 2018 and 2017.2019. 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)202120202019
Derivative assets (CVA)$208 $(118)$72 
Derivative assets/liabilities (FVA)(2)(24)(2)
Derivative liabilities (DVA)3 24 (147)
(1)At December 31, 2021, 2020 and 2019, cumulative CVA reduced the derivative assets balance by $438 million, $646 million, and $528 million cumulative FVA reduced the net derivatives balance by $179 million, $177 million and $153 million, and cumulative DVA reduced the derivative liabilities balance by $312 million, $309 million and $285 million, respectively.
         
Valuation Adjustments Gains (Losses) on Derivatives (1)
         
 GrossNet GrossNet GrossNet
 2019 2018 2017
Derivative assets (CVA)$72
$45
 $77
$187
 $330
$98
Derivative assets/liabilities (FVA)(2)46
 (15)14
 160
178
Derivative liabilities (DVA)(147)(135) (19)(55) (324)(281)
(1)
At December 31, 2019, 2018 and 2017, cumulative CVA reduced the derivative assets balance by $528 million, $600 million and $677 million, cumulative FVA reduced the net derivatives balance by $153 million, $151 million and $136 million, and cumulative DVA reduced the derivative liabilities balance by $285 million, $432 million and $450 million, respectively.

Bank of America 108110



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, 20192021 and 2018.2020.
Debt Securities
Amortized
Cost
Gross
Unrealized
Gains
Gross
Unrealized
Losses
Fair
Value
Amortized
Cost
Gross
Unrealized
Gains
Gross
Unrealized
Losses
Fair
Value
(Dollars in millions)December 31, 2021December 31, 2020
Available-for-sale debt securities
Mortgage-backed securities:
Agency$45,268 $1,257 $(186)$46,339 $59,518 $2,370 $(39)$61,849 
Agency-collateralized mortgage obligations3,331 74 (25)3,380 5,112 161 (13)5,260 
Commercial19,036 647 (79)19,604 15,470 1,025 (4)16,491 
Non-agency residential (1)
591 25 (33)583 899 127 (17)1,009 
Total mortgage-backed securities68,226 2,003 (323)69,906 80,999 3,683 (73)84,609 
U.S. Treasury and government agencies197,853 1,610 (318)199,145 114,157 2,236 (13)116,380 
Non-U.S. securities11,933   11,933 14,009 15 (7)14,017 
Other taxable securities2,725 39 (3)2,761 2,656 61 (6)2,711 
Tax-exempt securities15,155 317 (39)15,433 16,417 389 (32)16,774 
Total available-for-sale debt securities295,892 3,969 (683)299,178 228,238 6,384 (131)234,491 
Other debt securities carried at fair value (2)
8,873 105 (83)8,895 11,720 429 (39)12,110 
Total debt securities carried at fair value304,765 4,074 (766)308,073 239,958 6,813 (170)246,601 
Held-to-maturity debt securities
Agency mortgage-backed securities553,721 3,855 (10,366)547,210 414,289 9,768 (36)424,021 
U.S. Treasury and government agencies111,859 254 (2,395)109,718 16,084 — (71)16,013 
Other taxable securities9,011 147 (196)8,962 7,906 327 (87)8,146 
Total held-to-maturity debt securities674,591 4,256 (12,957)665,890 438,279 10,095 (194)448,180 
Total debt securities (3,4)
$979,356 $8,330 $(13,723)$973,963 $678,237 $16,908 $(364)$694,781 
        
Debt Securities    
  
 
Amortized
Cost
 
Gross
Unrealized
Gains
 
Gross
Unrealized
Losses
 
Fair
Value
(Dollars in millions)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
 6
 (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
        
 December 31, 2018
Available-for-sale debt securities       
Mortgage-backed securities: 
  
  
  
Agency$125,116
 $138
 $(3,428) $121,826
Agency-collateralized mortgage obligations5,621
 19
 (110) 5,530
Commercial14,469
 11
 (402) 14,078
Non-agency residential (1)
1,792
 136
 (11) 1,917
Total mortgage-backed securities146,998
 304
 (3,951) 143,351
U.S. Treasury and agency securities56,239
 62
 (1,378) 54,923
Non-U.S. securities9,307
 5
 (6) 9,306
Other taxable securities, substantially all asset-backed securities4,387
 29
 (6) 4,410
Total taxable securities216,931
 400
 (5,341) 211,990
Tax-exempt securities17,349
 99
 (72) 17,376
Total available-for-sale debt securities234,280
 499
 (5,413) 229,366
Other debt securities carried at fair value (2)
8,595
 172
 (32) 8,735
Total debt securities carried at fair value242,875
 671
 (5,445) 238,101
Held-to-maturity debt securities, substantially all U.S. agency mortgage-backed securities203,652
 747
 (3,964) 200,435
Total debt securities (3, 4)
$446,527
 $1,418
 $(9,409) $438,536
(1)At December 31, 2021 and 2020, the underlying collateral type included approximately 21 percent and 37 percent prime, 0 percent and 2 percent Alt-A and 79 percent and 61 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 $111.9 billion and $65.5 billion at December 31, 2021 and 2020.
(4)The Corporation held debt securities from FNMA and FHLMC that each exceeded 10 percent of shareholders’ equity, with an amortized cost of $345.3 billion and $205.3 billion, and a fair value of $342.5 billion and $202.4 billion at December 31, 2021, and 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.
At December 31, 2019 and 2018, the underlying collateral type included approximately 49 percent and 68 percent prime, 6 percent and 4 percent Alt-A and 45 percent and 28 percent subprime.
(2)
Primarily includes non-U.S. securities used to satisfy certain international regulatory requirements. Any changes in value are reported in other income. For detail on the components, see Note 21 – Fair Value Measurements.
(3)
Includes securities pledged as collateral of $67.0 billion and $40.6 billion at December 31, 2019 and 2018.
(4)
The Corporation held debt securities from FNMA and FHLMC that each exceeded 10 percent of shareholders’ equity, with an amortized cost of $157.2 billion and $54.1 billion, and a fair value of $160.6 billion and $55.1 billion at December 31, 2019, and an amortized cost of $161.2 billion and $52.2 billion, and a fair value of $158.5 billion and $51.4 billion at December 31, 2018.
At December 31, 2019,2021, the accumulated net unrealized gain on AFS debt securities, excluding the amount related to debt securities previously transferred to held to maturity, included in accumulated OCI was $1.8$2.5 billion, net of the related income tax expense of $569$817 million. The Corporation hadAt December 31, 2021 and 2020, nonperforming AFS debt securities of $9 million and $11 million at December 31, 2019 and 2018.held by the Corporation were insignificant.
At December 31, 2019,2021 and 2020, the Corporation had $268.5 billion and $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 $30.7 billion and $34.5 billion in AFS debt securities at December 31, 2021 and 2020, the amount of ECL was insignificant. Substantially all of the Corporation's HTM debt securities consist of U.S. agency and U.S. Treasury securities and have a zero credit loss assumption.
At December 31, 2021 and 2020, the Corporation held equity securities at an aggregate fair value of $891$513 million and $769 million and other equity securities, as valued under the
measurement alternative, at costa carrying value of $183$266 million and $240 million, both of which are included in other assets. At December 31, 2019,2021 and 2020, the Corporation also held equity securitiesmoney market investments at a fair value of $1.0$707 million and $1.6 billion, which are included in time deposits placed and other short-term investments.
The gross realized gains and losses on sales of AFS debt securities for 2019, 20182021, 2020 and 20172019 are presented in the table below.
      
Gains and Losses on Sales of AFS Debt Securities
    
(Dollars in millions)2019 2018 2017
Gross gains$336
 $169
 $352
Gross losses(119) (15) (97)
Net gains on sales of AFS debt securities$217
 $154
 $255
Income tax expense attributable to realized net gains on sales of AFS debt securities$54
 $37
 $97

Gains and Losses on Sales of AFS Debt Securities
(Dollars in millions)202120202019
Gross gains$49 $423 $336 
Gross losses(27)(12)(119)
Net gains on sales of AFS debt securities$22 $411 $217 
Income tax expense attributable to realized net gains on sales of AFS debt securities$5 $103 $54 

109111 Bank of America






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, 20192021 and 2018.2020.
            
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, 2019
Temporarily impaired 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 residential19
 (1) 1
 
 20
 (1)
Total mortgage-backed securities20,095
 (65) 18,606
 (168) 38,701
 (233)
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 securities34,720
 (136) 38,531
 (294) 73,251
 (430)
Tax-exempt securities4,286
 (5) 190
 (1) 4,476
 (6)
Total temporarily impaired AFS debt securities39,006
 (141) 38,721
 (295) 77,727
 (436)
Other-than-temporarily impaired AFS debt securities (1)
           
Non-agency residential mortgage-backed securities

103
 (5) 21
 (3) 124
 (8)
Total temporarily impaired and other-than-temporarily impaired
AFS debt securities
$39,109
 $(146) $38,742
 $(298) $77,851
 $(444)
            
 December 31, 2018
Temporarily impaired AFS debt securities           
Mortgage-backed securities:           
Agency$14,771
 $(49) $99,211
 $(3,379) $113,982
 $(3,428)
Agency-collateralized mortgage obligations3
 
 4,452
 (110) 4,455
 (110)
Commercial1,344
 (8) 11,991
 (394) 13,335
 (402)
Non-agency residential106
 (8) 49
 (3) 155
 (11)
Total mortgage-backed securities16,224
 (65) 115,703
 (3,886) 131,927
 (3,951)
U.S. Treasury and agency securities288
 (1) 51,374
 (1,377) 51,662
 (1,378)
Non-U.S. securities773
 (5) 21
 (1) 794
 (6)
Other taxable securities, substantially all asset-backed securities183
 (1) 185
 (5) 368
 (6)
Total taxable securities17,468
 (72) 167,283
 (5,269) 184,751
 (5,341)
Tax-exempt securities232
 (2) 2,148
 (70) 2,380
 (72)
Total temporarily impaired AFS debt securities17,700
 (74) 169,431
 (5,339) 187,131
 (5,413)
Other-than-temporarily impaired AFS debt securities (1)
           
Non-agency residential mortgage-backed securities131
 
 3
 
 134
 
Total temporarily impaired and other-than-temporarily impaired
AFS debt securities
$17,831
 $(74) $169,434
 $(5,339) $187,265
 $(5,413)
(1)
Includes other-than-temporarily impaired AFS debt securities on which an OTTI loss, primarily related to changes in interest rates, remains in accumulated OCI.
In 2019, 2018 and 2017, the Corporation had $24 million, $33 million and $41 million, respectively, of credit-related OTTI losses on AFS debt securities which were recognized in other income. The amount of non-credit related OTTI losses for these AFS debt securities, which is recognized in OCI, was not significant for all periods presented.
The cumulative OTTI credit losses recognized in income on AFS debt securities that the Corporation does not intend to sell were $85 million, $120 million and $274 million at December 31, 2019, 2018 and 2017, respectively.
The Corporation estimates the portion of a loss on a security that is attributable to credit using a discounted cash flow model and estimates the expected cash flows of the underlying collateral using internal credit, interest rate and prepayment risk models that incorporate management’s best estimate of current key
assumptions such as default rates, loss severity and prepayment rates. Assumptions used for the underlying loans that support the MBS can vary widely from loan to loan and are influenced by such factors as loan interest rate, geographic location of the borrower, borrower characteristics and collateral type. Based on these assumptions, the Corporation then determines how the underlying collateral cash flows will be distributed to each MBS issued from the applicable special purpose entity. Expected principal and interest cash flows on an impaired AFS debt security are discounted using the effective yield of each individual impaired AFS debt security.
Significant assumptions used in estimating the expected cash flows for measuring credit losses on non-agency residential mortgage-backed securities (RMBS) were as follows at December 31, 2019.

Total AFS Debt Securities in a Continuous Unrealized Loss Position
Less than Twelve MonthsTwelve Months or LongerTotal
Fair
Value
Gross
 Unrealized
 Losses
Fair
Value
Gross
 Unrealized
 Losses
Fair
Value
Gross
 Unrealized
 Losses
(Dollars in millions)December 31, 2021
Continuously unrealized loss-positioned AFS debt securities
Mortgage-backed securities:   
Agency$11,733 $(166)$815 $(20)$12,548 $(186)
Agency-collateralized mortgage obligations1,427 (22)122 (3)1,549 (25)
Commercial3,451 (41)776 (38)4,227 (79)
Non-agency residential241 (13)174 (20)415 (33)
Total mortgage-backed securities16,852 (242)1,887 (81)18,739 (323)
U.S. Treasury and government agencies103,307 (272)4,850 (46)108,157 (318)
Other taxable securities  82 (3)82 (3)
Tax-exempt securities502 (16)109 (23)611 (39)
Total AFS debt securities in a continuous
   unrealized loss position
$120,661 $(530)$6,928 $(153)$127,589 $(683)
December 31, 2020
Continuously unrealized loss-positioned AFS debt securities
Mortgage-backed securities:
Agency$2,841 $(39)$$— $2,843 $(39)
Agency-collateralized mortgage obligations187 (2)364 (11)551 (13)
Commercial566 (4)— 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 government agencies8,282 (9)498 (4)8,780 (13)
Non-U.S. securities1,861 (6)135 (1)1,996 (7)
Other taxable securities576 (2)396 (4)972 (6)
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)
Bank of America 110112


      
Significant Assumptions
    
   
Range (1)
 Weighted
average
 
10th
Percentile (2)
 
90th
Percentile (2)
Prepayment speed16.6% 5.5% 27.8%
Loss severity14.7
 8.0
 30.7
Life default rate11.9
 1.0
 36.5
(1)
Represents the range of inputs/assumptions based upon the underlying collateral.
(2)
The value of a variable below which the indicated percentile of observations will fall.
Annual constant prepayment speed and loss severity rates are projected considering collateral characteristics such as LTV, creditworthiness of borrowers as measured using Fair Isaac Corporation (FICO) scores, and geographic concentrations. The weighted-average severity by collateral type was 12.9 percent for prime, 11.1 percent for Alt-A and 18.8 percent for subprime at December 31, 2019. Default rates are projected by considering collateral characteristics including, but not limited to, LTV, FICO and geographic concentration. Weighted-average life default rates
by collateral type were 7.8 percent for prime, 11.6 percent for Alt-A and 13.6 percent for subprime at December 31, 2019.
The remaining contractual maturity distribution and yields of the Corporation’s debt securities carried at fair value and HTM debt securities at December 31, 20192021 are summarized in the table below. Actual duration and yields may differ as prepayments on the loans underlying the mortgagesMBS 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$— — %$5.00 %$49 4.63 %$45,214 3.11 %$45,268 3.11 %
Agency-collateralized mortgage obligations— — — — 20 2.50 3,311 2.91 3,331 2.91 
Commercial363 2.30 10,123 2.48 6,285 1.79 2,278 1.87 19,049 2.18 
Non-agency residential— — — — — — 1,112 6.43 1,112 6.43 
Total mortgage-backed securities363 2.30 10,128 2.48 6,354 1.81 51,915 3.11 68,760 2.89 
U.S. Treasury and government agencies6,564 1.22 39,875 1.80 151,962 1.20 27 2.61 198,428 1.32 
Non-U.S. securities18,645 0.20 1,045 3.61 — — 9.15 19,697 0.38 
Other taxable securities562 1.49 1,646 1.97 308 2.04 209 1.76 2,725 1.86 
Tax-exempt securities2,485 1.06 6,520 1.42 3,105 1.81 3,045 1.46 15,155 1.45 
Total amortized cost of debt securities carried at fair value$28,619 0.56 $59,214 1.89 $161,729 1.23 $55,203 3.02 $304,765 1.62 
Amortized cost of HTM debt securities
Agency mortgage-backed securities$— — %$— — %$2.00 %$553,717 2.13 %$553,721 2.13 %
U.S. Treasury and government agencies— — — — 111,859 1.35 — — 111,859 1.35 
Other taxable securities37 5.31 1,035 2.21 473 2.66 7,466 2.51 9,011 2.50 
Total amortized cost of HTM debt securities$37 5.31 $1,035 2.21 $112,336 1.35 $561,183 2.13 $674,591 2.00 
Debt securities carried at fair value          
Mortgage-backed securities:          
Agency$—  $ $53  $46,281  $46,339  
Agency-collateralized mortgage obligations—  —  20  3,360  3,380  
Commercial366  10,562  6,379  2,310  19,617  
Non-agency residential—   —  1,164  1,168  
Total mortgage-backed securities366 10,571 6,452 53,115 70,504 
U.S. Treasury and government agencies6,614 40,912 152,168 26 199,720 
Non-U.S. securities18,599  1,046  —   19,652  
Other taxable securities566  1,676  310  212  2,764  
Tax-exempt securities2,489  6,660  3,223  3,061  15,433  
Total debt securities carried at fair value$28,634  $60,865  $162,153  $56,421  $308,073  
Fair value of HTM debt securities
Agency mortgage-backed securities$— $— $$547,206 $547,210 
U.S. Treasury and government agencies— — 109,718 — 109,718 
Other taxable securities371,060 4837,382 8,962 
Total fair value of HTM debt securities$37 $1,060 $110,205 $554,588 $665,890 
(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.
                    
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$
 % $11
 5.25% $66
 4.56% $124,618
 3.24% $124,695
 3.24%
Agency-collateralized mortgage obligations
 
 
 
 27
 2.48
 4,560
 3.16
 4,587
 3.16
Commercial
 
 3,806
 2.37
 10,136
 2.57
 868
 2.99
 14,810
 2.54
Non-agency residential
 
 
 
 12
 
 2,157
 9.26
 2,169
 9.22
Total mortgage-backed securities
 
 3,817
 2.38
 10,241
 2.58
 132,203
 3.33
 146,261
 3.25
U.S. Treasury and agency securities1,350
 0.92
 35,544
 1.67
 30,789
 2.25
 20
 2.45
 67,703
 1.92
Non-U.S. securities15,648
 1.17
 2,598
 1.03
 7
 4.17
 96
 6.74
 18,349
 1.18
Other taxable securities, substantially all asset-backed securities1,189
 2.80
 1,650
 3.02
 440
 3.32
 595
 2.91
 3,874
 2.97
Total taxable securities18,187
 1.26
 43,609
 1.74
 41,477
 2.34
 132,914
 3.34
 236,187
 2.70
Tax-exempt securities2,189
 1.72
 7,472
 2.10
 4,849
 2.06
 3,206
 2.44
 17,716
 2.10
Total amortized cost of debt securities carried at fair value$20,376
 1.31
 $51,081
 1.79
 $46,326
 2.31
 $136,120
 3.32
 $253,903
 2.67
Amortized cost of HTM debt securities (2)
$1,025
 2.83
 $48
 3.57
 $1,102
 2.57
 $213,555
 3.19
 $215,730
 3.19
                    
Debt securities carried at fair value 
  
  
  
  
  
  
  
  
  
Mortgage-backed securities: 
  
  
  
  
  
  
  
  
  
Agency$
  
 $11
  
 $71
  
 $125,449
  
 $125,531
  
Agency-collateralized mortgage obligations
  
 
  
 26
  
 4,615
  
 4,641
  
Commercial
  
 3,854
  
 10,287
  
 893
  
 15,034
  
Non-agency residential
  
 
  
 25
  
 2,386
  
 2,411
  
Total mortgage-backed securities
   3,865
   10,409
   133,343
   147,617
  
U.S. Treasury and agency securities1,347
   35,686
   31,478
   20
   68,531
  
Non-U.S. securities15,751
  
 2,606
  
 8
  
 98
  
 18,463
  
Other taxable securities, substantially all asset-backed securities1,196
  
 1,687
  
 465
  
 596
  
 3,944
  
Total taxable securities18,294
  
 43,844
  
 42,360
  
 134,057
  
 238,555
  
Tax-exempt securities2,192
  
 7,509
  
 4,976
  
 3,235
  
 17,912
  
Total debt securities carried at fair value$20,486
  
 $51,353
  
 $47,336
  
 $137,292
  
 $256,467
  
Fair value of HTM debt securities (2)
$1,025
   $48
   $1,113
   $217,635
   $219,821
  
(1)
The weighted-average yield is computed based on a constant effective interest rate over the contractual life of each security. The average yield considers the contractual coupon and the amortization of premiums and accretion of discounts, excluding the effect of related hedging derivatives.
(2)
Substantially all U.S. agency MBS.

111113 Bank of America







NOTE 5 Outstanding Loans and Leases and Allowance for Credit Losses
The following tables present total outstanding loans and leases and an aging analysis for the Consumer Real Estate, Credit Card and Other Consumer, and Commercial portfolio segments, by class of financing receivables, at December 31, 20192021 and 2018.2020.
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, 2021
Consumer real estate      
Residential mortgage$1,005 $297 $1,571 $2,873 $219,090 $221,963 
Home equity123 69 369 561 27,374 27,935 
Credit card and other consumer
Credit card298 212 487 997 80,441 81,438 
Direct/Indirect consumer (2)
147 52 18 217 103,343 103,560 
Other consumer    190 190 
Total consumer1,573 630 2,445 4,648 430,438 435,086 
Consumer loans accounted for under the fair value option (3)
     $618 618 
Total consumer loans and leases1,573 630 2,445 4,648 430,438 618 435,704 
Commercial
U.S. commercial815 308 396 1,519 324,417 325,936 
Non-U.S. commercial148 20 83 251 113,015 113,266 
Commercial real estate (4)
115 34 285 434 62,575 63,009 
Commercial lease financing104 28 13 145 14,680 14,825 
U.S. small business commercial (5)
129 259 89 477 18,706 19,183 
Total commercial1,311 649 866 2,826 533,393 536,219 
Commercial loans accounted for under the fair value option (3)
     7,201 7,201 
Total commercial loans and leases1,311 649 866 2,826 533,393 7,201 543,420 
Total loans and leases (6)
$2,884 $1,279 $3,311 $7,474 $963,831 $7,819 $979,124 
Percentage of outstandings0.29 %0.13 %0.34 %0.76 %98.44 %0.80 %100.00 %
              
 
30-59 Days Past Due (1)
 
60-89 Days Past Due (1)
 
90 Days or
More
Past Due (2)
 
Total Past
Due 30 Days
or More
 
Total Current or Less Than 30 Days Past Due (3)
 Loans Accounted for Under the Fair Value Option 
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 (4)
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 (5)
 
  
  
  
  
 $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
 8
 66
 104,900
   104,966
Commercial real estate (6)
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 (5)
 
  
  
  
  
 7,741
 7,741
Total commercial loans and leases1,186
 433
 644
 2,263
 507,653
 7,741
 517,657
Total loans and leases (7)
$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.
(2)
Consumer real estate includes fully-insured loans of $1.1 billion.
(3)
Consumer real estate includes $856 million and direct/indirect consumer includes $45 million of nonperforming loans.
(4)
Total outstandings primarily includes auto and specialty lending loans and leases of $50.4 billion, U.S. securities-based lending loans of $36.7 billion and non-U.S. consumer loans of $2.8 billion.
(5)
Consumer loans accounted for under the fair value option includes residential mortgage loans of $257 million and home equity loans of $337 million. Commercial loans accounted for under the fair value option includes U.S. commercial loans of $4.7 billion and non-U.S. commercial loans of $3.1 billion. For more information, see Note 21 – Fair Value Measurements and Note 22 – Fair Value Option.
(6)
Total outstandings includes U.S. commercial real estate loans of $59.0 billion and non-U.S. commercial real estate loans of $3.7 billion.
(7)
Total outstandings includes loans and leases pledged as collateral of $25.9 billion. The Corporation also pledged $168.2 billionConsumer real estate loans 30-59 days past due includes fully-insured loans of $164 million and nonperforming loans of $118 million. Consumer real estate loans 60-89 days past due includes fully-insured loans of $89 million and nonperforming loans of $100 million. Consumer real estate loans 90 days or more past due includes fully-insured loans of $633 million. Consumer real estate loans current or less than 30 days past due includes $1.4 billion and direct/indirect consumer includes $55 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 $48.5 billion, U.S. securities-based lending loans of $51.1 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 $279 million and home equity loans of $339 million. Commercial loans accounted for under the fair value option includes U.S. commercial loans of $4.6 billion and non-U.S. commercial loans of $2.6 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 $58.2 billion and non-U.S. commercial real estate loans of $4.8 billion.
(5)Includes Paycheck Protection Program loans.
(6)Total outstandings includes loans and leases pledged as collateral of $13.0 billion. The Corporation also pledged $146.6 billion of loans with no related outstanding borrowings to secure potential borrowing capacity with the Federal Reserve Bank and Federal Home Loan Bank.

Bank of America 112114


              
 
30-59 Days
Past Due
(1)
 
60-89 Days Past Due (1)
 
90 Days or
More
Past Due
(2)
 Total Past
Due 30 Days
or More
 
Total
Current or
Less Than
30 Days
Past Due (3)
 
Loans
Accounted
for Under
the Fair
Value Option
 Total Outstandings
(Dollars in millions)December 31, 2018
Consumer real estate 
    
  
  
  
  
Core portfolio             
Residential mortgage$1,188
 $249
 $793
 $2,230
 $191,465
  
 $193,695
Home equity200
 85
 387
 672
 39,338
  
 40,010
Non-core portfolio   
  
  
  
  
  
Residential mortgage757
 309
 2,201
 3,267
 11,595
  
 14,862
Home equity139
 69
 339
 547
 7,729
  
 8,276
Credit card and other consumer   
  
  
  
  
  
Credit card577
 418
 994
 1,989
 96,349
  
 98,338
Direct/Indirect consumer (4)
317
 90
 40
 447
 90,719
  
 91,166
Other consumer (5)

 
 
 
 202
  
 202
Total consumer3,178
 1,220
 4,754
 9,152
 437,397
  
446,549
Consumer loans accounted for under the fair value option (6)
          $682

682
Total consumer loans and leases3,178
 1,220
 4,754
 9,152
 437,397
 682
 447,231
Commercial   
  
  
  
  
  
U.S. commercial594
 232
 573
 1,399
 297,878
  
 299,277
Non-U.S. commercial1
 49
 
 50
 98,726
  
 98,776
Commercial real estate (7)
29
 16
 14
 59
 60,786
  
 60,845
Commercial lease financing124
 114
 37
 275
 22,259
  
 22,534
U.S. small business commercial83
 54
 96
 233
 14,332
  
 14,565
Total commercial831
 465
 720
 2,016
 493,981
  
 495,997
Commercial loans accounted for under the fair value option (6)
          3,667
 3,667
Total commercial loans and leases831
 465
 720
 2,016
 493,981
 3,667
 499,664
Total loans and leases (8)
$4,009
 $1,685
 $5,474
 $11,168
 $931,378
 $4,349
 $946,895
Percentage of outstandings0.42% 0.18% 0.58% 1.18% 98.36% 0.46% 100.00%

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, 2020
Consumer real estate      
Residential mortgage$1,430 $297 $1,699 $3,426 $220,129 $223,555 
Home equity154 78 345 577 33,734 34,311 
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 consumer — — — — 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 $637 million and nonperforming loans of $217 million. Consumer real estate loans 60-89 days past due includes fully-insured loans of $269 million and nonperforming loans of $146 million.
(2)
Consumer real estate includes fully-insured loans of $1.9 billion.
(3)
Consumer real estate includes $1.8 billion and direct/indirect consumer includes $53 million of nonperforming loans.
(4)
Total outstandings primarily includes auto and specialty lending loans and leases of $50.1 billion, U.S. securities-based lending loans of $37.0 billion and non-U.S. consumer loans of $2.9 billion.
(5)
Substantially all of other consumer is consumer overdrafts.
(6)
Consumer loans accounted for under the fair value option includes residential mortgage loans of $336 million and home equity loans of $346 million. Commercial loans accounted for under the fair value option includes U.S. commercial loans of $2.5 billion and non-U.S. commercial loans of $1.1 billion. For more information, see Note 21 – Fair Value Measurements and Note 22 – Fair Value Option.
(7)
Total outstandings includes U.S. commercial real estate loans of $56.6 billion and non-U.S. commercial real estate loans of $4.2 billion.
(8)
Total outstandings includes loans and leases pledged as collateral of $36.7 billion. The Corporation also pledged $166.1 billion of loans with no related outstanding borrowings to secure potential borrowing capacity with the Federal Reserve Bank and Federal Home Loan Bank.
The Corporation categorizes consumer real estate loans as core30-59 days past due includes fully-insured loans of $225 million and non-core basednonperforming 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 loan and customer characteristics such as origination date, product type, LTV, FICO scorethe Corporation's interest accrual policies and delinquency status consistent with its current consumerfor loan modifications related to the pandemic, see Note 1 – Summary of Significant Accounting Principles.
(2)Total outstandings primarily includes auto 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-corespecialty lending loans and represent runoff portfolios.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 Paycheck Protection Program 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.
The Corporation has entered into long-term credit protection agreements with FNMA and FHLMC on loans totaling $7.5$10.5 billion and $6.1$9.0 billion at December 31, 20192021 and 2018,2020, providing full credit protection on residential mortgage loans that become
severely delinquent. All of these loans are individually insured, and therefore the Corporation does not record an allowance for credit losses related to these loans.
During 2019, the Corporation sold $4.7 billion of consumer real estate compared to $11.6 billion in 2018.
Nonperforming Loans and Leases
The Corporation classifiesCommercial nonperforming loans decreased to $1.6 billion at December 31, 2021 from $2.2 billion at December 31, 2020. Consumer nonperforming loans increased to $3.0 billion at
December 31, 2021 from $2.7 billion at December 31, 2020 driven by consumer real estate loans that have been discharged in Chapter 7 bankruptcy and not reaffirmed by the borrower as TDRs, irrespective of payment history or delinquency status, even if the repayment terms for the loans have not been otherwise modified. The Corporation continues to have a lien on the underlying collateral.


113Bank of America






deferral activity.
The following 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, 20192021 and 2018.2020. Nonperforming LHFS are excluded from nonperforming loans and leases as they are recorded at either fair value or the lower of cost or fair value. For more information on the criteria for classification as nonperforming, see Note 1 – Summary of Significant Accounting Principles.Principles.
        
Credit Quality  
        
 
Nonperforming Loans
and Leases
 
Accruing Past Due
90 Days or More
 December 31
(Dollars in millions)2019 2018 2019 2018
Consumer real estate 
  
  
  
Core portfolio       
Residential mortgage (1)
$883
 $1,010
 $176
 $274
Home equity363
 955
 
 
Non-core portfolio 
  
  
  
Residential mortgage (1)
587
 883
 912
 1,610
Home equity173
 938
 
 
Credit card and other consumer 
  
    
Credit cardn/a
 n/a
 1,042
 994
Direct/Indirect consumer47
 56
 33
 38
Total consumer2,053
 3,842
 2,163
 2,916
Commercial 
  
  
  
U.S. commercial1,094
 794
 106
 197
Non-U.S. commercial43
 80
 8
 
Commercial real estate280
 156
 19
 4
Commercial lease financing32
 18
 20
 29
U.S. small business commercial50
 54
 97
 84
Total commercial1,499
 1,102
 250
 314
Total loans and leases$3,552
 $4,944
 $2,413
 $3,230
(1)115 Bank of America
Residential mortgage loans in the core and non-core portfolios accruing past due 90 days or more are fully-insured loans. At December 31, 2019 and 2018, residential mortgage includes $740 million and $1.4 billion of loans on which interest has been curtailed by the FHA and therefore are no longer accruing interest, although principal is still insured, and $348 million and $498 million of loans on which interest is still accruing.


Credit Quality
Nonperforming Loans
and Leases
Accruing Past Due
90 Days or More (1)
December 31
(Dollars in millions)2021202020212020
Residential mortgage (2)
$2,284 $2,005 $634 $762 
With no related allowance (3)
1,950 1,378  — 
Home equity (2)
630 649  — 
With no related allowance (3)
414 347  — 
Credit Card                     n/a              n/a487 903 
Direct/indirect consumer75 71 11 33 
Total consumer2,989 2,725 1,132 1,698 
U.S. commercial825 1,243 171 228 
Non-U.S. commercial268 418 19 10 
Commercial real estate382 404 40 
Commercial lease financing80 87 8 25 
U.S. small business commercial23 75 87 115 
Total commercial1,578 2,227 325 384 
Total nonperforming loans$4,567 $4,952 $1,457 $2,082 
Percentage of outstanding loans and leases0.47 %0.54 %0.15 %0.23 %
(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, 2021 and 2020 residential mortgage includes $444 million and $537 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 $190 million and $225 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
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 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 Quality IndicatorsCards 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.
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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. When a nonaccrual loan is deemed uncollectible, it is charged off against the allowance for credit losses. If the charged-off amount is later recovered, the amount is reversed through the allowance for credit losses at the recovery date. Charge-offs are reported net of recoveries (net charge-offs). If recoveries for the period are greater than charge-offs, net charge-offs are reported as a negative amount.
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 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.
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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 Coronavirus Disease 2019 (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 expired on January 1, 2022. 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 zero. For all other assets, the Corporation performs qualitative analyses, including consideration of historical losses and current economic conditions, to estimate any ECL which are then included in a valuation account that is recorded as a contra-asset against the amortized cost basis of the financial asset.
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
99 Bank of America


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 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
Bank of America 100


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 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
101 Bank of America


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, 2021, 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 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. At December 31, 2021 and 2020, the Corporation had approximately 67,000 and 332,000 PPP loans with a carrying value of $4.7 billion and $22.7 billion. As compensation for originating the loans, the Corporation received lender processing fees from the SBA, which were capitalized, along with the loan origination costs, and are being 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 are recognized as interest income in that period.


Bank of America 102


NOTE 2 Net Interest Income and Noninterest Income
The Corporation monitors credit quality within its Consumer Real Estate, Credit Cardtable below presents the Corporation’s net interest income and Other Consumer,noninterest income disaggregated by revenue source for 2021, 2020 and Commercial portfolio segments based on primary credit quality indicators.2019. For more information, on the portfolio segments, see Note 1 – Summary of Significant Accounting PrinciplesPrinciples. For a disaggregation of noninterest income by business segment and All Other, see Note 23 – Business Segment Information. Within
(Dollars in millions)202120202019
Net interest income
Interest income
Loans and leases$29,282 $34,029 $43,086 
Debt securities12,376 9,790 11,806 
Federal funds sold and securities borrowed or purchased under agreements to resell (1)
(90)903 4,843 
Trading account assets3,770 4,128 5,196 
Other interest income2,334 2,735 6,305 
Total interest income47,672 51,585 71,236 
Interest expense
Deposits537 1,943 7,188 
Short-term borrowings (1)
(358)987 7,208 
Trading account liabilities1,128 974 1,249 
Long-term debt3,431 4,321 6,700 
Total interest expense4,738 8,225 22,345 
Net interest income$42,934 $43,360 $48,891 
Noninterest income
Fees and commissions
Card income
Interchange fees (2)
$4,560 $3,954 $3,834 
Other card income1,658 1,702 1,963 
Total card income6,218 5,656 5,797 
Service charges
Deposit-related fees6,271 5,991 6,588 
Lending-related fees1,233 1,150 1,086 
Total service charges7,504 7,141 7,674 
Investment and brokerage services
Asset management fees12,729 10,708 10,241 
Brokerage fees3,961 3,866 3,661 
Total investment and brokerage services16,690 14,574 13,902 
Investment banking fees
Underwriting income5,077 4,698 2,998 
Syndication fees1,499 861 1,184 
Financial advisory services2,311 1,621 1,460 
Total investment banking fees8,887 7,180 5,642 
Total fees and commissions39,299 34,551 33,015 
Market making and similar activities8,691 8,355 9,034 
Other income (loss)(1,811)(738)304 
Total noninterest income$46,179 $42,168 $42,353 
(1)For more information on negative interest, see Note 1 – Summary of Significant Accounting Principles.
(2)Gross interchange fees and merchant income were $11.5 billion, $9.2 billion and $10.0 billion for 2021, 2020 and 2019, respectively, and are presented net of $6.9 billion, $5.5 billion and $6.2 billion of expenses for rewards and partner payments as well as certain other card costs for the Consumer Real Estate portfolio segment,same periods.
103 Bank of America


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, 2021 and 2020. 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, 2021
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$18,068.1 $150.5 $8.9 $159.4 $156.4 $4.4 $160.8 
Futures and forwards2,243.2 1.1  1.1 1.0  1.0 
Written options1,616.1    28.8  28.8 
Purchased options1,673.6 33.1  33.1    
Foreign exchange contracts 
Swaps1,420.9 28.6 0.2 28.8 30.5 0.2 30.7 
Spot, futures and forwards4,087.2 37.1 0.3 37.4 37.7 0.2 37.9 
Written options287.2    4.1  4.1 
Purchased options267.6 4.1  4.1    
Equity contracts 
Swaps443.8 12.3  12.3 14.5  14.5 
Futures and forwards113.3 0.5  0.5 1.7  1.7 
Written options737.7    58.5  58.5 
Purchased options657.0 55.9  55.9    
Commodity contracts  
Swaps47.7 3.1  3.1 6.0  6.0 
Futures and forwards101.5 2.3  2.3 0.3 1.1 1.4 
Written options44.4    2.6  2.6 
Purchased options38.3 3.2  3.2    
Credit derivatives (2)
   
Purchased credit derivatives:   
Credit default swaps297.0 1.9  1.9 4.3  4.3 
Total return swaps/options85.3 0.2  0.2 1.1  1.1 
Written credit derivatives:  
Credit default swaps279.8 4.2  4.2 1.6  1.6 
Total return swaps/options85.3 0.9  0.9 0.5  0.5 
Gross derivative assets/liabilities$339.0 $9.4 $348.4 $349.6 $5.9 $355.5 
Less: Legally enforceable master netting agreements  (282.3)  (282.3)
Less: Cash collateral received/paid   (30.8)  (35.5)
Total derivative assets/liabilities   $35.3   $37.7 
(1)Represents the total contract/notional amount of derivative assets and liabilities outstanding.
(2)The net derivative asset and notional amount of written credit derivatives for which the Corporation held purchased credit derivatives with identical underlying referenced names were $2.3 billion and $258.4 billion at December 31, 2021.
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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 — 3.6 
Written options1,530.5 — — — 40.5 — 40.5 
Purchased options1,545.8 45.3 — 45.3 — — — 
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 — 53.4 54.5 0.5 55.0 
Written options289.6 — — — 4.8 — 4.8 
Purchased options279.3 5.0 — 5.0 — — — 
Equity contracts       
Swaps320.2 13.3 — 13.3 14.5 — 14.5 
Futures and forwards106.2 0.3 — 0.3 1.4 — 1.4 
Written options599.1 — — — 48.8 — 48.8 
Purchased options541.2 52.6 — 52.6 — — — 
Commodity contracts       
Swaps36.4 1.9 — 1.9 4.4 — 4.4 
Futures and forwards63.6 2.0 — 2.0 1.0 — 1.0 
Written options24.6 — — — 1.4 — 1.4 
Purchased options24.7 1.5 — 1.5 — — — 
Credit derivatives (2)
       
Purchased credit derivatives:       
Credit default swaps322.7 2.3 — 2.3 4.4 — 4.4 
Total return swaps/options63.6 0.2 — 0.2 1.0 — 1.0 
Written credit derivatives:      
Credit default swaps301.5 4.4 — 4.4 1.9 — 1.9 
Total return swaps/options68.6 0.6 — 0.6 0.4 — 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 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.
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, 2021 and 2020 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 – Securities Financing Agreements, Short-term Borrowings and Restricted Cash.
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Offsetting of Derivatives (1)
Derivative
Assets
Derivative
 Liabilities
Derivative
Assets
Derivative
 Liabilities
(Dollars in billions)December 31, 2021December 31, 2020
Interest rate contracts    
Over-the-counter$171.3 $166.3 $247.7 $243.5 
Exchange-traded0.2  — — 
Over-the-counter cleared22.6 22.5 10.2 9.1 
Foreign exchange contracts
Over-the-counter67.9 70.5 92.2 96.5 
Over-the-counter cleared1.1 1.1 1.4 1.3 
Equity contracts
Over-the-counter29.2 32.9 31.3 28.3 
Exchange-traded38.3 38.4 32.3 31.0 
Commodity contracts
Over-the-counter6.1 7.6 3.5 5.0 
Exchange-traded1.4 1.3 0.7 0.7 
Over-the-counter cleared0.1 0.1 — — 
Credit derivatives
Over-the-counter5.2 5.3 5.2 5.6 
Over-the-counter cleared1.8 1.8 2.2 1.9 
Total gross derivative assets/liabilities, before netting
Over-the-counter279.7 282.6 379.9 378.9 
Exchange-traded39.9 39.7 33.0 31.7 
Over-the-counter cleared25.6 25.5 13.8 12.3 
Less: Legally enforceable master netting agreements and cash collateral received/paid
Over-the-counter(250.3)(254.6)(345.7)(347.2)
Exchange-traded(37.8)(37.8)(29.5)(29.5)
Over-the-counter cleared(25.0)(25.4)(12.2)(11.8)
Derivative assets/liabilities, after netting32.1 30.0 39.3 34.4 
Other gross derivative assets/liabilities (2)
3.2 7.7 7.9 11.1 
Total derivative assets/liabilities35.3 37.7 47.2 45.5 
Less: Financial instruments collateral (3)
(11.8)(10.6)(16.1)(16.6)
Total net derivative assets/liabilities$23.5 $27.1 $31.1 $28.9 
(1)Over-the-counter derivatives include bilateral transactions between the Corporation and a particular counterparty. Over-the-counter 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 quality indicatorscontracts are refreshed LTVutilized in the Corporation's ALM and refreshed FICO score. Refreshed LTV measuresrisk 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,
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and other forecasted transactions (cash flow hedges). The Corporation hedges its net investment in consolidated non-U.S. operations determined to have functional currencies other than the U.S. dollar using forward exchange contracts and cross-currency basis swaps, and by issuing foreign currency-denominated debt (net investment hedges).
Fair Value Hedges
The table below summarizes information related to fair value hedges for 2021, 2020 and 2019.
Gains and Losses on Derivatives Designated as Fair Value Hedges
DerivativeHedged Item
(Dollars in millions)202120202019202120202019
Interest rate risk on long-term debt (1)
$(7,018)$7,091 $6,113 $6,838 $(7,220)$(6,110)
Interest rate and foreign currency risk on long-term debt (2)
(90)783 119 79 (783)(101)
Interest rate risk on available-for-sale securities (3)
5,203 (44)(102)(5,167)49 98 
Total$(1,905)$7,830 $6,130 $1,750 $(7,954)$(6,113)
(1)Amounts are recorded in interest expense in the Consolidated Statement of Income.
(2)For 2021, 2020 and 2019, the derivative amount includes gains (losses) of $(73) million, $701 million and $73 million in interest expense, $0, $73 million and $28 million in market making and similar activities, and $(17) million, $9 million and $18 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 loancumulative 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 and Liabilities
December 31, 2021December 31, 2020
(Dollars in millions)Carrying Value
Cumulative
Fair Value
 Adjustments (1)
Carrying Value
Cumulative
Fair Value
 Adjustments (1)
Long-term debt (2)
$181,745 $3,987 $150,556 $8,910 
Available-for-sale debt securities (2, 3, 4)
209,038 (2,294)116,252 114 
Trading account assets (5)
2,067 32 427 15 
(1)Increase (decrease) to carrying value.
(2)At December 31, 2021 and 2020, the cumulative fair value adjustments remaining on long-term debt and available-for-sale debt securities from discontinued hedging relationships resulted in an increase in the related liability of $1.5 billion and $3.7 billion and a percentagedecrease in the related asset of $1.0 billion and $69 million, which are being amortized over the remaining contractual life of the de-designated hedged items.
(3)These amounts include the amortized cost 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, 2021 and 2020, the amortized cost of the closed portfolios used in these hedging relationships was $21.1 billion and $34.6 billion, of which $6.9 billion and $7.0 billion was designated in the last-of-layer hedging relationship. At December 31, 2021, the cumulative adjustment associated with these hedging relationships was a decrease of $172 million. At December 31, 2020, the cumulative adjustment was insignificant.
(4)Carrying value represents amortized cost.
(5)Represents hedging activities related to certain commodities inventory.
Cash Flow and Net Investment Hedges
The table below summarizes certain information related to cash flow hedges and net investment hedges for 2021, 2020 and 2019. Of the $1.9 billion after-tax net loss ($2.5 billion pretax) on derivatives in accumulated OCI at December 31, 2021, gains of $477 million after-tax ($630 million pretax) related to both open and terminated cash flow 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 15 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)202120202019202120202019
Cash flow hedges
Interest rate risk on variable-rate assets (1)
$(2,686)$763 $671 $148 $(7)$(104)
Price risk on forecasted MBS purchases (1)
(249)241 — 26 — 
Price risk on certain compensation plans (2)
93 85 34 55 12 (2)
Total$(2,842)$1,089 $705 $229 $14 $(106)
Net investment hedges
Foreign exchange risk (3)
$1,451 $(834)$22 $23 $$366 
(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 $(123) million, $(11) million and $154 million in 2021, 2020 and 2019, respectively.
107 Bank of America


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 table below presents gains (losses) on these derivatives for 2021, 2020 and 2019. 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)202120202019
Interest rate risk on mortgage activities (1, 2)
$(18)$611 $388 
Credit risk on loans (2)
(25)(68)(58)
Interest rate and foreign currency risk on asset and liability management activities (3)
1,757 (2,971)1,112 
Price risk on certain compensation plans (4)
917 700 943 
(1)Includes hedges of interest rate risk on MSRs and IRLCs to originate mortgage loans that will be held for sale.
(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 December 31, 2021 and 2020, the Corporation had transferred $4.8 billion and $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 $4.8 billion and $5.2 billion at the transfer dates. At December 31, 2021 and 2020, the fair value of the property securingtransferred securities was $5.0 billion and $5.5 billion.
Sales and Trading Revenue
The Corporation enters into trading derivatives to facilitate client transactions and to manage risk exposures arising from trading account assets and liabilities. It is the Corporation’s policy to include these derivative instruments in its trading activities, which include derivatives and non-derivative cash instruments. The resulting risk from these derivatives is managed on a portfolio basis as part of the Corporation’s Global Markets business segment. The related sales and trading revenue generated within Global Markets is recorded in various income statement line items, including market making and similar activities and net interest income as well as other revenue categories.
Sales and trading revenue includes changes in the fair value and realized gains and losses on the sales of trading and other assets, net interest income, and fees primarily from commissions on equity securities. Revenue is generated by the difference in the client price for an instrument and the price at which the trading desk can execute the trade in the dealer market. For equity securities, commissions related to purchases and sales are recorded in the “Other” column in the Sales and Trading Revenue table. Changes in the fair value of these securities are included in market making and similar activities. For debt securities, revenue, with the exception of interest associated with the debt securities, is typically included in market making and similar activities. Unlike commissions for equity securities, the initial revenue related to broker-dealer
services for debt securities is typically included in the pricing of the instrument rather than being charged through separate fee arrangements. Therefore, this revenue is recorded in market making and similar activities as part of the initial mark to fair value. For derivatives, the majority of revenue is included in market making and similar activities. In transactions where the Corporation acts as agent, which include exchange-traded futures and options, fees are recorded in other income.
The 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 2021, 2020 and 2019. 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)2021
Interest rate risk$523 $1,794 $217 $2,534 
Foreign exchange risk1,505 (80)14 1,439 
Equity risk4,581 (5)1,834 6,410 
Credit risk1,390 1,684 556 3,630 
Other risk (2)
759 (128)124 755 
Total sales and trading revenue$8,758 $3,265 $2,745 $14,768 
2020
Interest rate risk$2,236 $2,279 $229 $4,744 
Foreign exchange risk1,486 (19)1,469 
Equity risk3,656 (77)1,801 5,380 
Credit risk783 1,758 331 2,872 
Other risk (2)
308 44 356 
Total sales and trading revenue$8,469 $3,945 $2,407 $14,821 
2019
Interest rate risk$1,046 $1,697 $113 $2,856 
Foreign exchange risk1,293 61 56 1,410 
Equity risk3,563 (634)1,569 4,498 
Credit risk1,040 1,928 519 3,487 
Other risk (2)
120 70 54 244 
Total sales and trading revenue$7,062 $3,122 $2,311 $12,495 
(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, $1.9 billion and $1.7 billion in 2021, 2020 and 2019, respectively.
(2)Includes commodity risk.
Credit Derivatives
The Corporation enters into credit derivatives primarily to facilitate client transactions and to manage credit risk exposures. Credit derivatives derive value based on an underlying third-party referenced obligation or a portfolio of referenced obligations and generally require the Corporation, as the seller of credit protection, to make payments to a buyer upon the occurrence of a predefined credit event. Such credit events generally include bankruptcy of the referenced credit entity and failure to pay under the obligation, as well as acceleration of indebtedness and payment repudiation or moratorium. For credit derivatives based on a portfolio of referenced credits or credit indices, the Corporation may not be required to make payment until a specified amount of loss has
Bank of America 108


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, 2021 and 2020 are summarized in the table below.
Credit Derivative Instruments
Less than
One Year
One to
Three Years
Three to
Five Years
Over Five
Years
Total
December 31, 2021
(Dollars in millions)Carrying Value
Credit default swaps:     
Investment grade$ $5 $79 $49 $133 
Non-investment grade34 250 453 769 1,506 
Total34 255 532 818 1,639 
Total return swaps/options:     
Investment grade35 388   423 
Non-investment grade105  16  121 
Total140 388 16  544 
Total credit derivatives$174 $643 $548 $818 $2,183 
Credit-related notes:     
Investment grade$ $ $36 $412 $448 
Non-investment grade5  9 1,334 1,348 
Total credit-related notes$5 $ $45 $1,746 $1,796 
 Maximum Payout/Notional
Credit default swaps:     
Investment grade$34,503 $66,334 $73,444 $17,844 $192,125 
Non-investment grade16,119 29,233 34,356 7,961 87,669 
Total50,622 95,567 107,800 25,805 279,794 
Total return swaps/options:     
Investment grade49,626 11,494 78  61,198 
Non-investment grade22,621 717 642 73 24,053 
Total72,247 12,211 720 73 85,251 
Total credit derivatives$122,869 $107,778 $108,520 $25,878 $365,045 
December 31, 2020
Carrying Value
Credit default swaps:
Investment grade$— $$35 $94 $130 
Non-investment grade26 233 364 1,163 1,786 
Total26 234 399 1,257 1,916 
Total return swaps/options:     
Investment grade21 — — 25 
Non-investment grade345 — — — 345 
Total366 — — 370 
Total credit derivatives$392 $238 $399 $1,257 $2,286 
Credit-related notes:     
Investment grade$— $— $— $572 $572 
Non-investment grade64 10 947 1,023 
Total credit-related notes$64 $$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 — 32,099 
Non-investment grade36,128 364 27 36,524 
Total67,089 1,425 104 68,623 
Total credit derivatives$114,227 $105,926 $123,300 $26,679 $370,132 
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 refreshed quarterly. Home equity loansobligation (CLO)
109 Bank of America


and credit-linked note vehicles. These instruments are evaluated using CLTV which measures theprimarily classified as trading securities. The carrying value of these instruments equals the Corporation’s loanmaximum exposure to loss. The Corporation is not obligated to make any payments to the entities under the terms of the securities owned.
Credit-related Contingent Features and available lineCollateral
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 combinedcovenants 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 105, the Corporation enters into legally enforceable master netting agreements that reduce risk by permitting closeout and netting of transactions with any outstandingthe 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, 2021 and 2020, the Corporation held cash and securities collateral of $91.4 billion and $96.5 billion and posted cash and securities collateral of $79.3 billion and $88.6 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 liens againstdebt ratings of the property asCorporation or certain subsidiaries. The amount of additional collateral required depends on the contract and is usually a percentage offixed incremental amount and/or the market value of the property securingexposure.
At December 31, 2021, the loan, refreshed quarterly. FICO score measures the creditworthinessamount of the borrowercollateral, calculated based on the financial obligationsterms of the borrowercontracts, that the Corporation and certain subsidiaries could be required to post to counterparties but had not yet posted to counterparties was $2.3 billion, including $1.4 billion for Bank of America, National Association (BANA).
Some counterparties are currently able to unilaterally terminate certain contracts, or the borrower’sCorporation or certain subsidiaries may be required to take other action such as find a suitable replacement or obtain a guarantee. At December 31, 2021 and 2020, 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, 2021 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. The table also presents derivative liabilities that would be subject to unilateral termination by counterparties upon downgrade of the Corporation's or certain subsidiaries' long-term senior debt ratings.
Additional Collateral Required to be Posted and Derivative Liabilities Subject to Unilateral Termination Upon Downgrade
at December 31, 2021
(Dollars in millions)One
incremental
 notch
Second
incremental
 notch
Additional collateral required to be posted upon downgrade
Bank of America Corporation$316 $823 
Bank of America, N.A. and subsidiaries (1)
75 646 
Derivative liabilities subject to unilateral termination upon downgrade
Derivative liabilities$32 $994 
Collateral posted25 634 
(1)Included in Bank of America Corporation collateral requirements in this table.
Valuation Adjustments on Derivatives
TheCorporation records credit history. FICO scoresrisk 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 typically refreshed quarterly or more frequently. Certain borrowers (e.g.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), borrowers thatDVA and FVA gains (losses) on derivatives (excluding the effect of any related hedge activities), which are recorded in market making and similar activities, for 2021, 2020 and 2019. 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 had debts discharged in a bankruptcy proceeding) may notthe 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 their FICOthe opposite impact.
Valuation Adjustments Gains (Losses) on Derivatives (1)
(Dollars in millions)202120202019
Derivative assets (CVA)$208 $(118)$72 
Derivative assets/liabilities (FVA)(2)(24)(2)
Derivative liabilities (DVA)3 24 (147)
(1)At December 31, 2021, 2020 and 2019, cumulative CVA reduced the derivative assets balance by $438 million, $646 million, and $528 million cumulative FVA reduced the net derivatives balance by $179 million, $177 million and $153 million, and cumulative DVA reduced the derivative liabilities balance by $312 million, $309 million and $285 million, respectively.
Bank of America 110


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, 2021 and 2020.
Debt Securities
Amortized
Cost
Gross
Unrealized
Gains
Gross
Unrealized
Losses
Fair
Value
Amortized
Cost
Gross
Unrealized
Gains
Gross
Unrealized
Losses
Fair
Value
(Dollars in millions)December 31, 2021December 31, 2020
Available-for-sale debt securities
Mortgage-backed securities:
Agency$45,268 $1,257 $(186)$46,339 $59,518 $2,370 $(39)$61,849 
Agency-collateralized mortgage obligations3,331 74 (25)3,380 5,112 161 (13)5,260 
Commercial19,036 647 (79)19,604 15,470 1,025 (4)16,491 
Non-agency residential (1)
591 25 (33)583 899 127 (17)1,009 
Total mortgage-backed securities68,226 2,003 (323)69,906 80,999 3,683 (73)84,609 
U.S. Treasury and government agencies197,853 1,610 (318)199,145 114,157 2,236 (13)116,380 
Non-U.S. securities11,933   11,933 14,009 15 (7)14,017 
Other taxable securities2,725 39 (3)2,761 2,656 61 (6)2,711 
Tax-exempt securities15,155 317 (39)15,433 16,417 389 (32)16,774 
Total available-for-sale debt securities295,892 3,969 (683)299,178 228,238 6,384 (131)234,491 
Other debt securities carried at fair value (2)
8,873 105 (83)8,895 11,720 429 (39)12,110 
Total debt securities carried at fair value304,765 4,074 (766)308,073 239,958 6,813 (170)246,601 
Held-to-maturity debt securities
Agency mortgage-backed securities553,721 3,855 (10,366)547,210 414,289 9,768 (36)424,021 
U.S. Treasury and government agencies111,859 254 (2,395)109,718 16,084 — (71)16,013 
Other taxable securities9,011 147 (196)8,962 7,906 327 (87)8,146 
Total held-to-maturity debt securities674,591 4,256 (12,957)665,890 438,279 10,095 (194)448,180 
Total debt securities (3,4)
$979,356 $8,330 $(13,723)$973,963 $678,237 $16,908 $(364)$694,781 
(1)At December 31, 2021 and 2020, the underlying collateral type included approximately 21 percent and 37 percent prime, 0 percent and 2 percent Alt-A and 79 percent and 61 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 $111.9 billion and $65.5 billion at December 31, 2021 and 2020.
(4)The Corporation held debt securities from FNMA and FHLMC that each exceeded 10 percent of shareholders’ equity, with an amortized cost of $345.3 billion and $205.3 billion, and a fair value of $342.5 billion and $202.4 billion at December 31, 2021, and 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.
scores updated. FICO scores are also a primary credit quality indicator for
At December 31, 2021, the Credit Cardaccumulated 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 $2.5 billion, net of the related income tax expense of $817 million. At December 31, 2021 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 listed2020, nonperforming AFS debt securities held by the Corporation were insignificant.
At December 31, 2021 and 2020, the Corporation had $268.5 billion and $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 $30.7 billion and $34.5 billion in AFS debt securities at December 31, 2021 and 2020, the amount of ECL was insignificant. Substantially all of the Corporation's HTM debt securities consist of U.S. agency and U.S. Treasury securities and have a zero credit loss assumption.
At December 31, 2021 and 2020, the Corporation held equity securities at an aggregate fair value of $513 million and $769 million and other equity securities, as Special Mention, Substandard or Doubtful,valued under the
measurement alternative, at a carrying value of $266 million and $240 million, both of which are asset quality categories defined by regulatory authorities. These assets have an elevated level of riskincluded in other assets. At December 31, 2021 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,2020, the Corporation usesalso held money market investments at a fair value of $707 million and $1.6 billion, which are included in time deposits placed and other credit quality indicatorsshort-term investments.
The gross realized gains and losses on sales of AFS debt securities for certain types2021, 2020 and 2019 are presented in the table below.
Gains and Losses on Sales of AFS Debt Securities
(Dollars in millions)202120202019
Gross gains$49 $423 $336 
Gross losses(27)(12)(119)
Net gains on sales of AFS debt securities$22 $411 $217 
Income tax expense attributable to realized net gains on sales of AFS debt securities$5 $103 $54 
111 Bank of America


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, 2021 and 2020.
Total AFS Debt Securities in a Continuous Unrealized Loss Position
Less than Twelve MonthsTwelve Months or LongerTotal
Fair
Value
Gross
 Unrealized
 Losses
Fair
Value
Gross
 Unrealized
 Losses
Fair
Value
Gross
 Unrealized
 Losses
(Dollars in millions)December 31, 2021
Continuously unrealized loss-positioned AFS debt securities
Mortgage-backed securities:   
Agency$11,733 $(166)$815 $(20)$12,548 $(186)
Agency-collateralized mortgage obligations1,427 (22)122 (3)1,549 (25)
Commercial3,451 (41)776 (38)4,227 (79)
Non-agency residential241 (13)174 (20)415 (33)
Total mortgage-backed securities16,852 (242)1,887 (81)18,739 (323)
U.S. Treasury and government agencies103,307 (272)4,850 (46)108,157 (318)
Other taxable securities  82 (3)82 (3)
Tax-exempt securities502 (16)109 (23)611 (39)
Total AFS debt securities in a continuous
   unrealized loss position
$120,661 $(530)$6,928 $(153)$127,589 $(683)
December 31, 2020
Continuously unrealized loss-positioned AFS debt securities
Mortgage-backed securities:
Agency$2,841 $(39)$$— $2,843 $(39)
Agency-collateralized mortgage obligations187 (2)364 (11)551 (13)
Commercial566 (4)— 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 government agencies8,282 (9)498 (4)8,780 (13)
Non-U.S. securities1,861 (6)135 (1)1,996 (7)
Other taxable securities576 (2)396 (4)972 (6)
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)
Bank of America 112


The remaining contractual maturity distribution and yields of loans.the Corporation’s debt securities carried at fair value and HTM debt securities at December 31, 2021 are summarized in the table below. Actual duration and yields may differ as prepayments on the loans underlying the MBS 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$— — %$5.00 %$49 4.63 %$45,214 3.11 %$45,268 3.11 %
Agency-collateralized mortgage obligations— — — — 20 2.50 3,311 2.91 3,331 2.91 
Commercial363 2.30 10,123 2.48 6,285 1.79 2,278 1.87 19,049 2.18 
Non-agency residential— — — — — — 1,112 6.43 1,112 6.43 
Total mortgage-backed securities363 2.30 10,128 2.48 6,354 1.81 51,915 3.11 68,760 2.89 
U.S. Treasury and government agencies6,564 1.22 39,875 1.80 151,962 1.20 27 2.61 198,428 1.32 
Non-U.S. securities18,645 0.20 1,045 3.61 — — 9.15 19,697 0.38 
Other taxable securities562 1.49 1,646 1.97 308 2.04 209 1.76 2,725 1.86 
Tax-exempt securities2,485 1.06 6,520 1.42 3,105 1.81 3,045 1.46 15,155 1.45 
Total amortized cost of debt securities carried at fair value$28,619 0.56 $59,214 1.89 $161,729 1.23 $55,203 3.02 $304,765 1.62 
Amortized cost of HTM debt securities
Agency mortgage-backed securities$— — %$— — %$2.00 %$553,717 2.13 %$553,721 2.13 %
U.S. Treasury and government agencies— — — — 111,859 1.35 — — 111,859 1.35 
Other taxable securities37 5.31 1,035 2.21 473 2.66 7,466 2.51 9,011 2.50 
Total amortized cost of HTM debt securities$37 5.31 $1,035 2.21 $112,336 1.35 $561,183 2.13 $674,591 2.00 
Debt securities carried at fair value          
Mortgage-backed securities:          
Agency$—  $ $53  $46,281  $46,339  
Agency-collateralized mortgage obligations—  —  20  3,360  3,380  
Commercial366  10,562  6,379  2,310  19,617  
Non-agency residential—   —  1,164  1,168  
Total mortgage-backed securities366 10,571 6,452 53,115 70,504 
U.S. Treasury and government agencies6,614 40,912 152,168 26 199,720 
Non-U.S. securities18,599  1,046  —   19,652  
Other taxable securities566  1,676  310  212  2,764  
Tax-exempt securities2,489  6,660  3,223  3,061  15,433  
Total debt securities carried at fair value$28,634  $60,865  $162,153  $56,421  $308,073  
Fair value of HTM debt securities
Agency mortgage-backed securities$— $— $$547,206 $547,210 
U.S. Treasury and government agencies— — 109,718 — 109,718 
Other taxable securities371,060 4837,382 8,962 
Total fair value of HTM debt securities$37 $1,060 $110,205 $554,588 $665,890 
(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.
113 Bank of America


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, 20192021 and 2018.
2020.

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, 2021
Consumer real estate      
Residential mortgage$1,005 $297 $1,571 $2,873 $219,090 $221,963 
Home equity123 69 369 561 27,374 27,935 
Credit card and other consumer
Credit card298 212 487 997 80,441 81,438 
Direct/Indirect consumer (2)
147 52 18 217 103,343 103,560 
Other consumer    190 190 
Total consumer1,573 630 2,445 4,648 430,438 435,086 
Consumer loans accounted for under the fair value option (3)
     $618 618 
Total consumer loans and leases1,573 630 2,445 4,648 430,438 618 435,704 
Commercial
U.S. commercial815 308 396 1,519 324,417 325,936 
Non-U.S. commercial148 20 83 251 113,015 113,266 
Commercial real estate (4)
115 34 285 434 62,575 63,009 
Commercial lease financing104 28 13 145 14,680 14,825 
U.S. small business commercial (5)
129 259 89 477 18,706 19,183 
Total commercial1,311 649 866 2,826 533,393 536,219 
Commercial loans accounted for under the fair value option (3)
     7,201 7,201 
Total commercial loans and leases1,311 649 866 2,826 533,393 7,201 543,420 
Total loans and leases (6)
$2,884 $1,279 $3,311 $7,474 $963,831 $7,819 $979,124 
Percentage of outstandings0.29 %0.13 %0.34 %0.76 %98.44 %0.80 %100.00 %
(1)Consumer real estate loans 30-59 days past due includes fully-insured loans of $164 million and nonperforming loans of $118 million. Consumer real estate loans 60-89 days past due includes fully-insured loans of $89 million and nonperforming loans of $100 million. Consumer real estate loans 90 days or more past due includes fully-insured loans of $633 million. Consumer real estate loans current or less than 30 days past due includes $1.4 billion and direct/indirect consumer includes $55 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 $48.5 billion, U.S. securities-based lending loans of $51.1 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 $279 million and home equity loans of $339 million. Commercial loans accounted for under the fair value option includes U.S. commercial loans of $4.6 billion and non-U.S. commercial loans of $2.6 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 $58.2 billion and non-U.S. commercial real estate loans of $4.8 billion.
(5)Includes Paycheck Protection Program loans.
(6)Total outstandings includes loans and leases pledged as collateral of $13.0 billion. The Corporation also pledged $146.6 billion of loans with no related outstanding borrowings to secure potential borrowing capacity with the Federal Reserve Bank and Federal Home Loan Bank.
Bank of America 114


                
Consumer Real Estate – Credit Quality Indicators (1)
                
 Core Residential Mortgage Non-core Residential Mortgage 
Core
Home Equity
 Non-core Home Equity Core Residential Mortgage Non-core Residential Mortgage 
Core
Home Equity
 Non-core Home Equity
(Dollars in millions)December 31, 2019 December 31, 2018
Refreshed LTV 
 
  
  
    
  
  
  
Less than or equal to 90 percent$205,357
 $7,433
 $34,733
 $4,127
 $173,911
 $10,272
 $39,246
 $6,478
Greater than 90 percent but less than or equal to 100 percent3,100
 273
 226
 348
 2,349
 533
 354
 715
Greater than 100 percent1,049
 267
 267
 507
 817
 545
 410
 1,083
Fully-insured loans (2)
16,264
 2,426
     16,618
 3,512
    
Total consumer real estate$225,770
 $10,399
 $35,226
 $4,982
 $193,695
 $14,862
 $40,010
 $8,276
Refreshed FICO score         
  
  
  
Less than 620$2,127
 $1,230
 $751
 $541
 $2,125
 $1,974
 $1,064
 $1,503
Greater than or equal to 620 and less than 6804,821
 1,053
 1,550
 800
 4,538
 1,719
 2,008
 1,720
Greater than or equal to 680 and less than 74026,905
 1,981
 6,025
 1,412
 23,841
 3,042
 7,008
 2,188
Greater than or equal to 740175,653
 3,709
 26,900
 2,229
 146,573
 4,615
 29,930
 2,865
Fully-insured loans (2)
16,264
 2,426
     16,618
 3,512
    
Total consumer real estate$225,770
 $10,399
 $35,226
 $4,982
 $193,695
 $14,862
 $40,010
 $8,276
(1)
Excludes $594 million and $682 million of loans accounted for under the fair value option at December 31, 2019 and 2018.
(2)
Credit quality indicators are not reported for fully-insured loans as principal repayment is insured.
            
Credit Card and Other Consumer – Credit Quality Indicators        
            
 
Credit
Card
 
Direct/Indirect
Consumer
 Other Consumer Credit
Card
 Direct/Indirect
Consumer
 Other Consumer
(Dollars in millions)December 31, 2019 December 31, 2018
Refreshed FICO score 
  
        
Less than 620$5,179
 $1,720
   $5,016
 $1,719
  
Greater than or equal to 620 and less than 68012,277
 2,734
   12,415
 3,124
  
Greater than or equal to 680 and less than 74035,301
 8,460
   35,781
 8,921
  
Greater than or equal to 74044,851
 37,825
   45,126
 36,709
  
Other internal credit metrics (1, 2)
  40,259
 $192
   40,693
 $202
Total credit card and other consumer$97,608
 $90,998
 $192
 $98,338
 $91,166
 $202
(1)
Other internal credit metrics may include delinquency status, geography or other factors.
(2)
Direct/indirect consumer includes $39.6 billion and $39.9 billion of securities-based lending which is overcollateralized and therefore has minimal credit risk at December 31, 2019 and 2018.
          
Commercial – Credit Quality Indicators (1)
    
          
 
U.S.
Commercial
 
Non-U.S.
Commercial
 
Commercial
Real Estate
 
Commercial
Lease
Financing
 
U.S. Small
Business
Commercial (2)
(Dollars in millions)December 31, 2019
Risk ratings 
  
  
  
  
Pass rated$299,380
 $104,051
 $61,598
 $19,551
 $231
Reservable criticized7,668
 915
 1,091
 329
 18
Refreshed FICO score         
Less than 620 
       308
Greater than or equal to 620 and less than 680        756
Greater than or equal to 680 and less than 740        2,267
Greater than or equal to 740        4,607
Other internal credit metrics (3)
        7,146
Total commercial$307,048
 $104,966
 $62,689
 $19,880
 $15,333
          
 December 31, 2018
Risk ratings         
Pass rated$291,918
 $97,916
 $59,910
 $22,168
 $389
Reservable criticized7,359
 860
 935
 366
 29
Refreshed FICO score         
Less than 620        264
Greater than or equal to 620 and less than 680        684
Greater than or equal to 680 and less than 740        2,072
Greater than or equal to 740        4,254
Other internal credit metrics (3)
        6,873
Total commercial$299,277
 $98,776
 $60,845
 $22,534
 $14,565

(1)
Excludes $7.7 billion and $3.7 billion of loans accounted for under the fair value option at December 31, 2019 and 2018.
(2)
At December 31, 2019 and 2018, U.S. small business commercial includes $715 million and $731 million of criticized business card and small business loans which are evaluated using refreshed FICO scores or internal credit metrics, including delinquency status, rather than risk ratings. Refreshed FICO score and other internal credit metrics are applicable only to the U.S. small business commercial portfolio.
(3)
Other internal credit metrics may include delinquency status, application scores, geography or other factors. At both December 31, 2019 and 2018, 99 percent of the balances where internal credit metrics are used were current or less than 30 days past due.

115Bank of America






Impaired Loans and Troubled Debt Restructurings
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, 2020
Consumer real estate      
Residential mortgage$1,430 $297 $1,699 $3,426 $220,129 $223,555 
Home equity154 78 345 577 33,734 34,311 
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 consumer — — — — 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 %
A(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 is considered impaired when, based on current information, it is probable thatmodifications related to the Corporation will be unable to collect all amounts due from the borrower in accordance with the contractual terms of the loan. For more information,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 Paycheck Protection Program 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.
The Corporation has entered into long-term credit protection agreements with FNMA and FHLMC on loans totaling $10.5 billion and $9.0 billion at December 31, 2021 and 2020, 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 decreased to $1.6 billion at December 31, 2021 from $2.2 billion at December 31, 2020. Consumer nonperforming loans increased to $3.0 billion at
December 31, 2021 from $2.7 billion at December 31, 2020 driven by consumer real estate deferral activity.
The following table presents the Corporation’s nonperforming loans and leases including nonperforming TDRs, and loans accruing past due 90 days or more at December 31, 2021 and 2020. Nonperforming LHFS are excluded from nonperforming loans and leases as they are recorded at either fair value or the lower of cost or fair value. For more information on the criteria for classification as nonperforming, see Note 1 – Summary of Significant Accounting Principles.
115 Bank of America


Credit Quality
Nonperforming Loans
and Leases
Accruing Past Due
90 Days or More (1)
December 31
(Dollars in millions)2021202020212020
Residential mortgage (2)
$2,284 $2,005 $634 $762 
With no related allowance (3)
1,950 1,378  — 
Home equity (2)
630 649  — 
With no related allowance (3)
414 347  — 
Credit Card                     n/a              n/a487 903 
Direct/indirect consumer75 71 11 33 
Total consumer2,989 2,725 1,132 1,698 
U.S. commercial825 1,243 171 228 
Non-U.S. commercial268 418 19 10 
Commercial real estate382 404 40 
Commercial lease financing80 87 8 25 
U.S. small business commercial23 75 87 115 
Total commercial1,578 2,227 325 384 
Total nonperforming loans$4,567 $4,952 $1,457 $2,082 
Percentage of outstanding loans and leases0.47 %0.54 %0.15 %0.23 %
(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, 2021 and 2020 residential mortgage includes $444 million and $537 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 $190 million and $225 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
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 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.
97 Bank of America


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. When a nonaccrual loan is deemed uncollectible, it is charged off against the allowance for credit losses. If the charged-off amount is later recovered, the amount is reversed through the allowance for credit losses at the recovery date. Charge-offs are reported net of recoveries (net charge-offs). If recoveries for the period are greater than charge-offs, net charge-offs are reported as a negative amount.
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 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.
Bank of America 98


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 Coronavirus Disease 2019 (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 expired on January 1, 2022. 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 zero. For all other assets, the Corporation performs qualitative analyses, including consideration of historical losses and current economic conditions, to estimate any ECL which are then included in a valuation account that is recorded as a contra-asset against the amortized cost basis of the financial asset.
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
99 Bank of America


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 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
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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 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
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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, 2021, 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 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. At December 31, 2021 and 2020, the Corporation had approximately 67,000 and 332,000 PPP loans with a carrying value of $4.7 billion and $22.7 billion. As compensation for originating the loans, the Corporation received lender processing fees from the SBA, which were capitalized, along with the loan origination costs, and are being 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 are recognized as interest income in that period.


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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 2021, 2020 and 2019. 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)202120202019
Net interest income
Interest income
Loans and leases$29,282 $34,029 $43,086 
Debt securities12,376 9,790 11,806 
Federal funds sold and securities borrowed or purchased under agreements to resell (1)
(90)903 4,843 
Trading account assets3,770 4,128 5,196 
Other interest income2,334 2,735 6,305 
Total interest income47,672 51,585 71,236 
Interest expense
Deposits537 1,943 7,188 
Short-term borrowings (1)
(358)987 7,208 
Trading account liabilities1,128 974 1,249 
Long-term debt3,431 4,321 6,700 
Total interest expense4,738 8,225 22,345 
Net interest income$42,934 $43,360 $48,891 
Noninterest income
Fees and commissions
Card income
Interchange fees (2)
$4,560 $3,954 $3,834 
Other card income1,658 1,702 1,963 
Total card income6,218 5,656 5,797 
Service charges
Deposit-related fees6,271 5,991 6,588 
Lending-related fees1,233 1,150 1,086 
Total service charges7,504 7,141 7,674 
Investment and brokerage services
Asset management fees12,729 10,708 10,241 
Brokerage fees3,961 3,866 3,661 
Total investment and brokerage services16,690 14,574 13,902 
Investment banking fees
Underwriting income5,077 4,698 2,998 
Syndication fees1,499 861 1,184 
Financial advisory services2,311 1,621 1,460 
Total investment banking fees8,887 7,180 5,642 
Total fees and commissions39,299 34,551 33,015 
Market making and similar activities8,691 8,355 9,034 
Other income (loss)(1,811)(738)304 
Total noninterest income$46,179 $42,168 $42,353 
(1)For more information on negative interest, see Note 1 – Summary of Significant Accounting Principles.
(2)Gross interchange fees and merchant income were $11.5 billion, $9.2 billion and $10.0 billion for 2021, 2020 and 2019, respectively, and are presented net of $6.9 billion, $5.5 billion and $6.2 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, 2021 and 2020. 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, 2021
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$18,068.1 $150.5 $8.9 $159.4 $156.4 $4.4 $160.8 
Futures and forwards2,243.2 1.1  1.1 1.0  1.0 
Written options1,616.1    28.8  28.8 
Purchased options1,673.6 33.1  33.1    
Foreign exchange contracts 
Swaps1,420.9 28.6 0.2 28.8 30.5 0.2 30.7 
Spot, futures and forwards4,087.2 37.1 0.3 37.4 37.7 0.2 37.9 
Written options287.2    4.1  4.1 
Purchased options267.6 4.1  4.1    
Equity contracts 
Swaps443.8 12.3  12.3 14.5  14.5 
Futures and forwards113.3 0.5  0.5 1.7  1.7 
Written options737.7    58.5  58.5 
Purchased options657.0 55.9  55.9    
Commodity contracts  
Swaps47.7 3.1  3.1 6.0  6.0 
Futures and forwards101.5 2.3  2.3 0.3 1.1 1.4 
Written options44.4    2.6  2.6 
Purchased options38.3 3.2  3.2    
Credit derivatives (2)
   
Purchased credit derivatives:   
Credit default swaps297.0 1.9  1.9 4.3  4.3 
Total return swaps/options85.3 0.2  0.2 1.1  1.1 
Written credit derivatives:  
Credit default swaps279.8 4.2  4.2 1.6  1.6 
Total return swaps/options85.3 0.9  0.9 0.5  0.5 
Gross derivative assets/liabilities$339.0 $9.4 $348.4 $349.6 $5.9 $355.5 
Less: Legally enforceable master netting agreements  (282.3)  (282.3)
Less: Cash collateral received/paid   (30.8)  (35.5)
Total derivative assets/liabilities   $35.3   $37.7 
(1)Represents the total contract/notional amount of derivative assets and liabilities outstanding.
(2)The net derivative asset and notional amount of written credit derivatives for which the Corporation held purchased credit derivatives with identical underlying referenced names were $2.3 billion and $258.4 billion at December 31, 2021.
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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 — 3.6 
Written options1,530.5 — — — 40.5 — 40.5 
Purchased options1,545.8 45.3 — 45.3 — — — 
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 — 53.4 54.5 0.5 55.0 
Written options289.6 — — — 4.8 — 4.8 
Purchased options279.3 5.0 — 5.0 — — — 
Equity contracts       
Swaps320.2 13.3 — 13.3 14.5 — 14.5 
Futures and forwards106.2 0.3 — 0.3 1.4 — 1.4 
Written options599.1 — — — 48.8 — 48.8 
Purchased options541.2 52.6 — 52.6 — — — 
Commodity contracts       
Swaps36.4 1.9 — 1.9 4.4 — 4.4 
Futures and forwards63.6 2.0 — 2.0 1.0 — 1.0 
Written options24.6 — — — 1.4 — 1.4 
Purchased options24.7 1.5 — 1.5 — — — 
Credit derivatives (2)
       
Purchased credit derivatives:       
Credit default swaps322.7 2.3 — 2.3 4.4 — 4.4 
Total return swaps/options63.6 0.2 — 0.2 1.0 — 1.0 
Written credit derivatives:      
Credit default swaps301.5 4.4 — 4.4 1.9 — 1.9 
Total return swaps/options68.6 0.6 — 0.6 0.4 — 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 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.
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, 2021 and 2020 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 – Securities Financing Agreements, Short-term Borrowings and Restricted Cash.
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Offsetting of Derivatives (1)
Derivative
Assets
Derivative
 Liabilities
Derivative
Assets
Derivative
 Liabilities
(Dollars in billions)December 31, 2021December 31, 2020
Interest rate contracts    
Over-the-counter$171.3 $166.3 $247.7 $243.5 
Exchange-traded0.2  — — 
Over-the-counter cleared22.6 22.5 10.2 9.1 
Foreign exchange contracts
Over-the-counter67.9 70.5 92.2 96.5 
Over-the-counter cleared1.1 1.1 1.4 1.3 
Equity contracts
Over-the-counter29.2 32.9 31.3 28.3 
Exchange-traded38.3 38.4 32.3 31.0 
Commodity contracts
Over-the-counter6.1 7.6 3.5 5.0 
Exchange-traded1.4 1.3 0.7 0.7 
Over-the-counter cleared0.1 0.1 — — 
Credit derivatives
Over-the-counter5.2 5.3 5.2 5.6 
Over-the-counter cleared1.8 1.8 2.2 1.9 
Total gross derivative assets/liabilities, before netting
Over-the-counter279.7 282.6 379.9 378.9 
Exchange-traded39.9 39.7 33.0 31.7 
Over-the-counter cleared25.6 25.5 13.8 12.3 
Less: Legally enforceable master netting agreements and cash collateral received/paid
Over-the-counter(250.3)(254.6)(345.7)(347.2)
Exchange-traded(37.8)(37.8)(29.5)(29.5)
Over-the-counter cleared(25.0)(25.4)(12.2)(11.8)
Derivative assets/liabilities, after netting32.1 30.0 39.3 34.4 
Other gross derivative assets/liabilities (2)
3.2 7.7 7.9 11.1 
Total derivative assets/liabilities35.3 37.7 47.2 45.5 
Less: Financial instruments collateral (3)
(11.8)(10.6)(16.1)(16.6)
Total net derivative assets/liabilities$23.5 $27.1 $31.1 $28.9 
(1)Over-the-counter derivatives include bilateral transactions between the Corporation and a particular counterparty. Over-the-counter 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,
Bank of America 106


and other forecasted transactions (cash flow hedges). The Corporation hedges its net investment in consolidated non-U.S. operations determined to have functional currencies other than the U.S. dollar using forward exchange contracts and cross-currency basis swaps, and by issuing foreign currency-denominated debt (net investment hedges).
Fair Value Hedges
The table below summarizes information related to fair value hedges for 2021, 2020 and 2019.
Gains and Losses on Derivatives Designated as Fair Value Hedges
DerivativeHedged Item
(Dollars in millions)202120202019202120202019
Interest rate risk on long-term debt (1)
$(7,018)$7,091 $6,113 $6,838 $(7,220)$(6,110)
Interest rate and foreign currency risk on long-term debt (2)
(90)783 119 79 (783)(101)
Interest rate risk on available-for-sale securities (3)
5,203 (44)(102)(5,167)49 98 
Total$(1,905)$7,830 $6,130 $1,750 $(7,954)$(6,113)
(1)Amounts are recorded in interest expense in the Consolidated Statement of Income.
(2)For 2021, 2020 and 2019, the derivative amount includes gains (losses) of $(73) million, $701 million and $73 million in interest expense, $0, $73 million and $28 million in market making and similar activities, and $(17) million, $9 million and $18 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 and Liabilities
December 31, 2021December 31, 2020
(Dollars in millions)Carrying Value
Cumulative
Fair Value
 Adjustments (1)
Carrying Value
Cumulative
Fair Value
 Adjustments (1)
Long-term debt (2)
$181,745 $3,987 $150,556 $8,910 
Available-for-sale debt securities (2, 3, 4)
209,038 (2,294)116,252 114 
Trading account assets (5)
2,067 32 427 15 
(1)Increase (decrease) to carrying value.
(2)At December 31, 2021 and 2020, the cumulative fair value adjustments remaining on long-term debt and available-for-sale debt securities from discontinued hedging relationships resulted in an increase in the related liability of $1.5 billion and $3.7 billion and a decrease in the related asset of $1.0 billion and $69 million, which are being amortized over the remaining contractual life of the de-designated hedged items.
(3)These amounts include the amortized cost 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, 2021 and 2020, the amortized cost of the closed portfolios used in these hedging relationships was $21.1 billion and $34.6 billion, of which $6.9 billion and $7.0 billion was designated in the last-of-layer hedging relationship. At December 31, 2021, the cumulative adjustment associated with these hedging relationships was a decrease of $172 million. At December 31, 2020, the cumulative adjustment was insignificant.
(4)Carrying value represents amortized cost.
(5)Represents hedging activities related to certain commodities inventory.
Cash Flow and Net Investment Hedges
The table below summarizes certain information related to cash flow hedges and net investment hedges for 2021, 2020 and 2019. Of the $1.9 billion after-tax net loss ($2.5 billion pretax) on derivatives in accumulated OCI at December 31, 2021, gains of $477 million after-tax ($630 million pretax) related to both open and terminated cash flow 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 15 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)202120202019202120202019
Cash flow hedges
Interest rate risk on variable-rate assets (1)
$(2,686)$763 $671 $148 $(7)$(104)
Price risk on forecasted MBS purchases (1)
(249)241 — 26 — 
Price risk on certain compensation plans (2)
93 85 34 55 12 (2)
Total$(2,842)$1,089 $705 $229 $14 $(106)
Net investment hedges
Foreign exchange risk (3)
$1,451 $(834)$22 $23 $$366 
(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 $(123) million, $(11) million and $154 million in 2021, 2020 and 2019, respectively.
107 Bank of America


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 table below presents gains (losses) on these derivatives for 2021, 2020 and 2019. 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)202120202019
Interest rate risk on mortgage activities (1, 2)
$(18)$611 $388 
Credit risk on loans (2)
(25)(68)(58)
Interest rate and foreign currency risk on asset and liability management activities (3)
1,757 (2,971)1,112 
Price risk on certain compensation plans (4)
917 700 943 
(1)Includes hedges of interest rate risk on MSRs and IRLCs to originate mortgage loans that will be held for sale.
(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 December 31, 2021 and 2020, the Corporation had transferred $4.8 billion and $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 $4.8 billion and $5.2 billion at the transfer dates. At December 31, 2021 and 2020, the fair value of the transferred securities was $5.0 billion and $5.5 billion.
Sales and Trading Revenue
The Corporation enters into trading derivatives to facilitate client transactions and to manage risk exposures arising from trading account assets and liabilities. It is the Corporation’s policy to include these derivative instruments in its trading activities, which include derivatives and non-derivative cash instruments. The resulting risk from these derivatives is managed on a portfolio basis as part of the Corporation’s Global Markets business segment. The related sales and trading revenue generated within Global Markets is recorded in various income statement line items, including market making and similar activities and net interest income as well as other revenue categories.
Sales and trading revenue includes changes in the fair value and realized gains and losses on the sales of trading and other assets, net interest income, and fees primarily from commissions on equity securities. Revenue is generated by the difference in the client price for an instrument and the price at which the trading desk can execute the trade in the dealer market. For equity securities, commissions related to purchases and sales are recorded in the “Other” column in the Sales and Trading Revenue table. Changes in the fair value of these securities are included in market making and similar activities. For debt securities, revenue, with the exception of interest associated with the debt securities, is typically included in market making and similar activities. Unlike commissions for equity securities, the initial revenue related to broker-dealer
services for debt securities is typically included in the pricing of the instrument rather than being charged through separate fee arrangements. Therefore, this revenue is recorded in market making and similar activities as part of the initial mark to fair value. For derivatives, the majority of revenue is included in market making and similar activities. In transactions where the Corporation acts as agent, which include exchange-traded futures and options, fees are recorded in other income.
The 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 2021, 2020 and 2019. 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)2021
Interest rate risk$523 $1,794 $217 $2,534 
Foreign exchange risk1,505 (80)14 1,439 
Equity risk4,581 (5)1,834 6,410 
Credit risk1,390 1,684 556 3,630 
Other risk (2)
759 (128)124 755 
Total sales and trading revenue$8,758 $3,265 $2,745 $14,768 
2020
Interest rate risk$2,236 $2,279 $229 $4,744 
Foreign exchange risk1,486 (19)1,469 
Equity risk3,656 (77)1,801 5,380 
Credit risk783 1,758 331 2,872 
Other risk (2)
308 44 356 
Total sales and trading revenue$8,469 $3,945 $2,407 $14,821 
2019
Interest rate risk$1,046 $1,697 $113 $2,856 
Foreign exchange risk1,293 61 56 1,410 
Equity risk3,563 (634)1,569 4,498 
Credit risk1,040 1,928 519 3,487 
Other risk (2)
120 70 54 244 
Total sales and trading revenue$7,062 $3,122 $2,311 $12,495 
(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, $1.9 billion and $1.7 billion in 2021, 2020 and 2019, respectively.
(2)Includes commodity risk.
Credit Derivatives
The Corporation enters into credit derivatives primarily to facilitate client transactions and to manage credit risk exposures. Credit derivatives derive value based on an underlying third-party referenced obligation or a portfolio of referenced obligations and generally require the Corporation, as the seller of credit protection, to make payments to a buyer upon the occurrence of a predefined credit event. Such credit events generally include bankruptcy of the referenced credit entity and failure to pay under the obligation, as well as acceleration of indebtedness and payment repudiation or moratorium. For credit derivatives based on a portfolio of referenced credits or credit indices, the Corporation may not be required to make payment until a specified amount of loss has
Bank of America 108


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, 2021 and 2020 are summarized in the table below.
Credit Derivative Instruments
Less than
One Year
One to
Three Years
Three to
Five Years
Over Five
Years
Total
December 31, 2021
(Dollars in millions)Carrying Value
Credit default swaps:     
Investment grade$ $5 $79 $49 $133 
Non-investment grade34 250 453 769 1,506 
Total34 255 532 818 1,639 
Total return swaps/options:     
Investment grade35 388   423 
Non-investment grade105  16  121 
Total140 388 16  544 
Total credit derivatives$174 $643 $548 $818 $2,183 
Credit-related notes:     
Investment grade$ $ $36 $412 $448 
Non-investment grade5  9 1,334 1,348 
Total credit-related notes$5 $ $45 $1,746 $1,796 
 Maximum Payout/Notional
Credit default swaps:     
Investment grade$34,503 $66,334 $73,444 $17,844 $192,125 
Non-investment grade16,119 29,233 34,356 7,961 87,669 
Total50,622 95,567 107,800 25,805 279,794 
Total return swaps/options:     
Investment grade49,626 11,494 78  61,198 
Non-investment grade22,621 717 642 73 24,053 
Total72,247 12,211 720 73 85,251 
Total credit derivatives$122,869 $107,778 $108,520 $25,878 $365,045 
December 31, 2020
Carrying Value
Credit default swaps:
Investment grade$— $$35 $94 $130 
Non-investment grade26 233 364 1,163 1,786 
Total26 234 399 1,257 1,916 
Total return swaps/options:     
Investment grade21 — — 25 
Non-investment grade345 — — — 345 
Total366 — — 370 
Total credit derivatives$392 $238 $399 $1,257 $2,286 
Credit-related notes:     
Investment grade$— $— $— $572 $572 
Non-investment grade64 10 947 1,023 
Total credit-related notes$64 $$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 — 32,099 
Non-investment grade36,128 364 27 36,524 
Total67,089 1,425 104 68,623 
Total credit derivatives$114,227 $105,926 $123,300 $26,679 $370,132 
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)
109 Bank of America


and credit-linked note vehicles. These instruments are primarily classified as trading securities. The carrying value of these instruments equals the Corporation’s maximum exposure to loss. The Corporation is not obligated to make any payments to the entities under the terms of the securities owned.
Credit-related Contingent Features and Collateral
The Corporation executes the majority of its derivative contracts in the OTC market with large, international financial institutions, including broker-dealers and, to a lesser degree, with a variety of non-financial companies. A significant majority of the derivative transactions are executed on a daily margin basis. Therefore, events such as a credit rating downgrade (depending on the ultimate rating level) or a breach of credit covenants would typically require an increase in the amount of collateral required of the counterparty, where applicable, and/or allow the Corporation to take additional protective measures such as early termination of all trades. Further, as previously discussed on page 105, 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, 2021 and 2020, the Corporation held cash and securities collateral of $91.4 billion and $96.5 billion and posted cash and securities collateral of $79.3 billion and $88.6 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, 2021, the amount of collateral, calculated based on the terms of the contracts, that the Corporation and certain subsidiaries could be required to post to counterparties but had not yet posted to counterparties was $2.3 billion, including $1.4 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, 2021 and 2020, 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, 2021 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. The table also presents derivative liabilities that would be subject to unilateral termination by counterparties upon downgrade of the Corporation's or certain subsidiaries' long-term senior debt ratings.
Additional Collateral Required to be Posted and Derivative Liabilities Subject to Unilateral Termination Upon Downgrade
at December 31, 2021
(Dollars in millions)One
incremental
 notch
Second
incremental
 notch
Additional collateral required to be posted upon downgrade
Bank of America Corporation$316 $823 
Bank of America, N.A. and subsidiaries (1)
75 646 
Derivative liabilities subject to unilateral termination upon downgrade
Derivative liabilities$32 $994 
Collateral posted25 634 
(1)Included in Bank of America Corporation collateral requirements in this table.
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 2021, 2020 and 2019. 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)202120202019
Derivative assets (CVA)$208 $(118)$72 
Derivative assets/liabilities (FVA)(2)(24)(2)
Derivative liabilities (DVA)3 24 (147)
(1)At December 31, 2021, 2020 and 2019, cumulative CVA reduced the derivative assets balance by $438 million, $646 million, and $528 million cumulative FVA reduced the net derivatives balance by $179 million, $177 million and $153 million, and cumulative DVA reduced the derivative liabilities balance by $312 million, $309 million and $285 million, respectively.
Bank of America 110


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, 2021 and 2020.
Debt Securities
Amortized
Cost
Gross
Unrealized
Gains
Gross
Unrealized
Losses
Fair
Value
Amortized
Cost
Gross
Unrealized
Gains
Gross
Unrealized
Losses
Fair
Value
(Dollars in millions)December 31, 2021December 31, 2020
Available-for-sale debt securities
Mortgage-backed securities:
Agency$45,268 $1,257 $(186)$46,339 $59,518 $2,370 $(39)$61,849 
Agency-collateralized mortgage obligations3,331 74 (25)3,380 5,112 161 (13)5,260 
Commercial19,036 647 (79)19,604 15,470 1,025 (4)16,491 
Non-agency residential (1)
591 25 (33)583 899 127 (17)1,009 
Total mortgage-backed securities68,226 2,003 (323)69,906 80,999 3,683 (73)84,609 
U.S. Treasury and government agencies197,853 1,610 (318)199,145 114,157 2,236 (13)116,380 
Non-U.S. securities11,933   11,933 14,009 15 (7)14,017 
Other taxable securities2,725 39 (3)2,761 2,656 61 (6)2,711 
Tax-exempt securities15,155 317 (39)15,433 16,417 389 (32)16,774 
Total available-for-sale debt securities295,892 3,969 (683)299,178 228,238 6,384 (131)234,491 
Other debt securities carried at fair value (2)
8,873 105 (83)8,895 11,720 429 (39)12,110 
Total debt securities carried at fair value304,765 4,074 (766)308,073 239,958 6,813 (170)246,601 
Held-to-maturity debt securities
Agency mortgage-backed securities553,721 3,855 (10,366)547,210 414,289 9,768 (36)424,021 
U.S. Treasury and government agencies111,859 254 (2,395)109,718 16,084 — (71)16,013 
Other taxable securities9,011 147 (196)8,962 7,906 327 (87)8,146 
Total held-to-maturity debt securities674,591 4,256 (12,957)665,890 438,279 10,095 (194)448,180 
Total debt securities (3,4)
$979,356 $8,330 $(13,723)$973,963 $678,237 $16,908 $(364)$694,781 
(1)At December 31, 2021 and 2020, the underlying collateral type included approximately 21 percent and 37 percent prime, 0 percent and 2 percent Alt-A and 79 percent and 61 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 $111.9 billion and $65.5 billion at December 31, 2021 and 2020.
(4)The Corporation held debt securities from FNMA and FHLMC that each exceeded 10 percent of shareholders’ equity, with an amortized cost of $345.3 billion and $205.3 billion, and a fair value of $342.5 billion and $202.4 billion at December 31, 2021, and 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.
At December 31, 2021, 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 $2.5 billion, net of the related income tax expense of $817 million. At December 31, 2021 and 2020, nonperforming AFS debt securities held by the Corporation were insignificant.
At December 31, 2021 and 2020, the Corporation had $268.5 billion and $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 $30.7 billion and $34.5 billion in AFS debt securities at December 31, 2021 and 2020, the amount of ECL was insignificant. Substantially all of the Corporation's HTM debt securities consist of U.S. agency and U.S. Treasury securities and have a zero credit loss assumption.
At December 31, 2021 and 2020, the Corporation held equity securities at an aggregate fair value of $513 million and $769 million and other equity securities, as valued under the
measurement alternative, at a carrying value of $266 million and $240 million, both of which are included in other assets. At December 31, 2021 and 2020, the Corporation also held money market investments at a fair value of $707 million and $1.6 billion, which are included in time deposits placed and other short-term investments.
The gross realized gains and losses on sales of AFS debt securities for 2021, 2020 and 2019 are presented in the table below.
Gains and Losses on Sales of AFS Debt Securities
(Dollars in millions)202120202019
Gross gains$49 $423 $336 
Gross losses(27)(12)(119)
Net gains on sales of AFS debt securities$22 $411 $217 
Income tax expense attributable to realized net gains on sales of AFS debt securities$5 $103 $54 
111 Bank of America


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, 2021 and 2020.
Total AFS Debt Securities in a Continuous Unrealized Loss Position
Less than Twelve MonthsTwelve Months or LongerTotal
Fair
Value
Gross
 Unrealized
 Losses
Fair
Value
Gross
 Unrealized
 Losses
Fair
Value
Gross
 Unrealized
 Losses
(Dollars in millions)December 31, 2021
Continuously unrealized loss-positioned AFS debt securities
Mortgage-backed securities:   
Agency$11,733 $(166)$815 $(20)$12,548 $(186)
Agency-collateralized mortgage obligations1,427 (22)122 (3)1,549 (25)
Commercial3,451 (41)776 (38)4,227 (79)
Non-agency residential241 (13)174 (20)415 (33)
Total mortgage-backed securities16,852 (242)1,887 (81)18,739 (323)
U.S. Treasury and government agencies103,307 (272)4,850 (46)108,157 (318)
Other taxable securities  82 (3)82 (3)
Tax-exempt securities502 (16)109 (23)611 (39)
Total AFS debt securities in a continuous
   unrealized loss position
$120,661 $(530)$6,928 $(153)$127,589 $(683)
December 31, 2020
Continuously unrealized loss-positioned AFS debt securities
Mortgage-backed securities:
Agency$2,841 $(39)$$— $2,843 $(39)
Agency-collateralized mortgage obligations187 (2)364 (11)551 (13)
Commercial566 (4)— 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 government agencies8,282 (9)498 (4)8,780 (13)
Non-U.S. securities1,861 (6)135 (1)1,996 (7)
Other taxable securities576 (2)396 (4)972 (6)
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)
Bank of America 112


The remaining contractual maturity distribution and yields of the Corporation’s debt securities carried at fair value and HTM debt securities at December 31, 2021 are summarized in the table below. Actual duration and yields may differ as prepayments on the loans underlying the MBS 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$— — %$5.00 %$49 4.63 %$45,214 3.11 %$45,268 3.11 %
Agency-collateralized mortgage obligations— — — — 20 2.50 3,311 2.91 3,331 2.91 
Commercial363 2.30 10,123 2.48 6,285 1.79 2,278 1.87 19,049 2.18 
Non-agency residential— — — — — — 1,112 6.43 1,112 6.43 
Total mortgage-backed securities363 2.30 10,128 2.48 6,354 1.81 51,915 3.11 68,760 2.89 
U.S. Treasury and government agencies6,564 1.22 39,875 1.80 151,962 1.20 27 2.61 198,428 1.32 
Non-U.S. securities18,645 0.20 1,045 3.61 — — 9.15 19,697 0.38 
Other taxable securities562 1.49 1,646 1.97 308 2.04 209 1.76 2,725 1.86 
Tax-exempt securities2,485 1.06 6,520 1.42 3,105 1.81 3,045 1.46 15,155 1.45 
Total amortized cost of debt securities carried at fair value$28,619 0.56 $59,214 1.89 $161,729 1.23 $55,203 3.02 $304,765 1.62 
Amortized cost of HTM debt securities
Agency mortgage-backed securities$— — %$— — %$2.00 %$553,717 2.13 %$553,721 2.13 %
U.S. Treasury and government agencies— — — — 111,859 1.35 — — 111,859 1.35 
Other taxable securities37 5.31 1,035 2.21 473 2.66 7,466 2.51 9,011 2.50 
Total amortized cost of HTM debt securities$37 5.31 $1,035 2.21 $112,336 1.35 $561,183 2.13 $674,591 2.00 
Debt securities carried at fair value          
Mortgage-backed securities:          
Agency$—  $ $53  $46,281  $46,339  
Agency-collateralized mortgage obligations—  —  20  3,360  3,380  
Commercial366  10,562  6,379  2,310  19,617  
Non-agency residential—   —  1,164  1,168  
Total mortgage-backed securities366 10,571 6,452 53,115 70,504 
U.S. Treasury and government agencies6,614 40,912 152,168 26 199,720 
Non-U.S. securities18,599  1,046  —   19,652  
Other taxable securities566  1,676  310  212  2,764  
Tax-exempt securities2,489  6,660  3,223  3,061  15,433  
Total debt securities carried at fair value$28,634  $60,865  $162,153  $56,421  $308,073  
Fair value of HTM debt securities
Agency mortgage-backed securities$— $— $$547,206 $547,210 
U.S. Treasury and government agencies— — 109,718 — 109,718 
Other taxable securities371,060 4837,382 8,962 
Total fair value of HTM debt securities$37 $1,060 $110,205 $554,588 $665,890 
(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.
113 Bank of America


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, 2021 and 2020.
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, 2021
Consumer real estate      
Residential mortgage$1,005 $297 $1,571 $2,873 $219,090 $221,963 
Home equity123 69 369 561 27,374 27,935 
Credit card and other consumer
Credit card298 212 487 997 80,441 81,438 
Direct/Indirect consumer (2)
147 52 18 217 103,343 103,560 
Other consumer    190 190 
Total consumer1,573 630 2,445 4,648 430,438 435,086 
Consumer loans accounted for under the fair value option (3)
     $618 618 
Total consumer loans and leases1,573 630 2,445 4,648 430,438 618 435,704 
Commercial
U.S. commercial815 308 396 1,519 324,417 325,936 
Non-U.S. commercial148 20 83 251 113,015 113,266 
Commercial real estate (4)
115 34 285 434 62,575 63,009 
Commercial lease financing104 28 13 145 14,680 14,825 
U.S. small business commercial (5)
129 259 89 477 18,706 19,183 
Total commercial1,311 649 866 2,826 533,393 536,219 
Commercial loans accounted for under the fair value option (3)
     7,201 7,201 
Total commercial loans and leases1,311 649 866 2,826 533,393 7,201 543,420 
Total loans and leases (6)
$2,884 $1,279 $3,311 $7,474 $963,831 $7,819 $979,124 
Percentage of outstandings0.29 %0.13 %0.34 %0.76 %98.44 %0.80 %100.00 %
(1)Consumer real estate loans 30-59 days past due includes fully-insured loans of $164 million and nonperforming loans of $118 million. Consumer real estate loans 60-89 days past due includes fully-insured loans of $89 million and nonperforming loans of $100 million. Consumer real estate loans 90 days or more past due includes fully-insured loans of $633 million. Consumer real estate loans current or less than 30 days past due includes $1.4 billion and direct/indirect consumer includes $55 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 $48.5 billion, U.S. securities-based lending loans of $51.1 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 $279 million and home equity loans of $339 million. Commercial loans accounted for under the fair value option includes U.S. commercial loans of $4.6 billion and non-U.S. commercial loans of $2.6 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 $58.2 billion and non-U.S. commercial real estate loans of $4.8 billion.
(5)Includes Paycheck Protection Program loans.
(6)Total outstandings includes loans and leases pledged as collateral of $13.0 billion. The Corporation also pledged $146.6 billion of loans with no related outstanding borrowings to secure potential borrowing capacity with the Federal Reserve Bank and Federal Home Loan Bank.
Bank of America 114


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, 2020
Consumer real estate      
Residential mortgage$1,430 $297 $1,699 $3,426 $220,129 $223,555 
Home equity154 78 345 577 33,734 34,311 
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 consumer — — — — 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 Paycheck Protection Program 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.
The Corporation has entered into long-term credit protection agreements with FNMA and FHLMC on loans totaling $10.5 billion and $9.0 billion at December 31, 2021 and 2020, 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 decreased to $1.6 billion at December 31, 2021 from $2.2 billion at December 31, 2020. Consumer nonperforming loans increased to $3.0 billion at
December 31, 2021 from $2.7 billion at December 31, 2020 driven by consumer real estate deferral activity.
The following table presents the Corporation’s nonperforming loans and leases including nonperforming TDRs, and loans accruing past due 90 days or more at December 31, 2021 and 2020. Nonperforming LHFS are excluded from nonperforming loans and leases as they are recorded at either fair value or the lower of cost or fair value. For more information on the criteria for classification as nonperforming, see Note 1 – Summary of Significant Accounting Principles.
115 Bank of America


Credit Quality
Nonperforming Loans
and Leases
Accruing Past Due
90 Days or More (1)
December 31
(Dollars in millions)2021202020212020
Residential mortgage (2)
$2,284 $2,005 $634 $762 
With no related allowance (3)
1,950 1,378  — 
Home equity (2)
630 649  — 
With no related allowance (3)
414 347  — 
Credit Card                     n/a              n/a487 903 
Direct/indirect consumer75 71 11 33 
Total consumer2,989 2,725 1,132 1,698 
U.S. commercial825 1,243 171 228 
Non-U.S. commercial268 418 19 10 
Commercial real estate382 404 40 
Commercial lease financing80 87 8 25 
U.S. small business commercial23 75 87 115 
Total commercial1,578 2,227 325 384 
Total nonperforming loans$4,567 $4,952 $1,457 $2,082 
Percentage of outstanding loans and leases0.47 %0.54 %0.15 %0.23 %
(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, 2021 and 2020 residential mortgage includes $444 million and $537 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 $190 million and $225 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
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 Fair Isaac Corporation (FICO) score. Refreshed LTV measures the carrying value of TDRs. Most modificationsthe loan as a percentage of the value of the property securing the loan, refreshed quarterly. Home equity loans are evaluated using combined loan-to-value (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, 2021, including revolving loans that converted to term loans without an additional credit decision after origination or through a TDR.
Bank of America 116


Residential Mortgage – Credit Quality Indicators By Vintage
Term Loans by Origination Year
(Dollars in millions)Total as of
December 31,
 2021
20212020201920182017Prior
Total Residential Mortgage
Refreshed LTV
   
Less than or equal to 90 percent$206,562 $87,051 $43,597 $23,205 $7,392 $10,956 $34,361 
Greater than 90 percent but less than or equal to 100 percent1,938 1,401 331 81 17 14 94 
Greater than 100 percent759 520 112 29 11 12 75 
Fully-insured loans12,704 3,845 3,486 1,150 216 235 3,772 
Total Residential Mortgage$221,963 $92,817 $47,526 $24,465 $7,636 $11,217 $38,302 
Total Residential Mortgage
Refreshed FICO score
Less than 620$2,451 $636 $442 $140 $120 $104 $1,009 
Greater than or equal to 620 and less than 6805,199 1,511 1,123 477 294 307 1,487 
Greater than or equal to 680 and less than 74024,532 8,822 5,454 2,785 1,057 1,434 4,980 
Greater than or equal to 740177,077 78,003 37,021 19,913 5,949 9,137 27,054 
Fully-insured loans12,704 3,845 3,486 1,150 216 235 3,772 
Total Residential Mortgage$221,963 $92,817 $47,526 $24,465 $7,636 $11,217 $38,302 
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, 2021
Total Home Equity
Refreshed LTV
   
Less than or equal to 90 percent$27,594 $1,773 $19,095 $6,726 
Greater than 90 percent but less than or equal to 100 percent130 55 34 41 
Greater than 100 percent211 85 54 72 
Total Home Equity$27,935 $1,913 $19,183 $6,839 
Total Home Equity
Refreshed FICO score
Less than 620$893 $244 $209 $440 
Greater than or equal to 620 and less than 6801,434 222 495 717 
Greater than or equal to 680 and less than 7404,625 468 2,493 1,664 
Greater than or equal to 74020,983 979 15,986 4,018 
Total Home Equity$27,935 $1,913 $19,183 $6,839 
(1)Includes reverse mortgages of $1.3 billion and home equity loans of $582 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,
 2021
Revolving Loans20212020201920182017PriorTotal Credit Card as of December 31,
 2021
Revolving Loans
Revolving Loans Converted to Term Loans (1)
Refreshed FICO score  
Less than 620$685 $13 $179 $115 $129 $79 $101 $69 $3,017 $2,857 $160 
Greater than or equal to 620 and less than 6802,313 14 1,170 414 313 148 134 120 9,264 9,064 200 
Greater than or equal to 680 and less than 7408,530 60 4,552 1,659 1,126 466 314 353 28,347 28,155 192 
Greater than or equal to 74037,164 94 15,876 8,642 6,465 2,679 1,573 1,835 40,810 40,762 48 
Other internal credit
   metrics (2,3)
54,868 54,173 283 53 77 75 63 144  — — 
Total credit card and other
   consumer
$103,560 $54,354 $22,060 $10,883 $8,110 $3,447 $2,185 $2,521 $81,438 $80,838 $600 
(1)Represents TDRs that were modified into term loans.
(2)Other internal credit metrics may include delinquency status, geography or other factors.
(3)Direct/indirect consumer real estateincludes $54.2 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, 2021.

117 Bank of America


Commercial – Credit Quality Indicators By Vintage (1, 2)
Term Loans
Amortized Cost Basis by Origination Year
(Dollars in millions)Total as of
December 31,
 2021
20212020201920182017PriorRevolving Loans
U.S. Commercial
Risk ratings    
Pass rated$315,618 $55,862 $25,012 $23,373 $11,439 $10,426 $23,877 $165,629 
Reservable criticized10,318 598 687 1,308 1,615 514 1,072 4,524 
Total U.S. Commercial$325,936 $56,460 $25,699 $24,681 $13,054 $10,940 $24,949 $170,153 
Non-U.S. Commercial
Risk ratings
Pass rated$110,787 $25,749 $8,703 $7,133 $4,521 $3,016 $3,062 $58,603 
Reservable criticized2,479 223 324 487 275 257 216 697 
Total Non-U.S. Commercial$113,266 $25,972 $9,027 $7,620 $4,796 $3,273 $3,278 $59,300 
Commercial Real Estate
Risk ratings
Pass rated$55,511 $14,402 $7,244 $11,237 $5,710 $3,326 $6,831 $6,761 
Reservable criticized7,498 277 990 2,237 1,710 596 1,464 224 
Total Commercial Real Estate$63,009 $14,679 $8,234 $13,474 $7,420 $3,922 $8,295 $6,985 
Commercial Lease Financing
Risk ratings
Pass rated$14,438 $3,280 $2,485 $2,427 $2,030 $1,741 $2,475 $— 
Reservable criticized387 25 18 91 67 48 138 — 
Total Commercial Lease Financing$14,825 $3,305 $2,503 $2,518 $2,097 $1,789 $2,613 $— 
U.S. Small Business Commercial (3)
Risk ratings
Pass rated$11,618 $4,257 $2,922 $1,059 $763 $623 $1,853 $141 
Reservable criticized433 12 29 91 87 64 147 
Total U.S. Small Business Commercial$12,051 $4,269 $2,951 $1,150 $850 $687 $2,000 $144 
 Total$529,087 $104,685 $48,414 $49,443 $28,217 $20,611 $41,135 $236,582 
(1) Excludes $7.2 billion of loans meetaccounted for under the definitionfair value option at December 31, 2021.
(2)     Includes $16 million of loans that converted from revolving to term loans.
(3)     Excludes U.S. Small Business Card loans of $7.1 billion. Refreshed FICO scores for this portfolio are $192 million for less than 620; $618 million for greater than or equal to 620 and less than 680; $1.9 billion for greater than or equal to 680 and less than 740; and $4.4 billion greater than or equal to 740.

Bank of America 118


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.
Residential Mortgage – Credit Quality Indicators By Vintage
Term Loans by Origination Year
(Dollars in millions)Total as of
 December 31,
 2020
20202019201820172016Prior
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.
119 Bank of America


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 (1)
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 (2, 3)
44,766 44,098 74 115 84 67 52 276 — — — 
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)Represents TDRs when a binding offerthat were modified into term loans.
(2)Other internal credit metrics may include delinquency status, geography or other factors.
(3)Direct/indirect consumer includes $44.1 billion of securities-based lending which is extendedtypically supported by highly liquid collateral with market value greater than or equal to a borrower. the outstanding loan balance and therefore has minimal credit risk at December 31, 2020.

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$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.

Bank of America 120


During 2021, commercial credit quality showed signs of stabilization as the economy continued to recover. Commercial reservable criticized utilized exposure decreased to $22.4 billion at December 31, 2021 from $38.7 billion (to 3.91 percent from 7.31 percent of total commercial reservable utilized exposure) at December 31, 2020, which was broad-based across industries.
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 $632$306 million that have been discharged in Chapter 7 bankruptcy with no change in
repayment terms and not reaffirmed by the borrower were included in TDRs at December 31, 2019,2021, of which $101$87 million were classified as nonperforming and $275$55 million were loans fully insured by the FHA. For more information on loans discharged in Chapter 7 bankruptcy, see Nonperforming Loans and Leases in this Note.
Consumer real estate TDRs are measured primarily based on the net present value of the estimated cash flows discounted at the loan’s original effective interest rate. If the carrying value of a TDR exceeds this amount, a specific allowance is recorded as a component of the allowance for loan and lease losses.
Alternatively, consumer real estate TDRs that are considered to be dependent solely on the collateral for repayment (e.g., due to the lack of income verification) are measured based on the estimated fair value of the collateral and a charge-off is recorded if the carrying value exceeds the fair value of the collateral. Consumer real estate loans that reached 180 days past due prior to modification had been charged off to their net realizable value, less costs to sell, before they were modified as TDRs in accordance with established policy. Therefore, modifications of consumer real estate loans that are 180 or more days past due as TDRs do not have an impact on the allowance for loan and lease losses nor are additional charge-offs required at the time of modification. Subsequent declines in the fair value of the collateral after a loan has reached 180 days past due are recorded as charge-offs. Fully-insured loans are protected against principal loss, and therefore, the Corporation does not record an allowance for loan and lease losses on the outstanding principal balance, even after they have been modified in a TDR.insured.
At December 31, 20192021 and 2018,2020, remaining commitments to lend additional funds to debtors whose terms have been modified in a consumer real estate TDR were not significant. Consumer real estate foreclosed properties totaled $229$101 million and $244$123 million at December 31, 20192021 and 2018.2020. The carrying value of consumer real estate loans, including fully-insured loans, for which formal foreclosure proceedings were in process at December 31, 20192021 and 2020 was $1.6$1.1 billion and $1.2 billion. During 20192021 and 2018,2020, the Corporation reclassified $611$64 million and $670$182 million of consumer real estate loans, to foreclosed properties or, for properties acquired upon foreclosure of certain government-guaranteed loans (principally FHA-insured loans), to other assets. The reclassifications represent non-cash investing activities and, accordingly, are not reflected in the Consolidated Statement of Cash Flows.
The following table provides the unpaid principal balance, carrying value and related allowance at December 31, 2019 and 2018 and the average carrying value and interest income recognized in 2019, 2018 and 2017 for impaired loans in the Corporation’s Consumer Real Estate portfolio segment. Certain impaired consumer real estate loans do not have a related allowance as the current valuation of these impaired loans exceeded the carrying value, which is net of previously recorded charge-offs.

Bank of America 116


                
Impaired Loans – Consumer Real Estate  
                
     
Unpaid
Principal
Balance
 
Carrying
Value
 
Related
Allowance
 
Unpaid
Principal
Balance
 
Carrying
Value
 
Related
Allowance
(Dollars in millions)    December 31, 2019 December 31, 2018
With no recorded allowance     
  
  
  
  
  
Residential mortgage    $4,224
 $3,354
 $
 $5,396
 $4,268
 $
Home equity    1,176
 706
 
 2,948
 1,599
 
With an allowance recorded         
      
Residential mortgage    $1,426
 $1,399
 $70
 $1,977
 $1,929
 $114
Home equity    543
 523
 69
 812
 760
 144
Total     
  
  
      
Residential mortgage    $5,650
 $4,753
 $70
 $7,373
 $6,197
 $114
Home equity    1,719
 1,229
 69
 3,760
 2,359
 144
                
     Average
Carrying
Value
 
Interest
Income
Recognized
(1)
 Average
Carrying
Value
 
Interest
Income
Recognized
(1)
 Average
Carrying
Value
 
Interest
Income
Recognized
(1)
     2019 2018 2017
With no recorded allowance               
Residential mortgage    $3,831
 $155
 $5,424
 $207
 $7,737
 $311
Home equity    1,221
 76
 1,894
 105
 1,997
 109
With an allowance recorded               
Residential mortgage    $1,635
 $62
 $2,409
 $91
 $3,414
 $123
Home equity    637
 22
 861
 25
 858
 24
Total               
Residential mortgage    $5,466
 $217
 $7,833
 $298
 $11,151
 $434
Home equity    1,858
 98
 2,755
 130
 2,855
 133
(1)
Interest income recognized includes interest accrued and collected on the outstanding balances of accruing impaired loans as well as interest cash collections on nonaccruing impaired loans for which the principal is considered collectible.
The table below presents the December 31, 2019, 20182021, 2020 and 20172019 unpaid principal balance, carrying value, and average pre- and post-modification interest rates of consumer real estate loans that were modified in TDRs during 2019, 20182021, 2020 and 2017.2019. 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 2021, 2020 and 2019
Unpaid Principal BalanceCarrying
Value
Pre-Modification Interest Rate
Post-Modification Interest Rate (1)
(Dollars in millions)December 31, 2021
Residential mortgage$891 $788 3.48 %3.38 %
Home equity107 77 3.60 3.59 
Total$998 $865 3.49 3.41 
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 
(1)The post-modification interest rate reflects the interest rate applicable only to permanently completed modifications, which exclude loans that are in a trial modification period.


                
Consumer Real Estate – TDRs Entered into During 2019, 2018 and 2017
  
         Unpaid Principal Balance Carrying
Value
 Pre-Modification Interest Rate 
Post-Modification Interest Rate (1)
(Dollars in millions)  December 31, 2019
Residential mortgage        $464
 $377
 4.19% 4.13%
Home equity        141
 101
 5.04
 4.31
Total        $605
 $478
 4.39
 4.17
                
   December 31, 2018
Residential mortgage        $774
 $641
 4.33% 4.21%
Home equity        489
 358
 4.46
 3.74
Total        $1,263
 $999
 4.38
 4.03
                
   December 31, 2017
Residential mortgage        $824
 $712
 4.43% 4.16%
Home equity        764
 590
 4.22
 3.49
Total        $1,588
 $1,302
 4.33
 3.83
(1)
The post-modification interest rate reflects the interest rate applicable only to permanently completed modifications, which exclude loans that are in a trial modification period.

117121 Bank of America






The table below presents the December 31, 2019, 20182021, 2020 and 20172019 carrying value for consumer real estate loans that were modified in a TDR during 2019, 20182021, 2020 and 2017,2019, by type of modification.
Consumer Real Estate – Modification Programs
TDRs Entered into During
(Dollars in millions)202120202019
Modifications under government programs$4 $13 $35 
Modifications under proprietary programs774 570 174 
Loans discharged in Chapter 7 bankruptcy (1)
33 53 68 
Trial modifications54 79 201 
Total modifications$865 $715 $478 
      
Consumer Real Estate – Modification Programs    
      
 TDRs Entered into During
(Dollars in millions)2019 2018 2017
Modifications under government programs (1)
$35
 $61
 $85
Modifications under proprietary programs (1)
174
 523
 437
Loans discharged in Chapter 7 bankruptcy (2)
68
 130
 211
Trial modifications201
 285
 569
Total modifications$478
 $999
 $1,302
(1)(1)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. During 2018, this included $198 million of modifications that met the definition of a TDR related to the 2017 hurricanes; there were 0 such modifications in 2019 or 2017. These modifications were written down to their net realizable value less costs to sell or were fully insured as of December 31, 2018.
(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 2019, 20182021, 2020 and 20172019 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 3 monthly payments (not necessarily consecutively) since modification.
Consumer Real Estate – TDRs Entering Payment Default that were Modified During the Preceding 12 Months
(Dollars in millions)202120202019
Modifications under government programs$4 $16 $26 
Modifications under proprietary programs128 51 88 
Loans discharged in Chapter 7 bankruptcy (1)
9 19 30 
Trial modifications (2)
19 54 57 
Total modifications$160 $140 $201 
        
Consumer Real Estate – TDRs Entering Payment Default that were Modified During the Preceding 12 Months
        
(Dollars in millions)  2019 2018 2017
Modifications under government programs  $26
 $39
 $81
Modifications under proprietary programs  88
 158
 138
Loans discharged in Chapter 7 bankruptcy (1)
  30
 64
 116
Trial modifications (2)
  57
 107
 391
Total modifications  $201
 $368
 $726
(1)Includes loans discharged in Chapter 7 bankruptcy with no change in repayment terms that are classified as TDRs.
(2)Includes trial modification offers to which the customer did not respond.
(1)
Includes loans discharged in Chapter 7 bankruptcy with no change in repayment terms that are classified as TDRs.
(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 thatwho are experiencing financial difficulty by modifying loans while ensuring compliance with federal and local laws and guidelines. Credit card and other consumer loan modifications generally involve reducing the interest rate on the account, placing the customer on a fixed payment plan not exceeding 60 months and canceling the customer’s available line of credit, all of which are considered TDRs. The Corporation makes loan modifications directly with borrowers for debt held only by the Corporation (internal programs). Additionally, the Corporation makes loan modifications for borrowers working with third-party renegotiation
agencies that
provide solutions to customers’ entire unsecured debt structures (external programs). The Corporation classifies other secured consumer loans that have been discharged in Chapter 7 bankruptcy as TDRs, which are written down to collateral value and placed on nonaccrual status no later than the time of discharge. For more information on the regulatory guidance on loans discharged in Chapter 7 bankruptcy, see Nonperforming Loans and Leases in this Note.
The following table provides the unpaid principal balance, carrying value and related allowance at December 31, 2019 and 2018 and the average carrying value for 2019, 2018 and 2017 on TDRs within the Credit Card and Other Consumer portfolio segment.
                   
Impaired Loans – Credit Card and Other Consumer        
                   
  
Unpaid
Principal
Balance
 
Carrying
Value (1)
 
Related
Allowance
 
Unpaid
Principal
Balance
 
Carrying
Value (1)
 
Related
Allowance
  
   
Average Carrying Value (2)
(Dollars in millions) December 31, 2019 December 31, 2018 2019 2018 2017
With no recorded allowance  
  
  
            
Direct/Indirect consumer $73
 $32
 $
 $72
 $33
 $
 $33
 $30
 $21
With an allowance recorded  
  
  
          
  
Credit card (3)
 $633
 $647
 $188
 $522
 $533
 $154
 $594
 $491
 $511
(1)
Includes accrued interest and fees.
(2)
The related interest income recognized, which includes interest accrued and collected on the outstanding balances of accruing impaired loans as well as interest cash collections on nonaccruing impaired loans for which the principal was considered collectible, was not significant in 2019, 2018 and 2017.
(3)
The average carrying value in 2017 includes $47 million related to the non-U.S. credit card portfolio, which was sold in the second quarter of 2017.

Bank of America 118


The table below provides information on the Corporation’s primary modification programs for the Credit Card and Other Consumer TDR portfolio at December 31, 2019 and 2018.
            
Credit Card and Other Consumer – TDRs by Program Type at December 31
      
 Credit Card Direct/Indirect Consumer Total TDRs by Program Type
(Dollars in millions)2019 2018 2019 2018 2019 2018
Internal programs$339
 $259
 $
 $
 $339
 $259
External programs308
 273
 
 
 308
 273
Other
 1
 32
 33
 32
 34
Total$647
 $533
 $32
 $33
 $679
 $566
Percent of balances current or less than 30 days past due85% 85% 78% 81% 84% 85%

The table below provides information on the Corporation’s Credit Card and Other Consumer TDR portfolio including the December 31, 2019, 20182021, 2020 and 20172019 unpaid principal balance, carrying value, and average pre- and post-modification interest rates of loans that were modified in TDRs during 2019, 20182021, 2020 and 2017.2019.
Credit Card and Other Consumer – TDRs Entered into During 2021, 2020 and 2019
 Unpaid Principal Balance
Carrying
Value
(1)
Pre-Modification Interest RatePost-Modification Interest Rate
(Dollars in millions)December 31, 2021
Credit card$237 $248 18.45 %4.09 %
Direct/Indirect consumer23 16 5.88 5.88 
Total$260 $264 17.68 4.20 
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 
(1)Includes accrued interest and fees.

                
Credit Card and Other Consumer – TDRs Entered into During 2019, 2018 and 2017
                
         Unpaid Principal Balance 
Carrying
Value (1)
 Pre-Modification Interest Rate Post-Modification Interest Rate
(Dollars in millions)  December 31, 2019
Credit card        $340
 $355
 19.18% 5.35%
Direct/Indirect consumer        40
 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 consumer        42
 23
 5.10
 4.95
Total        $320
 $315
 18.45
 5.22
                
         December 31, 2017
Credit card

        $203
 $213
 18.47% 5.32%
Non-U.S. credit card        37
 22
 4.81
 4.30
Total        $240
 $235
 17.17
 5.22
(1)Bank of America 122
Includes accrued interest and fees.


The table below presents the December 31, 2021, 2020 and 2019 carrying value for Credit Card and Other Consumer loans that were modified in a TDR during 2021, 2020 and 2019, by program type.
Credit Card and Other Consumer – TDRs by Program Type at December 31 (1)
(Dollars in millions)202120202019
Internal programs$214 $225 $247 
External programs44 73 108 
Other6 16 21 
Total$264 $314 $376 
(1) Includes accrued interest and fees.
Credit card and other consumer loans are deemed to be in payment default during the quarter in which a borrower misses the second of 2 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 1410 percent of new credit card TDRs and 2018 percent of new direct/indirect consumer TDRs may be in payment default within 12 months after modification.
Commercial Loans
Impaired commercial loans include nonperforming loans and TDRs (both performing and nonperforming). Modifications of loans to commercial borrowers that are experiencing financial difficulty are designed to reduce the Corporation’s loss exposure while providing the borrower with an opportunity to work through financial difficulties, often to avoid foreclosure or bankruptcy. Each modification is unique and reflects the individual circumstances of the borrower. Modifications that result in a TDR may include extensions of maturity at a concessionary (below market) rate of interest, payment forbearances or other actions designed to benefit the 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
During 2021, the carrying value of the Corporation’s commercial loans that were modified as TDRs was $1.3 billion compared to $1.2 billion and $1.7 billion for the U.S. small business commercial portfolio, see Credit Card2020 and Other Consumer in this Note.2019. At
At
December 31, 2021, 2020 and 2019, and 2018, remainingthe Corporation had commitments to lend additional funds to debtors whose terms have been modified in a commercial loan TDR were$283 million, $402 million and $445 million and $297 million.to commercial borrowers whose loans were classified as TDRs. The balance of commercial TDRs in payment default was not significant$262 million, $218 million and $207 million at December 31, 20192021, 2020 and 2018.2019.
The table below provides information on impaired loans in the Commercial loan portfolio segment including the unpaid principal balance, carrying value and related allowance at December 31, 2019 and 2018, and the average carrying value for 2019, 2018 and 2017. Certain impaired commercial loans do not have a related allowance because the valuation of these impaired loans exceeded the carrying value, which is net of previously recorded charge-offs.

119Bank of America






                    
Impaired Loans – Commercial        
                    
   
Unpaid
Principal
Balance
 
Carrying
Value
 
Related
Allowance
 
Unpaid
Principal
Balance
 
Carrying
Value
 
Related
Allowance
    
         
Average Carrying Value (1)
(Dollars in millions)  December 31, 2019 December 31, 2018 2019 2018 2017
With no recorded allowance   
  
  
  
  
        
U.S. commercial  $534
 $520
 $
 $638
 $616
 $
 $635
 $655
 $772
Non-U.S. commercial  123
 123
 
 93
 93
 
 79
 43
 46
Commercial real estate  67
 58
 
 
 
 
 96
 44
 69
Commercial lease financing  12
 12
 
 
 
 
 5
 3
 
With an allowance recorded             
      
U.S. commercial  $1,776
 $1,574
 $216
 $1,437
 $1,270
 $121
 $1,316
 $1,162
 $1,260
Non-U.S. commercial  113
 113
 9
 155
 149
 30
 218
 327
 463
Commercial real estate  322
 236
 64
 247
 162
 16
 149
 46
 73
Commercial lease financing  57
 51
 1
 71
 71
 
 73
 42
 8
U.S. small business commercial (2)
 91
 77
 30
 83
 72
 29
 75
 73
 73
Total   
  
  
            
U.S. commercial  $2,310
 $2,094
 $216
 $2,075
 $1,886
 $121
 $1,951
 $1,817
 $2,032
Non-U.S. commercial  236
 236
 9
 248
 242
 30
 297
 370
 509
Commercial real estate  389
 294
 64
 247
 162
 16
 245
 90
 142
Commercial lease financing  69
 63
 1
 71
 71
 
 78
 45
 8
U.S. small business commercial (2)
 91
 77
 30
 83
 72
 29
 75
 73
 73

(1)
The related interest income recognized, which includes interest accrued and collected on the outstanding balances of accruing impaired loans as well as interest cash collections on nonaccruing impaired loans for which the principal was considered collectible, was not significant in 2019, 2018 and 2017.
(2)
Includes U.S. small business commercial renegotiated TDR loans and related allowance.
Loans Held-for-sale
The Corporation had LHFS of $9.2$15.6 billion and $10.4$9.2 billion at December 31, 20192021 and 2018.2020. Cash and non-cash proceeds from sales and paydowns of loans originally classified as LHFS were $43.6 billion, $20.1 billion and $30.6 billion $29.2 billionfor 2021, 2020 and $41.3 billion for 2019, 2018 and 2017, respectively. Cash used for originations and purchases of LHFS totaled $37.3 billion, $19.7 billion and $28.9 billion $28.1for 2021, 2020 and 2019, respectively.
Accrued Interest Receivable
Accrued interest receivable for loans and leases and loans held-for-sale at December 31, 2021 and 2020 was $2.2 billion and $43.5$2.4 billion for 2019, 2018 and 2017, respectively.
is reported in customer and other receivables on the Consolidated Balance Sheet.
NOTE 6 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 2021 and 2020, the Corporation reversed $446 million and $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 2021 and 2020, interest and fee income reversed at the time the loans were classified as nonperforming was not significant. For more information on the Corporation's nonperforming loan policies, see Note 1 – Summary of Significant Accounting Principles.
123 Bank of America


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 table below summarizesallowance 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.
The December 31, 2021 estimate for allowance for credit losses was based on various economic outlooks that included a baseline scenario, which is derived from consensus estimates, a downside scenario that assumed a significantly longer period until full economic recovery, a tail risk scenario similar to the severely adverse scenario used in stress testing, a scenario to account for inflationary risk and higher interest rates and an upside scenario to consider the potential for improvement in the consensus outlooks. The weighted economic outlook assumes that the U.S. average unemployment rate will be just above 5 percent by the fourth quarter of 2022 and slowly declines to just under 5 percent by the fourth quarter of 2023. Additionally, in
this economic outlook, U.S. gross domestic product is forecasted to grow at 2.1 percent and 1.9 percent year-over-year in the fourth quarters of 2022 and 2023. For comparison, as of December 31, 2020, the weighted macroeconomic outlook for the U.S. average unemployment rate was forecasted at 6.6 percent, 5.5 percent and 5.0 percent in the fourth quarters of 2021, 2022 and 2023, respectively, and the weighted macroeconomic outlook for U.S. GDP was forecasted to grow at 2.5 percent, 2.4 percent and 2.1 percent year-over-year in the fourth quarters of 2021, 2022 and 2023, respectively. The allowance for credit losses considered the impact of enacted government stimulus measures and continued to factor in the uncertainty resulting from the unprecedented nature of the current public health crisis and risks that may prevent a full economic recovery.
While there has been improvement across the U.S. economy, the Corporation continues to factor 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 the pandemic.
The allowance for credit losses at December 31, 2021 was $13.8 billion, a decrease of $6.8 billion compared to December 31, 2020. The decrease in the allowance for credit losses was primarily driven by improvements in the macroeconomic outlook and credit quality. The change in the allowance for credit losses was comprised of a net decrease of $6.4 billion in the allowance for loan and lease losses and a $422 million decrease in the reserve for unfunded lending commitments. The decrease in the allowance for credit losses was attributed to $342 million in the consumer real estate portfolio, $2.7 billion in the credit card and other consumer portfolio, and $3.8 billion in the commercial portfolio. Similarly, the provision for credit losses improved $15.9 billion to a benefit of $4.6 billion in 2021 compared to provision expense of $11.3 billion and $3.6 billion in 2020 and 2019. The benefit in 2021 was primarily driven by improvements in the macroeconomic outlook and credit quality.
Outstanding loans and leases excluding loans accounted for under the fair value option increased $50.1 billion in 2021 driven by commercial loans, which increased $60.4 billion, excluding small business, primarily driven by Global Markets. Consumer loans increased $7.0 billion primarily driven by securities-based lending, partially offset by lower consumer real estate due to prepayments in a low rate environment.
The changes in the allowance for credit losses, by portfolio segmentincluding net charge-offs and provision for 2019, 2018loan and 2017.lease losses, are detailed in the following table.
        
 Consumer
Real Estate
 Credit Card and Other Consumer Commercial Total
(Dollars in millions)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) 1
 (5) (111)
Allowance for loan and lease losses, December 31546
 3,996
 4,874
 9,416
Reserve for unfunded lending commitments, January 1
 
 797
 797
Provision for unfunded lending commitments
 
 16
 16
Reserve for unfunded lending commitments, December 31
 
 813
 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 1
 
 777
 777
Provision for unfunded lending commitments
 
 20
 20
Reserve for unfunded lending commitments, December 31
 
 797
 797
Allowance for credit losses, December 31$928
 $3,874
 $5,596
 $10,398
        
 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(113) (2,965) (901) (3,979)
Provision for loan and lease losses(710) 3,437
 654
 3,381
Other (1)
(207) (38) (1) (246)
Allowance for loan and lease losses, December 311,720
 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

(1)
Primarily represents write-offs of purchased credit-impaired loans, the net impact of portfolio sales, and transfers to LHFS.

Bank of America 120124


The table below presents the allowance and the carrying value of outstanding loans and leases by portfolio segment at December 31, 2019 and 2018.
        
 Consumer
Real Estate
 Credit Card and Other Consumer Commercial Total
(Dollars in millions)December 31, 2019
Impaired loans and troubled debt restructurings (1)
 
  
  
  
Allowance for loan and lease losses$139
 $188
 $320
 $647
Carrying value (2)
5,982
 679
 2,764
 9,425
Allowance as a percentage of carrying value2.32% 27.69% 11.58% 6.86%
Loans collectively evaluated for impairment 
  
  
  
Allowance for loan and lease losses$407
 $3,808
 $4,554
 $8,769
Carrying value (2, 3)
270,395
 188,119
 507,152
 965,666
Allowance as a percentage of carrying value (3)
0.15% 2.02% 0.90% 0.91%
Total 
  
  
  
Allowance for loan and lease losses$546
 $3,996
 $4,874
 $9,416
Carrying value (2, 3)
276,377
 188,798
 509,916
 975,091
Allowance as a percentage of carrying value (3)
0.20% 2.12% 0.96% 0.97%
        
 December 31, 2018
Impaired loans and troubled debt restructurings (1)
 
  
  
  
Allowance for loan and lease losses$258
 $154
 $196
 $608
Carrying value (2)
8,556
 566
 2,433
 11,555
Allowance as a percentage of carrying value3.02% 27.21% 8.06% 5.26%
Loans collectively evaluated for impairment 
  
  
  
Allowance for loan and lease losses$670
 $3,720
 $4,603
 $8,993
Carrying value (2, 3)
248,287
 189,140
 493,564
 930,991
Allowance as a percentage of carrying value (3)
0.27% 1.97% 0.93% 0.97%
Total 
  
  
  
Allowance for loan and lease losses$928
 $3,874
 $4,799
 $9,601
Carrying value (2, 3)
256,843
 189,706
 495,997
 942,546
Allowance as a percentage of carrying value (3)
0.36% 2.04% 0.97% 1.02%

Consumer
Real Estate
Credit Card and
 Other Consumer
CommercialTotal
(Dollars in millions)2021
Allowance for loan and lease losses, January 1$858 $9,213 $8,731 $18,802 
Loans and leases charged off(78)(3,000)(719)(3,797)
Recoveries of loans and leases previously charged off225 1,006 323 1,554 
Net charge-offs147 (1,994)(396)(2,243)
Provision for loan and lease losses(449)(744)(2,980)(4,173)
Other1 1 (1)1 
Allowance for loan and lease losses, December 31557 6,476 5,354 12,387 
Reserve for unfunded lending commitments, January 1137  1,741 1,878 
Provision for unfunded lending commitments(41) (380)(421)
Other  (1)(1)
Reserve for unfunded lending commitments, December 3196  1,360 1,456 
Allowance for credit losses, December 31$653 $6,476 $6,714 $13,843 
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— (8)— 
Allowance for loan and lease losses, December 31858 9,213 8,731 18,802 
Reserve for unfunded lending commitments, January 1119 — 1,004 1,123 
Provision for unfunded lending commitments18 — 737 755 
Reserve for unfunded lending commitments, December 31137 — 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 1— — 797 797 
Provision for unfunded lending commitments— — 16 16 
Reserve for unfunded lending commitments, December 31— — 813 813 
Allowance for credit losses, December 31$546 $3,996 $5,687 $10,229 
(1)Primarily represents write-offs of purchased credit-impaired loans in 2019.

(1)
Impaired loans include nonperforming commercial loans and leases, as well as all TDRs, including both commercial and consumer TDRs. Impaired loans exclude nonperforming consumer loans unless they are TDRs, and all consumer and commercial loans accounted for under the fair value option.
(2)
Amounts are presented gross of the allowance for loan and lease losses.
(3)
Outstanding loan and lease balances and ratios do not include loans accounted for under the fair value option of $8.3 billion and $4.3 billion at December 31, 2019 and 2018.
NOTE 76 Securitizations and Other Variable Interest Entities
The Corporation utilizes VIEs in the ordinary course of business to support its own and its customers’ financing and investing needs. The Corporation routinely securitizes loans and debt securities using VIEs as a source of funding for the Corporation and as a means of transferring the economic risk of the loans or debt securities to third parties. The assets are transferred into a trust or other securitization vehicle such that the assets are legally isolated from the creditors of the Corporation and are not available to satisfy its obligations. These assets can only be used to settle obligations of the trust or other securitization vehicle. The Corporation also administers, structures or invests in other VIEs including CDOs, investment vehicles and other entities. For more information on the Corporation’s use of VIEs, see Note 1 – Summary of Significant Accounting Principles.
The tables in this Note present the assets and liabilities of consolidated and unconsolidated VIEs at December 31, 20192021 and 20182020 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, 20192021 and 20182020 resulting from its involvement with consolidated VIEs and unconsolidated VIEs in which the Corporation holds a variable interest. The Corporation’s
maximum loss exposure is based on the unlikely event that all of the assets in the VIEs become worthless and incorporates not only potential losses associated with assets recorded on the Consolidated Balance Sheet but also potential losses associated with off-balance sheet commitments, such as unfunded liquidity commitments and other contractual
arrangements. The Corporation’s maximum loss exposure does not include losses previously recognized through write-downs of assets.
The Corporation invests in ABS issued by third-party VIEs with which it has no other form of involvement and enters into certain commercial lending arrangements that may also incorporate the use of VIEs, for example to hold collateral. These securities and loans are included in Note 4 – Securities or Note 5 – Outstanding Loans and Leases.Leases and Allowance for Credit Losses. In addition, the Corporation has used VIEs in connection with its funding activities.
The Corporation did not provide financial support to consolidated or unconsolidated VIEs during 2019, 20182021, 2020 and 20172019 that it was not previously contractually required to provide, nor does it intend to do so.
The Corporation had liquidity commitments, including written put options and collateral value guarantees, with certain unconsolidated VIEs of $1.1 billion$968 million and $218$929 million at December 31, 20192021 and 2018.2020.
125 Bank of America


First-lien Mortgage Securitizations
As part of its mortgage banking activities, the Corporation securitizes a portion of the first-lien residential mortgage loans it originates or purchases from third parties, generally in the form of RMBSresidential mortgage-backed securities (RMBS) guaranteed by GSEs,government-sponsored enterprises, FNMA and FHLMC (collectively the GSEs), or the Government National Mortgage Association (GNMA) primarily in the case of FHA-insured and U.S. Department of Veterans Affairs (VA)-guaranteed mortgage loans. Securitization usually occurs in conjunction with or shortly after origination or purchase, and the Corporation may also securitize loans held in its residential
mortgage portfolio. In addition, the Corporation may, from time to time, securitize commercial mortgages it originates

121Bank of America






or purchases from other entities. The Corporation typically services the loans it securitizes. Further, the Corporation may retain beneficial interests in the securitization trusts including senior and subordinate securities and equity tranches issued by the trusts. Except as described in Note 1312 – Commitments and Contingencies,
the Corporation does not provide guarantees or recourse to the securitization trusts other than standard representations and warranties.
The table below summarizes select information related to first-lien mortgage securitizations for 2019, 20182021, 2020 and 2017.2019.
First-lien Mortgage Securitizations
 
Residential Mortgage - AgencyCommercial Mortgage
(Dollars in millions)202120202019202120202019
Proceeds from loan sales (1)
$6,664 $15,823 $6,858 $10,874 $5,084 $8,661 
Gains on securitizations (2)
9 728 27 156 61 103 
Repurchases from securitization trusts (3)
756 436 881  — — 
            
First-lien Mortgage Securitizations           
            
 Residential Mortgage - Agency Commercial Mortgage
(Dollars in millions)2019 2018 2017 2019 2018 2017
Proceeds from loan sales (1)
$6,858
 $5,801
 $16,161
 $8,661
 $6,991
 $5,887
Gains on securitizations (2)
27
 62
 158
 103
 101
 91
Repurchases from securitization trusts (3)
881
 1,485
 2,713
 
 
 
(1)The Corporation transfers residential mortgage loans to securitizations sponsored primarily by the GSEs or GNMA in the normal course of business and primarily receives RMBS in exchange. Substantially all of these securities are classified as Level 2 within the fair value hierarchy and are typically sold shortly after receipt.
(1)
(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 $121 million, $160 million and $64 million net of hedges, during 2021, 2020 and 2019, respectively, are not included in the table above.
(3)The Corporation may have the option to repurchase delinquent loans out of securitization trusts, which reduces the amount of servicing advances it is required to make. The Corporation may also repurchase loans from securitization trusts to perform modifications. Repurchased loans include FHA-insured mortgages collateralizing GNMA securities.
The Corporation transfers residential mortgage loans to securitizations sponsored primarily by the GSEs or GNMA in the normal course of business and primarily receives RMBS in exchange. Substantially all of these securities are classified as Level 2 within the fair value hierarchy and are sold shortly after receipt.
(2)
A majority of the first-lien residential mortgage loans securitized are initially classified as LHFS and accounted for under the fair value option. Gains recognized on these LHFS prior to securitization, which totaled $64 million, $71 million and $243 million, net of hedges, during 2019, 2018 and 2017, respectively, are not included in the table above.
(3)
The Corporation may have the option to repurchase delinquent loans out of securitization trusts, which reduces the amount of servicing advances it is required to make. The Corporation may also repurchase loans from securitization trusts to perform modifications. Repurchased loans include FHA-insured mortgages collateralizing GNMA securities.
The Corporation recognizes consumer MSRs from the sale or securitization of consumer real estate loans. The unpaid principal balance of loans serviced for investors, including residential mortgage and home equity loans, totaled $192.1$115.4 billion and $226.6$160.4 billion at December 31, 20192021 and 2018.2020. Servicing fee and ancillary fee income on serviced loans was $392 million, $474 million and $585 million $710 millionduring 2021, 2020 and $893 million during 2019, 2018 and 2017.respectively. Servicing advances on serviced loans, including loans serviced for others and loans held for investment, were $2.4$2.0 billion and $3.3$2.2 billion
at December 31, 20192021 and 2018.2020. For more information on MSRs, see Note 2120 – Fair Value Measurements.

During 2019,2020, the Corporation deconsolidated agency residential mortgage securitization trusts with total assetscompleted the sale of $1.2 billion. There$9.3 billion of consumer real estate loans through GNMA loan securitizations. As part of the securitizations, the Corporation retained $8.4 billion of MBS, which are classified as debt securities carried at fair value on the Consolidated Balance Sheet. Total gains on loan sales of $704 million were no significant deconsolidationsrecorded in 2018 or 2017.other income in the Consolidated Statement of Income.
The following table summarizes select information related to first-lien mortgage securitization trusts in which the Corporation held a variable interest at December 31, 20192021 and 2018.2020.
               
First-lien Mortgage VIEs           
     
 Residential Mortgage  
 
  
 
 Non-agency  
 
 Agency Prime Subprime Alt-A Commercial Mortgage
 December 31
(Dollars in millions)20192018 20192018 20192018 20192018 20192018
Unconsolidated VIEs 
 
  
 
  
 
  
 
  
 
Maximum loss exposure (1)
$12,554
$16,011
 $340
$448
 $1,622
$1,897
 $98
$217
 $1,036
$767
On-balance sheet assets 
 
  
 
  
 
  
 
  
 
Senior securities: 
 
  
 
  
 
  
 
  
 
Trading account assets$627
$460
 $5
$30
 $54
$36
 $24
$90
 $65
$97
Debt securities carried at fair value6,392
9,381
 193
246
 1,178
1,470
 72
125
 

Held-to-maturity securities5,535
6,170
 

 

 

 809
528
All other assets

 2
3
 49
37
 2
2
 38
40
Total retained positions$12,554
$16,011
 $200
$279
 $1,281
$1,543
 $98
$217
 $912
$665
Principal balance outstanding (2)
$160,226
$187,512
 $7,268
$8,954
 $8,594
$8,719
 $19,878
$23,467
 $60,129
$43,593
               
Consolidated VIEs 
 
  
 
  
 
  
 
  
 
Maximum loss exposure (1)
$10,857
$13,296
 $5
$7
 $44
$
 $
$
 $
$76
On-balance sheet assets 
 
  
 
  
 
  
 
  
 
Trading account assets$780
$1,318
 $116
$150
 $149
$
 $
$
 $
$76
Loans and leases, net9,917
11,858
 

 

 

 

All other assets161
143
 

 

 

 

Total assets$10,858
$13,319
 $116
$150
 $149
$
 $
$
 $
$76
Total liabilities$4
$26
 $111
$143
 $105
$
 $
$
 $
$
(1)
Maximum loss exposure includes obligations under loss-sharing reinsurance and other arrangements for non-agency residential mortgage and commercial mortgage securitizations, but excludes the reserve for representations and warranties obligations and corporate guarantees and also excludes servicing advances and other servicing rights and obligations. For more information, see Note 13 – Commitments and Contingencies and Note 21 – Fair Value Measurements.
(2)
Principal balance outstanding includes loans where the Corporation was the transferor to securitization VIEs with which it has continuing involvement, which may include servicing the loans.

Bank of America 122126


First-lien Mortgage VIEs
Residential Mortgage  
   Non-agency  
 AgencyPrimeSubprimeAlt-ACommercial Mortgage
 December 31
(Dollars in millions)2021202020212020202120202021202020212020
Unconsolidated VIEs          
Maximum loss exposure (1)
$11,600 $13,477 $121 $250 $908 $1,031 $14 $46 $1,445 $1,169 
On-balance sheet assets          
Senior securities:          
Trading account assets$175 $152 $8 $$44 $$12 $12 $21 $60 
Debt securities carried at fair value5,009 7,588  103 537 676  33  — 
Held-to-maturity securities6,416 5,737  —  —  — 1,157 925 
All other assets — 3 29 26 2 93 50 
Total retained positions$11,600 $13,477 $11 $111 $610 $710 $14 $46 $1,271 $1,035 
Principal balance outstanding (2)
$93,142 $133,497 $4,710 $6,081 $6,179 $6,691 $13,627 $16,554 $85,540 $59,268 
Consolidated VIEs          
Maximum loss exposure (1)
$1,644 $1,328 $49 $66 $ $53 $ $— $ $— 
On-balance sheet assets          
Trading account assets$1,644 $1,328 $ $350 $ $260 $ $— $ $— 
Loans and leases, net — 58 —  —  —  — 
Total assets$1,644 $1,328 $58 $350 $ $260 $ $— $ $— 
Total liabilities$ $— $9 $284 $ $207 $ $— $ $— 
(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, credit card and other asset-backed VIEs in which the Corporation held a variable interest at December 31, 20192021 and 2018.2020.
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)20212020202120202021202020212020
Unconsolidated VIEs      
Maximum loss exposure$152 $206 $ $— $6,089 $8,543 $4,094 $3,507 
On-balance sheet assets      
Securities (3):
      
Trading account assets$ $— $ $— $1,030 $948 $ $— 
Debt securities carried at fair value1  — 1,903 2,727  — 
Held-to-maturity securities —  — 3,156 4,868  — 
Total retained positions$1 $$ $— $6,089 $8,543 $ $— 
Total assets of VIEs$430 $609 $ $— $18,633 $17,250 $4,655 $4,042 
Consolidated VIEs      
Maximum loss exposure$45 $58 $10,279 $14,606 $680 $217 $210 $1,030 
On-balance sheet assets      
Trading account assets$ $— $ $— $686 $217 $122 $990 
Loans and leases140 218 14,434 21,310  —  — 
Allowance for loan and lease losses14 14 (970)(1,704) —  — 
All other assets3 70 1,289  — 88 40 
Total assets$157 $236 $13,534 $20,895 $686 $217 $210 $1,030 
On-balance sheet liabilities      
Short-term borrowings$ $— $ $— $ $— $196 $432 
Long-term debt113 178 3,248 6,273 6 —  — 
All other liabilities — 7 16  —  — 
Total liabilities$113 $178 $3,255 $6,289 $6 $— $196 $432 
(1)For unconsolidated home equity loan VIEs, the maximum loss exposure includes outstanding trust certificates issued by trusts in rapid amortization, net of recorded reserves. For both consolidated and unconsolidated home equity loan VIEs, the maximum loss exposure excludes the reserve for representations and warranties obligations and corporate guarantees. For more information, see Note 12 – Commitments and Contingencies.
(2)At December 31, 2021 and 2020, loans and leases in the consolidated credit card trust included $4.3 billion and $7.6 billion of seller’s interest.
(3)The retained senior securities were valued using quoted market prices or observable market inputs (Level 2 of the fair value hierarchy).

            
Home Equity Loan, Credit Card and Other Asset-backed VIEs    
         
 
Home Equity (1)
 
Credit Card (2, 3)
 Resecuritization Trusts Municipal Bond Trusts
 December 31
(Dollars in millions)20192018 20192018 20192018 20192018
Unconsolidated VIEs 
 
     
 
  
 
Maximum loss exposure$412
$908
 $
$
 $7,526
$7,647
 $3,701
$2,150
On-balance sheet assets 
 
     
 
  
 
Senior securities (4):
 
 
     
 
  
 
Trading account assets$
$
 $
$
 $2,188
$1,419
 $
$26
Debt securities carried at fair value11
27
 

 1,126
1,337
 

Held-to-maturity securities

 

 4,212
4,891
 

Total retained positions$11
$27
 $
$
 $7,526
$7,647
 $
$26
Total assets of VIEs (5)
$1,023
$1,813
 $
$
 $21,234
$16,949
 $4,395
$2,829
            
Consolidated VIEs 
 
     
 
  
 
Maximum loss exposure$64
$85
 $17,915
$18,800
 $54
$128
 $2,656
$1,540
On-balance sheet assets 
 
     
 
  
 
Trading account assets$
$
 $
$
 $73
$366
 $2,480
$1,553
Loans and leases122
133
 26,985
29,906
 

 

Allowance for loan and lease losses(2)(5) (800)(901) 

 

All other assets3
4
 119
136
 

 176
1
Total assets$123
$132
 $26,304
$29,141
 $73
$366
 $2,656
$1,554
On-balance sheet liabilities 
 
     
 
  
 
Short-term borrowings$
$
 $
$
 $
$
 $2,175
$742
Long-term debt64
55
 8,372
10,321
 19
238
 
12
All other liabilities

 17
20
 

 

Total liabilities$64
$55
 $8,389
$10,341
 $19
$238
 $2,175
$754
(1)127 Bank of America
For unconsolidated home equity loan VIEs, the maximum loss exposure includes outstanding trust certificates issued by trusts in rapid amortization, net of recorded reserves. For both consolidated and unconsolidated home equity loan VIEs, the maximum loss exposure excludes the reserve for representations and warranties obligations and corporate guarantees. For more information, see Note 13 – Commitments and Contingencies.
(2)


At December 31, 2019 and 2018, loans and leases in the consolidated credit card trust included $10.5 billion and $11.0 billion of seller’s interest.
(3)
At December 31, 2019 and 2018, all other assets in the consolidated credit card trust included unbilled accrued interest and fees.
(4)
The retained senior securities were valued using quoted market prices or observable market inputs (Level 2 of the fair value hierarchy).
(5)
Total assets of VIEs includes loans the Corporation transferred with which it has continuing involvement, which may include servicing the loan.
Home Equity Loans
The Corporation retains interests, primarily senior securities, in home equity securitization trusts to which it transferred home equity loans. In addition, the Corporation may be obligated to provide subordinate funding to the trusts during a rapid amortization event. This obligation is included in the maximum loss exposure in the table above. The charges that will ultimately be recorded as a result of the rapid amortization events depend on the undrawn portion of the home equity lines of credit, (HELOCs), performance of the loans, the amount of subsequent draws and the timing of related cash flows.
Credit Card Securitizations
The Corporation securitizes originated and purchased credit card loans. The Corporation’s continuing involvement with the securitization trust includes servicing the receivables, retaining an undivided interest (seller’s interest) in the receivables, and holding certain retained interests, including subordinate interests in accrued interest and fees on the securitized receivables.receivables and cash reserve accounts.
During 2021, 2020 and 2019, 2018 and 2017,the Corporation issued new senior debt securities issued to third-party investors from the credit card securitization trust were $1.3of $1.0 billion, $4.0$1.0 billion and $3.1$1.3 billion, respectively.
At December 31, 20192021 and 2018,2020, the Corporation held subordinate securities issued by the credit card securitization trust with a notional principal amount of $7.4$6.5 billion and $7.7$6.8 billion. These securities serve as a form of credit enhancement to the senior debt securities and have a stated interest rate of 0zero percent. During 2019, 20182021, 2020 and 2017,2019, the credit card securitization trust issued $202$161 million, $650$161 million and $500$202 million, respectively, of these subordinate securities.
Resecuritization Trusts
The Corporation transfers securities, typically MBS, into resecuritization VIEs generally at the request of customers seeking securities with specific characteristics. Generally, there are no significant ongoing activities performed in a resecuritization trust, and no single investor has the unilateral ability to liquidate the trust.
The Corporation resecuritized $24.4$28.9 billion, $22.8$39.0 billion and $25.1$24.4 billion of securities during 2019, 20182021, 2020 and 2017,2019, respectively. Securities transferred into resecuritization VIEs were measured at fair value with changes in fair value recorded in market making and similar activities prior to the resecuritization and, accordingly, no gain or loss on sale was recorded. During 2019, 2018 and 2017,Securities received from the resecuritization proceeds included securities with an initialVIEs were recognized at their fair value of $2.2 billion, $6.1 billion and $5.2 billion $4.1during 2021, 2020 and 2019, respectively. In 2021 and 2019, substantially all of the securities were classified as trading account assets. All of the securities received as resecuritization proceeds during 2020 were classified as trading account assets. Of the securities received as resecuritization proceeds during 2020, $2.4 billion, $2.1 billion and $3.3$1.7 billion were classified as trading account assets, debt securities carried at fair value and HTM securities, respectively. Substantially all of the othertrading account securities received as resecuritization proceeds were classified as trading securities andcarried at fair value were categorized as Level 2 within the fair value hierarchy.
Municipal Bond Trusts
The Corporation administers municipal bond trusts that hold highly-rated, long-term, fixed-rate municipal bonds. The trusts obtain financing by issuing floating-rate trust certificates that reprice on a weekly or other short-term basis to third-party investors.
The Corporation’s liquidity commitments to unconsolidated municipal bond trusts, including those for which the Corporation was transferor, totaled $3.7$4.1 billion and $2.1$3.5 billion at December 31, 20192021 and 2018.2020. The weighted-average remaining life of bonds held in the trusts at December 31, 20192021 was 10.0 years.6.3 years. There were no significant write-downs or downgrades of assets or issuers during 2019, 20182021, 2020 and 2017.

123Bank of America






2019.
Other Variable Interest Entities
The table below summarizes select information related to other VIEs in which the Corporation held a variable interest at December 31, 20192021 and 2018.2020.
Other VIEs
ConsolidatedUnconsolidatedTotalConsolidatedUnconsolidatedTotal
(Dollars in millions)December 31, 2021December 31, 2020
Maximum loss exposure$4,819 $27,790 $32,609 $4,106 $23,870 $27,976 
On-balance sheet assets      
Trading account assets$2,552 $626 $3,178 $2,080 $623 $2,703 
Debt securities carried at fair value 7 7 — 
Loans and leases2,503 47 2,550 2,108 184 2,292 
Allowance for loan and lease losses(2)(12)(14)(3)(3)(6)
All other assets28 26,628 26,656 54 22,553 22,607 
Total$5,081 $27,296 $32,377 $4,239 $23,366 $27,605 
On-balance sheet liabilities      
Short-term borrowings$51 $ $51 $22 $— $22 
Long-term debt211  211 111 — 111 
All other liabilities 6,548 6,548 — 5,658 5,658 
Total$262 $6,548 $6,810 $133 $5,658 $5,791 
Total assets of VIEs$5,081 $92,249 $97,330 $4,239 $77,984 $82,223 
            
Other VIEs        
    
 Consolidated Unconsolidated Total Consolidated Unconsolidated Total
 December 31
(Dollars in millions)2019 2018
Maximum loss exposure$4,055
 $26,326
 $30,381
 $4,177
 $24,498
 $28,675
On-balance sheet assets 
  
  
  
  
  
Trading account assets$2,213
 $549
 $2,762
 $2,335
 $860
 $3,195
Debt securities carried at fair value
 74
 74
 
 84
 84
Loans and leases1,810
 3,214
 5,024
 1,949
 3,940
 5,889
Allowance for loan and lease losses(2) (38) (40) (2) (30) (32)
All other assets81
 20,547
 20,628
 53
 18,885
 18,938
Total$4,102
 $24,346
 $28,448
 $4,335
 $23,739
 $28,074
On-balance sheet liabilities 
  
  
  
  
  
Long-term debt$46
 $
 $46
 $152
 $
 $152
All other liabilities2
 5,087
 5,089
 7
 4,231
 4,238
Total$48
 $5,087
 $5,135
 $159
 $4,231
 $4,390
Total assets of VIEs$4,102
 $98,491
 $102,593
 $4,335
 $94,746
 $99,081

Bank of America 128


Customer VIEs
Customer VIEs include credit-linked, equity-linked and commodity-linked note VIEs, repackaging VIEs and asset acquisition VIEs, which are typically created on behalf of customers who wish to obtain market or credit exposure to a specific company, index, commodity or financial instrument.
The Corporation’s maximum loss exposure to consolidated and unconsolidated customer VIEs totaled $2.2$2.9 billion and $2.1$2.3 billion at December 31, 20192021 and 2018,2020, including the notional amount of derivatives to which the Corporation is a counterparty, net of losses previously recorded, and the Corporation’s investment, if any, in securities issued by the VIEs.
Collateralized Debt Obligation VIEs
The Corporation receives fees for structuring CDO VIEs, which hold diversified pools of fixed-income securities, typically corporate debt or ABS, which the CDO VIEs fund by issuing multiple tranches of debt and equity securities. CDOs are generally managed by third-party portfolio managers. The Corporation typically transfers assets to these CDOs, holds securities issued by the CDOs and may be a derivative counterparty to the CDOs. The Corporation’s maximum loss exposure to consolidated and unconsolidated CDOs totaled $304$235 million and $421$298 million at December 31, 20192021 and 2018.2020.
Investment VIEs
The Corporation sponsors, invests in or provides financing, which may be in connection with the sale of assets, to a variety of investment VIEs that hold loans, real estate, debt securities or other financial instruments and are designed to provide the desired investment profile to investors or the Corporation. At December 31, 20192021 and 2018,2020, the Corporation’s consolidated investment VIEs had total assets of $104 million$1.0 billion and $270 million.$494 million. The Corporation also held investments in unconsolidated VIEs with total assets of $32.4$7.1 billion and $37.7$5.4 billion at December 31, 20192021 and 2018.2020. The Corporation’s maximum loss exposure associated with both consolidated and unconsolidated investment VIEs totaled $6.4$2.0 billion and $7.2$1.5 billion at December 31, 20192021 and 20182020 comprised primarily of on-balance sheet assets less non-recourse liabilities.
Leveraged Lease Trusts
The Corporation’s net investment in consolidated leveraged lease trusts totaled $1.7$1.5 billion and $1.8$1.7 billion at December 31, 20192021 and 2018.2020. The trusts hold long-lived equipment such as rail cars, power generation and distribution equipment, and commercial aircraft. The Corporation structures the trusts and holds a significant residual interest. The net investment represents the Corporation’s maximum loss exposure to the trusts in the unlikely event that the leveraged lease investments become worthless. Debt issued by the leveraged lease trusts is non-recourse to the Corporation.
Tax Credit VIEs
The Corporation holds investments in unconsolidated limited partnerships and similar entities that construct, own and operate affordable housing, wind and solar projects. An unrelated third party is typically the general partner or managing
member and has control over the significant activities of the VIE. The Corporation earns a return primarily through the receipt of tax credits allocated to the projects. The maximum loss exposure included in the Other VIEs table was $18.9$25.7 billion and $17.0$22.0 billion at December 31, 20192021 and 2018.2020. 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 $10.0$12.6 billion and $8.9$11.2 billion, including unfunded commitments to provide capital contributions of $4.3$5.8 billion and $3.8$5.0 billion, at December 31, 20192021 and 2018.2020. The unfunded commitments are expected to be paid over the next five years. During 2019, 20182021, 2020 and 2017,2019, the Corporation recognized tax credits and other tax benefits from investments in affordable housing partnerships of $1.0$1.3 billion, $981 million$1.2 billion and $1.0 billion and reported pretax losses in other income of $1.1 billion, $1.0 billion and $882 million, $798 million and $766 million, respectively. TaxThese tax credits are recognized as part of the Corporation’s annual effective tax rate used to determine tax expense in a given quarter. Accordingly, the portion of a year’s expected tax benefits recognized in any given quarter may differ from 25 percent. The Corporation may from time to time be asked to invest additional amounts to support a troubled affordable housing project. Such additional investments have not been and are not expected to be significant.

Bank of America 124


NOTE 87 Goodwill and Intangible Assets
Goodwill
The table below presents goodwill balances by business segment and All Otherat December 31, 20192021 and 2018.2020. The reporting units utilized for goodwill impairment testing are the operating segments or one level below.
   
Goodwill   Goodwill
   
December 31
December 31
(Dollars in millions)2019 2018(Dollars in millions)20212020
Consumer Banking$30,123
 $30,123
Consumer Banking$30,137 $30,123 
Global Wealth & Investment Management9,677
 9,677
Global Wealth & Investment Management9,677 9,677 
Global Banking23,923
 23,923
Global Banking (1)
Global Banking (1)
24,026 23,969 
Global Markets5,182
 5,182
Global Markets5,182 5,182 
All Other46
 46
Total goodwill$68,951
 $68,951
Total goodwill$69,022 $68,951 

(1)
Prior period has been revised to conform to current-period presentation.
During 2019,2021, the Corporation completed its annual goodwill impairment test as of June 30, 20192021 using qualitative assessments for all applicable reporting units. Based on the results of the annual goodwill impairment test, the Corporation determined there was no impairment. For more information on the use of qualitative assessments, see Note 1 – Summary of Significant Accounting Principles.Principles.
Intangible Assets
At both December 31, 20192021 and 2018,2020, the net carrying value of intangible assets was $1.7 billion and $1.8$2.2 billion. At both December 31, 20192021 and 2018,2020, 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 $76 million, $95 million and $112 million $538 millionfor 2021, 2020 and $621 million for 2019, 2018 and 2017, respectively.2019.
129 Bank of America


NOTE 98 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.
At December 31, 2019,The table below presents the total net investment in sales-type and direct financing leases was $21.9 billion, comprised of $19.3 billion in lease receivablesat December 31, 2021 and $2.6 billion in unguaranteed residuals. 2020.
Net Investment (1)
December 31
(Dollars in millions)20212020
Lease receivables$16,806 $17,627 
Unguaranteed residuals2,078 2,303 
   Total net investment in sales-type and direct
      financing leases
$18,884 $19,930 
(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 $5.8 billion.$7.1 billion and $6.9 billion at December 31, 2021 and 2020.
For 2019, totalThe table below presents lease income was $1.7 billion, consisting of $797 million from sales-typeat December 31, 2021 and direct financing leases and $891 million from operating leases.2020.
Lease Income
December 31
(Dollars in millions)20212020
Sales-type and direct financing leases$613 $707 
Operating leases930 931 
   Total lease income$1,543 $1,638 
Lessee Arrangements
The Corporation’sCorporation's lessee arrangements predominantly consist of operating leases for premises and equipment; the Corporation’s
Corporation's financing leases are not significant. Right-of-use assets were $9.7 billion and lease liabilities were $10.1 billion at December 31, 2019. The weighted-average discount rate used to calculate the present value of future minimum lease payments was 4 percent.
Lease terms may contain renewal and extension options and early termination features. Generally, these options do not impact the lease term because the Corporation is not reasonably certain that it will exercise the options.
The following table provides information on the right-of-use assets, lease liabilities and weighted-average discount rates and lease term was 8.2 yearsterms at December 31, 2019.2021 and 2020.
The table below provides
Lessee Arrangements
December 31
(Dollars in millions)20212020
Right-of-use asset$10,233 $10,000 
Lease liabilities10,858 10,474 
Weighted-average discount rate used to calculate present value of future minimum lease payments2.91 %3.38 %
Weighted-average lease term (in years)9.08.4
Lease Cost and Supplemental Information:
Operating lease cost$2,025 $2,149 
Variable lease cost (1)
462 474 
   Total lease cost (2)
$2,487 $2,623 
Right-of-use assets obtained in exchange for
new operating lease liabilities (3)
$1,713 $851 
Operating cash flows from operating
    leases (4)
1,964 2,039 
(1)Primarily consists of payments for common area maintenance and property taxes.
(2)Amounts are recorded in occupancy and equipment expense in the componentsConsolidated 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 cost and supplemental information for 2019.liabilities.
  
Lease Cost and Supplemental Information for 2019
  
(Dollars in millions) 
Operating lease cost$2,085
Variable lease cost (1)
498
Total lease cost (2)
$2,583
  
Right-of-use assets obtained in exchange for new operating lease liabilities (3)
$931
Operating cash flows from operating leases (4)
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 measurement of lease liabilities.
Maturity Analysis
The maturities of lessor and lessee arrangements outstanding at December 31, 20192021 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, 2021
2022$848 $5,208 $1,917 
2023742 4,617 1,716 
2024591 3,888 1,550 
2025412 1,318 1,309 
2026296 1,634 1,153 
Thereafter696 1,358 4,758 
Total undiscounted
cash flows
$3,585 18,023 12,403 
Less: Net present
value adjustment
1,217 1,545 
Total (3)
$16,806 $10,858 
      
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, 2019
2020$843
 $4,657
 $1,966
2021746
 4,887
 1,763
2022651
 4,259
 1,502
2023530
 3,416
 1,240
2024397
 1,939
 1,098
Thereafter1,057
 1,910
 4,225
Total undiscounted
cash flows
$4,224
 21,068
 11,794
Less: Net present
value adjustment
  1,756
 1,701
Total (3)



$19,312

$10,093
(1)
Excludes $1.5 billionExcludes $179 million in commitments under lessee arrangements that have not yet commenced with lease terms that will begin in 2020.
(2)
Includes $15.1 billion in commercial lease financing receivables and $4.2 billion in direct/indirect consumer lease financing receivables.
(3)
Represents lease receivables for lessor arrangements and lease liabilities for lessee arrangements.
At December 31, 2018, operating lease commitments under lessee arrangements were $2.4 billion, $2.2 billion, $2.0 billion, $1.7 billion and $1.3 billion for 2019 through 2023, respectively, and $6.2 billion in the aggregate for all years thereafter. These amounts include variable lease payments and commitments under leases that have not yet commenced both of which are excluded from thewith lease terms that will begin in 2022.
(2)Includes $10.9 billion in commercial lease financing receivables and $5.9 billion in direct/indirect consumer lease financing receivables.
(3)Represents lease receivables for lessor arrangements and lease liabilities for lessee maturity analysis presented in the table above.arrangements.


125Bank of America130







NOTE 109 Deposits
The table below presents information about the Corporation’s time deposits of $100 thousand or more at December 31, 2019 and 2018. The Corporation also had aggregate time deposits of $15.8 billion and $16.4 billion in denominations that met or exceeded the Federal Deposit Insurance Corporation (FDIC) insurance limit at December 31, 2019 and 2018.
  ��       
Time Deposits of $100 Thousand or More        
          
 December 31, 2019 December 31
2018
(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$16,115
 $21,351
 $2,273
 $39,739
 $29,505
Non-U.S. certificates of deposit and other time deposits7,108
 4,821
 1,105
 13,034
 10,792

The scheduled contractual maturities for total time deposits at December 31, 20192021 are presented in the table below.
      
Contractual Maturities of Total Time Deposits
     
      
(Dollars in millions)U.S. Non-U.S. Total
Due in 2020$56,351
 $12,000
 $68,351
Due in 20213,503
 101
 3,604
Due in 2022990
 18
 1,008
Due in 2023280
 15
 295
Due in 2024187
 981
 1,168
Thereafter212
 35
 247
Total time deposits$61,523
 $13,150
 $74,673

Contractual Maturities of Total Time Deposits
(Dollars in millions)U.S.Non-U.S.Total
Due in 2022$34,555 $9,193 $43,748 
Due in 20231,934 75 2,009 
Due in 2024350 355 
Due in 2025230 11 241 
Due in 2026120 1,361 1,481 
Thereafter248 29 277 
Total time deposits$37,437 $10,674 $48,111 
At December 31, 2021 and 2020, the Corporation had aggregate U.S. time deposits of $9.4 billion and $10.7 billion and non-U.S. time deposits of $10.6 billion and $11.8 billion in denominations that met or exceeded insurance limits.
NOTE 1110 Federal Funds Sold or Purchased, Securities Financing Agreements, Short-term Borrowings and Restricted Cash
The table below presents federal funds sold or purchased,Corporation enters into securities financing agreements (which includeto accommodate customers (also referred to as “matched-book transactions”), obtain securities borrowed or purchased under agreements to resellcover short positions and securities loaned or sold under agreements to repurchase) and short-term borrowings.finance inventory positions. 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 2221 – Fair Value Option.
        
 Amount Rate Amount Rate
(Dollars in millions)2019 2018
Federal funds sold and securities borrowed or purchased under agreements to resell       
Average during year$279,610
 1.73% $251,328
 1.26%
Maximum month-end balance during year281,684
 n/a
 279,350
 n/a
Federal funds purchased and securities loaned or sold under agreements to repurchase       
Average during year$201,797
 2.31% $193,681
 1.80%
Maximum month-end balance during year203,063
 n/a
 201,089
 n/a
Short-term borrowings       
Average during year24,301
 2.42
 36,021
 2.69
Maximum month-end balance during year36,538
 n/a
 52,480
 n/a
n/a = not applicable
Bank of America, N.A. maintains a global program to offer up to a maximum of $75 billion outstanding at any one time, of bank notes with fixed or floating rates and maturities of at least seven days from the date of issue. Short-term bank notes outstanding under this program totaled $11.7 billion and $12.1 billion at December 31, 2019 and 2018. These short-term bank notes, along with Federal Home Loan Bank advances, U.S. Treasury tax and loan notes, and term federal funds purchased, are included in short-term borrowings on the Consolidated Balance Sheet.
Offsetting of Securities Financing Agreements
The Corporation enters into securities financing agreements to accommodate customers (also referred to as “matched-book transactions”), obtain securities to cover short positions and finance inventory positions. Substantially all of the Corporation’s securities financing activities are transacted under legally enforceable master repurchase agreements or legally enforceable master securities lending agreements that give the Corporation,
in the event of
default by the counterparty, the right to liquidate securities held and to offset receivables and payables with the same counterparty. The Corporation offsets securities financing transactions with the same counterparty on the Consolidated Balance Sheet where it has such a legally enforceable master netting agreement and the transactions have the same maturity date.
The Securities Financing Agreements table presents securities financing agreements included on the Consolidated Balance Sheet in federal funds sold and securities borrowed or purchased under agreements to resell, and in federal funds purchased and securities loaned or sold under agreements to repurchase at December 31, 20192021 and 2018.2020. 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.Derivatives.

Securities Financing Agreements
Gross Assets/Liabilities (1)
Amounts OffsetNet Balance Sheet Amount
Financial Instruments (2)
Net Assets/Liabilities
(Dollars in millions)December 31, 2021
Securities borrowed or purchased under agreements to resell (3)
$527,054 $(276,334)$250,720 $(229,525)$21,195 
Securities loaned or sold under agreements to repurchase$468,663 $(276,334)$192,329 $(181,860)$10,469 
Other (4)
11,391  11,391 (11,391) 
Total$480,054 $(276,334)$203,720 $(193,251)$10,469 
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 — 16,210 (16,210)— 
Total$374,862 $(188,329)$186,533 $(175,077)$11,456 
(1)Includes activity where uncertainty exists as to the enforceability of certain master netting agreements under bankruptcy laws in some countries or industries.
Bank of America 126(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 $20.1 billion and $14.7 billion reported in loans and leases on the Consolidated Balance Sheet at December 31, 2021 and 2020.
(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 Offset Net Balance Sheet Amount 
Financial Instruments (2)
 Net Assets/Liabilities
(Dollars in millions)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
          
 December 31, 2018
Securities borrowed or purchased under agreements to resell (3)
$366,274
 $(106,865) $259,409
 $(240,790) $18,619
Securities loaned or sold under agreements to repurchase$293,853
 $(106,865) $186,988
 $(176,740) $10,248
Other (4)
19,906
 
 19,906
 (19,906) 
Total$313,759
 $(106,865) $206,894
 $(196,646) $10,248

(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 $12.9 billion and $11.5 billion reported in loans and leases on the Consolidated Balance Sheet at December 31, 2019 and 2018.
(4)
Balance is reported in accrued expenses and other liabilities on the Consolidated Balance Sheet and relates to transactions where the Corporation acts as the lender in a securities lending agreement and receives securities that can be pledged as collateral or sold. In these transactions, the Corporation recognizes an asset at fair value, representing the securities received, and a liability, representing the obligation to return those securities.
Repurchase Agreements and Securities Loaned Transactions Accounted for as Secured Borrowings
The following tables present securities sold under agreements to repurchase and securities loaned by remaining contractual term to maturity and class of collateral pledged. Included in “Other” are transactions where the Corporation acts as the lender in a
securities lending agreement and receives securities that can be pledged as collateral or sold. Certain agreements contain a right to substitute collateral and/or terminate the agreement prior to maturity at the option of the Corporation or the counterparty. Such agreements are included in the table below based on the remaining contractual term to maturity.
          
Remaining Contractual Maturity
          
 Overnight and Continuous 30 Days or Less After 30 Days Through 90 Days 
Greater than
90 Days (1)
 Total
(Dollars in millions)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
          
 December 31, 2018
Securities sold under agreements to repurchase$139,017
 $81,917
 $34,204
 $21,476
 $276,614
Securities loaned7,753
 4,197
 1,783
 3,506
 17,239
Other19,906
 
 
 
 19,906
Total$166,676
 $86,114
 $35,987
 $24,982
 $313,759
(1)
No agreements have maturities greater than three years.
        
Class of Collateral Pledged
        
 Securities Sold Under Agreements to Repurchase 
Securities
Loaned
 Other Total
(Dollars in millions)December 31, 2019
U.S. government and agency securities$173,533
 $1
 $
 $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
        
 December 31, 2018
U.S. government and agency securities$164,664
 $
 $
 $164,664
Corporate securities, trading loans and other11,400
 2,163
 287
 13,850
Equity securities14,090
 10,869
 19,572
 44,531
Non-U.S. sovereign debt81,329
 4,207
 47
 85,583
Mortgage trading loans and ABS5,131
 
 
 5,131
Total$276,614
 $17,239
 $19,906
 $313,759


127131 Bank of America




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, 2021
Securities sold under agreements to repurchase$148,023 $194,964 $36,939 $36,501 $416,427 
Securities loaned46,231 466 1,428 4,111 52,236 
Other11,391    11,391 
Total$205,645 $195,430 $38,367 $40,612 $480,054 
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 — — — 16,210 
Total$193,750 $122,719 $33,178 $25,215 $374,862 

(1)No agreements have maturities greater than three years.



Class of Collateral Pledged
Securities Sold Under Agreements to RepurchaseSecurities
Loaned
OtherTotal
(Dollars in millions)December 31, 2021
U.S. government and agency securities$201,546 $27 $ $201,573 
Corporate securities, trading loans and other12,838 3,440 1,148 17,426 
Equity securities19,907 48,650 10,192 78,749 
Non-U.S. sovereign debt178,019 119 51 178,189 
Mortgage trading loans and ABS4,117   4,117 
Total$416,427 $52,236 $11,391 $480,054 
December 31, 2020
U.S. government and agency securities$195,167 $$— $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 — — 3,987 
Total$335,681 $22,971 $16,210 $374,862 
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.
Short-term Bank Notes
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 $1.8 billion and $3.9 billion at December 31, 2021 and 2020. 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.
Restricted Cash
At December 31, 20192021 and 2018,2020, the Corporation held restricted cash included within cash and cash equivalents on the Consolidated Balance Sheet of $24.4$5.9 billion and $22.6$7.0 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.regulations and cash held on deposit with central banks to meet reserve requirements.
Bank of America 132


NOTE 1211 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, 20192021 and 2018,2020, and the related contractual rates and maturity dates as of December 31, 2019.
2021.
      
Weighted-average Rate   December 31Weighted-average RateDecember 31
(Dollars in millions) Interest Rates Maturity Dates 2019 2018(Dollars in millions)Interest RatesMaturity Dates20212020
Notes issued by Bank of America Corporation (1)
    
  
Notes issued by Bank of America Corporation (1)
  
Senior notes:    
  
Senior notes:  
Fixed3.30% 0.25 - 8.05
% 2020 - 2050 $140,265
 $120,548
Fixed2.85%0.25 - 8.05%2022 - 2052$194,191 $174,385 
Floating1.81 0.25 - 6.68
 2020 - 2044 19,552
 25,574
Floating0.640.02 - 4.882023 - 204418,753 16,788 
Senior structured notes   16,941
 13,815
Senior structured notes15,086 17,033 
Subordinated notes:      Subordinated notes:
Fixed4.89 2.94 - 8.57
 2021 - 2045 21,632
 20,843
Fixed4.882.94 - 8.572024 - 204522,311 23,337 
Floating2.74 2.56 - 2.89
 2022 - 2026 782
 1,742
Floating2.180.82 - 2.482026 - 20362,371 799 
Junior subordinated notes:      Junior subordinated notes:
Fixed6.71 6.45 - 8.05
 2027 - 2066 736
 732
Fixed6.716.45 - 8.052027 - 2066741 738 
Floating (2)
2.71 2.71
 2056 1
 1
FloatingFloating0.970.9720561 
Total notes issued by Bank of America Corporation   199,909
 183,255
Total notes issued by Bank of America Corporation253,454 233,081 
Notes issued by Bank of America, N.A.    
  
Notes issued by Bank of America, N.A.  
Senior notes:    
  
Senior notes:  
Fixed3.34 3.34
 2023 508
 
Fixed3.343.342023501 511 
Floating2.18 1.99 - 2.51
 2020 - 2041 6,519
 1,770
Floating0.260.20 - 0.332022 - 20233,173 2,323 
Subordinated notes6.00 6.00
 2036 1,744
 1,617
Subordinated notes6.006.0020361,780 1,883 
Advances from Federal Home Loan Banks:      Advances from Federal Home Loan Banks:
Fixed4.98 0.01 - 7.72
 2020 - 2034 112
 130
Fixed1.540.01 - 7.722022 - 2034290 599 
Floating1.79 1.77 - 1.84
 2020 2,500
 14,751
Securitizations and other BANA VIEs (3)
   8,373
 10,326
Securitizations and other BANA VIEs (2)
Securitizations and other BANA VIEs (2)
3,338 6,296 
Other    402
 442
Other680 683 
Total notes issued by Bank of America, N.A.   20,158
 29,036
Total notes issued by Bank of America, N.A.9,762 12,295 
Other debt    
  
Other debt  
Structured liabilities   20,442
 16,483
Nonbank VIEs (3)
   347
 618
Total other debt   20,789
 17,101
Structured liabilities (3)
Structured liabilities (3)
16,599 16,792 
Nonbank VIEs (2)
Nonbank VIEs (2)
249 757 
OtherOther53 
Total notes issued by nonbank and other entitiesTotal notes issued by nonbank and other entities16,901 17,558 
Total long-term debt   $240,856

$229,392
Total long-term debt$280,117 $262,934 
(1)
(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. Long-term debt of VIEs is collateralized by the assets of the VIEs. At December 31, 2021, amount includes debt predominantly from credit card securitization and other VIEs of $3.2 billion and $211 million. For more information, see Note 6 – Securitizations and Other Variable Interest Entities.
(3)Includes debt outstanding of $5.4 billion and $4.8 billion at December 31, 2021 and 2020 that 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.

Includes total loss-absorbing capacity compliant debt.
(2)
Includes amounts related to trust preferred securities. For more information, see Trust Preferred Securities in this Note.
(3)
Represents liabilities of consolidated VIEs included in total long-term debt on the Consolidated Balance Sheet.
During 2019,2021, the Corporation issued $52.5$76.7 billion of long-term debt consisting of $29.3$56.2 billion of notes issued by Bank of America Corporation, $10.9$8.0 billion of notes issued by Bank of America, N.A. and $12.3$12.5 billion of other debt, substantially all of which was structured liabilities.debt. During 2018,2020, the Corporation issued $64.4$56.9 billion of long-term debt consisting of $30.7$43.8 billion of notes issued by Bank of America Corporation, $18.7$4.8 billion of notes issued by Bank of America, N.A. and $15.0$8.3 billion of other debt, substantially all of which was structured liabilities.debt.
During 2019,2021, the Corporation had total long-term debt maturities and redemptions in the aggregate of $50.6$46.4 billion consisting of $21.1$24.4 billion for Bank of America Corporation, $19.9$10.4 billion for Bank of America, N.A. and $9.6$11.6 billion of other debt. During 2018,2020, the Corporation had total long-term debt maturities and redemptions in the aggregate of $53.3$47.1 billion consisting of $29.8$22.6 billion for Bank of America Corporation, $11.2$11.5 billion for Bank of America, N.A. and $12.3$13.0 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, 20192021 and 2018,2020, the amount of foreign currency-denominated debt translated into U.S. dollars included in total long-term debt was $49.6$53.1 billion and $48.6$54.6 billion. Foreign currency contracts may be used to convert certain foreign currency-denominated debt into U.S. dollars.
At December 31, 2019, long-term debt of consolidated VIEs in the table above included debt from credit card, residential mortgage, home equity, other VIEs and ABS of $8.4 billion, $217 million, $64 million, $46 million and $19 million, respectively. Long-term debt of VIEs is collateralized by the assets of the VIEs. For more information, see Note 7 – Securitizations and Other Variable Interest Entities.

Bank of America 128


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 3.262.83 percent, 3.553.08 percent and 1.920.75 percent, respectively, at December 31, 2019,2021, and 3.02 percent, 3.29 percent 3.66 percent and 2.260.71 percent, respectively, at December 31, 2018.2020. 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.
Debt outstanding of $5.7 billion at December 31, 2019 was issued by BofA Finance LLC, a 100 percent owned finance
subsidiary of Bank of America Corporation, the parent company, and is fully and unconditionally guaranteed by the parent company.
The following table below shows the carrying value for aggregate annual contractual maturities of long-term debt as of December 31, 2019.2021. 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)2020 2021 2022 2023 2024 Thereafter Total
Bank of America Corporation             
Senior notes$9,312
 $15,978
 $14,875
 $23,045
 $17,236
 $79,371
 $159,817
Senior structured notes822
 453
 2,232
 288
 547
 12,599
 16,941
Subordinated notes
 360
 386
 
 3,213
 18,455
 22,414
Junior subordinated notes (1)

 
 
 
 
 737
 737
Total Bank of America Corporation10,134

16,791

17,493

23,333

20,996

111,162

199,909
Bank of America, N.A.             
Senior notes3,000
 3,499
 
 509
 
 19
 7,027
Subordinated notes
 
 
 
 
 1,744
 1,744
Advances from Federal Home Loan Banks2,509
 2
 3
 1
 
 97
 2,612
Securitizations and other Bank VIEs (2)
3,099
 4,080
 1,185
 9
 
 
 8,373
Other134
 55
 
 130
 
 83
 402
Total Bank of America, N.A.8,742

7,636

1,188

649



1,943

20,158
Other debt             
Structured liabilities5,275
 1,884
 1,057
 1,372
 745
 10,109
 20,442
Nonbank VIEs (2)

 
 
 1
 
 346
 347
Total other debt5,275

1,884

1,057

1,373

745

10,455

20,789
Total long-term debt$24,151

$26,311

$19,738

$25,355

$21,741

$123,560

$240,856
(1)133 Bank of America
Includes amounts related to trust preferred securities. For more information, see Trust Preferred Securities in this Note.


Long-term Debt by Maturity
(Dollars in millions)20222023202420252026ThereafterTotal
Bank of America Corporation
Senior notes$3,217 $23,326 $23,462 $21,534 $17,968 $123,437 $212,944 
Senior structured notes1,937 572 396 398 819 10,964 15,086 
Subordinated notes— — 3,283 5,379 5,171 10,849 24,682 
Junior subordinated notes— — — — — 742 742 
Total Bank of America Corporation5,154 23,898 27,141 27,311 23,958 145,992 253,454 
Bank of America, N.A.
Senior notes1,600 2,074 — — — — 3,674 
Subordinated notes— — — — — 1,780 1,780 
Advances from Federal Home Loan Banks202 — 16 10 61 290 
Securitizations and other Bank VIEs (1)
1,259 988 1,000 — 90 3,338 
Other102 386 32 143 10 680 
Total Bank of America, N.A.3,163 3,449 1,032 160 17 1,941 9,762 
Other debt
Structured Liabilities3,586 2,823 1,996 668 1,621 5,905 16,599 
Nonbank VIEs (1)
51 — — — 196 249 
Other— — — — — 53 53 
Total other debt3,588 2,874 1,996 668 1,621 6,154 16,901 
Total long-term debt$11,905 $30,221 $30,169 $28,139 $25,596 $154,087 $280,117 
(1)     (2)
Represents liabilities of consolidated VIEs included in total long-term debt on the Consolidated Balance Sheet.
Trust Preferred Securities
At December 31, 2019, trust preferred securities (Trust Securities) with a carrying value of $1 million, issued by BAC Capital Trust XV (the Trust), a 100 percent owned, non-consolidated finance subsidiary of the Corporation, were issued and outstanding. The Trust Securities are mandatorily redeemable preferred security obligations of the Trust. The sole asset of the Trust is a junior subordinated deferrable interest note of the Corporation (the Note).
Periodic cash payments and payments upon liquidation or redemption with respect to Trust Securities are guaranteed by the Corporation to the extent of funds held by the Trust (the Preferred Securities Guarantee). The Preferred Securities Guarantee, when taken together with the Corporation’s other obligations including its obligations under the Note, generally will constitute a full and unconditional guarantee, on a subordinated basis, by the Corporation of payments due on the Trust Securities.Consolidated Balance Sheet.
NOTE 1312 Commitments and Contingencies
In the normal course of business, the Corporation enters into a number of off-balance sheet commitments. These commitments expose the Corporation to varying degrees of credit and market risk and are subject to the same credit and market risk limitation
reviews as those instruments recorded on the Consolidated Balance Sheet.
Credit Extension Commitments
The Corporation enters into commitments to extend credit such as loan commitments, SBLCs and commercial letters of credit to meet the financing needs of its customers. The following table includes the notional amount of unfunded legally binding lending commitments net of amounts distributed (i.e., syndicated or participated) to other financial institutions. The distributed amounts were $10.6$10.7 billion and $10.7$10.5 billion at December 31, 20192021 and 2018. At December 31, 2019, the2020. The carrying value of thesethe Corporation’s credit extension commitments at December 31, 2021 and 2020, excluding commitments accounted for under
the fair value option, was $829 million, including deferred revenue of $16 million$1.5 billion and a$1.9 billion, which predominantly related to the reserve for unfunded lending commitments of $813 million. At December 31, 2018, the comparable amounts were $813 million, $16 million and $797 million, respectively.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.


129Bank of America






The following table below includes the notional amount of commitments of $4.4$4.8 billion and $3.1$4.0 billion at December 31, 20192021 and 20182020 that are accounted for under the fair value option. However, the table excludes the cumulative net fair value for these commitments of $90$97 million and $169$99 million at December 31, 20192021 and 2018 on these commitments,
2020, 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 2221 – Fair Value Option.
          
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, 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
          
 December 31, 2018
Notional amount of credit extension commitments 
  
  
  
  
Loan commitments (1)
$84,910
 $142,271
 $155,298
 $22,683
 $405,162
Home equity lines of credit2,578
 2,249
 3,530
 34,702
 43,059
Standby letters of credit and financial guarantees (2)
22,571
 9,702
 2,457
 1,074
 35,804
Letters of credit (3)
1,168
 84
 69
 57
 1,378
Legally binding commitments111,227
 154,306
 161,354
 58,516
 485,403
Credit card lines (4)
371,658
 
 
 
 371,658
Total credit extension commitments$482,885
 $154,306
 $161,354
 $58,516
 $857,061
(1)
At December 31, 2019 and 2018, $5.1 billion and $4.3 billion of these loan commitments are held in the form of a security.
(2)
The notional amounts of SBLCs and financial guarantees classified as investment grade and non-investment grade based on the credit quality of the underlying reference name within the instrument were $27.9 billion and $8.6 billion at December 31, 2019, and $28.3 billion and $7.1 billion at December 31, 2018. Amounts in the table include consumer SBLCs of $413 million and $372 million at December 31, 2019 and 2018.
(3)
At December 31, 2019 and 2018, included are lettersBank of credit of $1.4 billion and $422 million related to certain liquidity commitments of VIEs. For more information, seeAmerica Note 7 – Securitizations and Other Variable Interest Entities.134
(4)


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, 2021
Notional amount of credit extension commitments     
Loan commitments (1)
$102,464 $190,687 $174,978 $26,635 $494,764 
Home equity lines of credit890 5,097 10,268 24,276 40,531 
Standby letters of credit and financial guarantees (2)
22,359 10,742 2,017 422 35,540 
Letters of credit1,145 124 56 98 1,423 
Other commitments (3)
18 59 81 1,233 1,391 
Legally binding commitments126,876 206,709 187,400 52,664 573,649 
Credit card lines (4)
406,169    406,169 
Total credit extension commitments$533,045 $206,709 $187,400 $52,664 $979,818 
 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 credit886 197 25 27 1,135 
Other commitments (3)
22 132 125 1,219 1,498 
Legally binding commitments130,986 187,246 150,793 48,486 517,511 
Credit card lines (4)
384,955 — — — 384,955 
Total credit extension commitments$515,941 $187,246 $150,793 $48,486 $902,466 
(1)     At December 31, 2021 and 2020, $4.6 billion and $4.8 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 $26.3 billion and $8.7 billion at December 31, 2021, and $25.0 billion and $10.2 billion at December 31, 2020. Amounts in the table include consumer SBLCs of $512 million and $500 million at December 31, 2021 and 2020.
(3)     Primarily includes second-loss positions on lease-end residual value guarantees.
(4)     Includes business card unused lines of credit.
Includes business card unused lines of credit.
Other Commitments
At December 31, 20192021 and 2018,2020, the Corporation had commitments to purchase loans (e.g., residential mortgage and commercial real estate) of $86$181 million and $329$93 million, which upon settlement will be included in trading account assets, loans or LHFS, and commitments to purchase commercial loans of $1.1 billion$518 million and $463$645 million, which upon settlement will be included in trading account assets.
At December 31, 20192021 and 2018,2020, the Corporation had commitments to purchase commodities, primarily liquefied natural gas, of $830$949 million and $1.3 billion,$582 million, which upon settlement will be included in trading account assets.
At December 31, 20192021 and 2018,2020, the Corporation had commitments to enter into resale and forward-dated resale and securities borrowing agreements of $97.2$92.0 billion and $59.7$66.5 billion, and commitments to enter into forward-dated repurchase and securities lending agreements of $24.9$32.6 billion and $21.2$32.1 billion. These commitments generally expire primarily within the next 12 months.
At December 31, 20192021 and 2018,2020, the Corporation had a commitment to originate or purchase up to $3.3$4.0 billion and $3.0$3.9 billion on a rolling 12-month basis, of auto loans and leases from a strategic partner. This commitment extends through November 20222026 and can be terminated with 12 months prior notice.
At December 31, 2021 and 2020, the Corporation had unfunded equity investment commitments of $395 million and $213 million.
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, 20192021 and 2018,
2020, the notional amount of these guarantees totaled $7.3$6.3 billion and
$9.8 $7.1 billion. At December 31, 20192021 and 2018,2020, the Corporation’s maximum exposure related to these guarantees totaled $1.1 billion$928 million and $1.5$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
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. IfPrior to July 1, 2020, a merchant processor fails to meet its obligation regarding

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disputed transactions, then the Corporation could be held liable. In 2019 and 2018, the sponsored entities processed $916.6 billion and $874.3 billion of transactions and recorded losses of $24 million and $31 million.
At December 31, 2019 and 2018, the maximum potential exposure for sponsored transactions totaled $384.2 billion and $348.1 billion. However, the Corporation believes that the maximum potential exposure is not representative of the actual potential loss exposure and does not expect to make material payments in connection with these guarantees.
A significant portion of the Corporation's merchant processing activity iswas performed by a joint venture formed in 2009, in which the Corporation holdsheld a 49 percent ownership interest. 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.

135 Bank of America


The carrying valueCorporation in its role as merchant acquirer or as a sponsor of other merchant acquirers may be held liable for any reversed charges that cannot be collected from the merchants, due to, among other things, merchant fraud or insolvency. 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. The total amount of transactions processed for the preceding six-month period, which was $476.2 billion, is an estimate of the Corporation’s investment was $640 million and $2.8 billion atmaximum potential exposure as of December 31, 20192021. 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 2018. The joint venture is accounted for as an equity method investment and reported in All Other. On July 29, 2019, the Corporation gave noticelosses incurred related to the joint venture partnermerchant processing activity were not significant. The Corporation continues to monitor its exposure in this area due to the potential economic impacts of the termination of the joint venture upon the conclusion of its current term in June 2020. As a result, the Corporation incurred a non-cash, pretax impairment charge in 2019 of $2.1 billion, included in other general operating expense.pandemic.
Exchange and Clearing House Member Guarantees
The Corporation is a member of various securities and derivative exchanges and clearinghouses, both in the U.S. and other countries. As a member, the Corporation may be required to pay a pro-rata share of the losses incurred by some of these organizations as a result of another member default and under other loss scenarios. The Corporation’s potential obligations may be limited to its membership interests in such exchanges and clearinghouses, to the amount (or multiple) of the Corporation’s contribution to the guarantee fund or, in limited instances, to the full pro-rata share of the residual losses after applying the guarantee fund. The Corporation’s maximum potential exposure under these membership agreements is difficult to estimate; however, the Corporation has assessed the probability of making any such payments as remote.
Prime Brokerage and Securities Clearing Services
In connection with its prime brokerage and clearing businesses, the Corporation performs securities clearance and settlement services with other brokerage firms and clearinghouses on behalf of its clients. Under these arrangements, the Corporation stands ready to meet the obligations of its clients with respect to securities transactions. The Corporation’s obligations in this respect are secured by the assets in the clients’ accounts and the accounts of their customers as well as by any proceeds received from the transactions cleared and settled by the Corporation on behalf of clients or their customers. The Corporation’s maximum potential exposure under these arrangements is difficult to estimate; however, the potential for the Corporation to incur material losses pursuant to these arrangements is remote.
Other GuaranteesFixed Income Clearing Corporation Sponsored Member Repo Program
The Corporation has entered into additionalacts 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 agreementsobligation is secured by a security interest in cash or high-quality securities collateral placed by clients with the clearinghouse 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.therefore, the potential for the Corporation to incur significant losses under this arrangement is remote. The Corporation’s maximum potential future payments under these agreements are approximately $8.7exposure, without taking into consideration the related collateral, was $42.0 billion and $5.9$22.5 billion at December 31, 20192021 and 2018. The estimated maturity dates of these obligations extend up to 2049. The Corporation has made
2020.
no material payments under these guarantees. For more information on maximum potential future payments under VIE-related liquidity commitments, see Note 7 – Securitizations and Other Variable Interest Entities.
During 2019, the Corporation recognized a loss of $210 million in other income under its indemnity obligation in connection with the 2017 sale of its non-U.S. consumer credit card business (payment protection insurance).Guarantees
In the normal course of business, the Corporation periodically guarantees the obligations of its affiliates in a variety of transactions including ISDA-related transactions and non-ISDA related transactions such as commodities trading, repurchase
agreements, prime brokerage agreements and other transactions.
Guarantees of Certain Long-term Debt
The Corporation, as the parent company, fully and unconditionally guarantees the securities issued by BofA Finance LLC, a 100 percent ownedconsolidated 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).
Unresolved Repurchase Claims
Unresolved representations and warranties repurchase claims represent the notional amount of repurchase claims made by counterparties, typically the outstanding principal balance or the unpaid principal balance at the time of default. In the case of first-lien mortgages, the claim amount is often significantly greater than the expected loss amount due to the benefit of collateral and, in some cases, mortgage insurance or mortgage guarantee payments.
The notional amount of unresolved repurchase claims at December 31, 20192021 and 20182020 was $10.7$8.4 billion and $14.4$8.5 billion. These balances included $3.7$2.8 billion and $6.2$2.9 billion at December 31, 20192021 and 20182020 of claims related to loans in specific private-label securitization groups or tranches where the Corporation owns substantially all of the outstanding securities or will otherwise realize the benefit of any repurchase claims paid. The balance for 2019 also includes $1.6 billion of repurchase claims related to a single monoline insurer and is the subject of litigation.
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During 2019,2021, the Corporation received $461$49 million in new repurchase claims that were not time-barred. During 2019, $4.2 billion2021, $141 million in claims were resolved, including $2.1 billion of claims that were deemed time-barred.resolved.

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Reserve and Related Provision
The reserve for representations and warranties obligations and corporate guarantees was $1.8$1.2 billion and $2.0$1.3 billion at December 31, 20192021 and 20182020 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 ourits experience in previous negotiations, and is subject to judgment, a variety of assumptions and known or unknown uncertainties. Future representations and warranties losses may occur in excess of the amounts recorded for these exposures; however, the Corporation does not expect such amounts to be material to the Corporation's financial condition and liquidity. See Litigation and Regulatory Matters in this Note below for the Corporation's combined range of possible loss in excess of the reserve for representations and warranties and the accrued liability for litigation.
Litigation and Regulatory Matters
In the ordinary course of business, the Corporation and its subsidiaries are routinely defendants in or parties to many pending and threatened legal, regulatory and governmental actions and proceedings. In view of the inherent difficulty of predicting the outcome of such matters, particularly where the claimants seek very large or indeterminate damages or where the matters present novel legal theories or involve a large number of parties, the Corporation generally cannot predict the eventual outcome of the pending matters, timing of the ultimate resolution of these matters, or eventual loss, fines or penalties related to each pending matter.
In accordance with applicable accounting guidance, the Corporation establishes an accrued liability when those matters present loss contingencies that are both probable and estimable. In such cases, there may be an exposure to loss in excess of any amounts accrued. As a matter develops, the Corporation, in conjunction with any outside counsel handling the matter, evaluates on an ongoing basis whether such matter presents a loss contingency that is probable and estimable.estimable, and, for the matters described below 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 $681$164 million and $469$823 million was recognized in 20192021 and 2018.2020.
For a limited number of the mattersany matter 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. With respect to the matters disclosed in this Note, in cases in which the Corporation possesses sufficient appropriate information to estimate a range of possible loss, that estimate is aggregated and disclosed below. There may be other disclosed matters for which a loss is probable or reasonably possible but such an estimate of the range of possible loss may not be possible. For such matters disclosed in this Note, where an estimate of the
Corporation’s estimated range of possible loss is possible, as well as for representations and warranties exposures, management currently estimates the aggregate range of reasonably possible loss for these exposures is $0 to $1.6$1.0 billion in excess of the accrued liability, if any.any, as of December 31, 2021.
The accrued liability and estimated range of possible loss as well as the Corporation's accrued liability, isare based upon currently available information and is subject to significant judgment, a variety of assumptions and known and unknown uncertainties. The matters underlying the accrued liability and estimated range of possible loss and liability accrual are unpredictable and willmay change from time to time, and actual losses may vary
significantly from the current estimate and accrual. The
estimated range of possible loss does not represent the Corporation’s maximum loss exposure.
Information is provided below regarding the nature of the litigation and, where specified, associated 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,below, will have a material adverse effect on the consolidated financial condition or liquidity of the Corporation. However, in light of the significant judgment, variety of assumptions and uncertainties involved in these matters, some of which are beyond the Corporation’s control, and the very large or indeterminate damages sought in some of these matters, an adverse outcome in one or more of these matters could be material to the Corporation’s business or results of operations for any particular reporting period, or cause significant reputational harm.
Ambac Bond Insurance Litigation
Ambac Assurance Corporation and the Segregated Account of Ambac Assurance Corporation (together, Ambac) have filed four4 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 optionpay-option adjustable-rate mortgage loans. Ambac alleges that they have paid or will pay claims as a result of defaults in the underlying loans and asserts that the defendants misrepresented the characteristics of the underlying loans and/or breached certain contractual representations and warranties regarding the underwriting and servicing of the loans. In those actions where the Corporation is named as a defendant, Ambac contends the Corporation is liable on various successor and vicarious liability theories. These actions are at various procedural stages with material developments provided below.
Ambac v. Countrywide I
TheAmbac named the Corporation Countrywide and otherseveral Countrywide entities are named as defendants in an action filed on September 28, 2010 in New York Supreme Court. Ambac assertsCourt asserting claims for fraudulent inducement as well as breach of contract and seeksseeking damages in excess of $2.2 billion, plus punitive damages.
On The Supreme Court dismissed Ambac’s fraudulent inducement claim, and on May 16, 2017,11, 2021, the First Department, issued its decisionsa New York State appellate court (First Department), affirmed the dismissal. The Supreme Court has scheduled a non-jury trial for September 7, 2022 on the parties’ cross-appeals of the trial court’s October 22, 2015 summary judgment rulings. Ambac appealed the First Department’s rulings requiring Ambac to prove all of the elements of its fraudulent inducementcontract claim including justifiable reliance and loss causation; restricting Ambac’s sole remedy for its breach of contract claims to the repurchase protocol of cure, repurchase or substitution of any materially defective loan; and dismissing Ambac’s claim for reimbursements of attorneys’ fees. On June 27, 2018, the New York Court of Appeals affirmed the First Department rulings that Ambac appealed.remains.

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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 seeksCorporation, while seeking damages in excess of $600 million, plus punitive damages. On December 19, 2016, the Court granted in part and denied in part Countrywide’s motion to dismiss the complaint.
Ambac v. Countrywide IV
On July 21, 2015, Ambac filed an action in New York Supreme Court against Countrywide asserting the same claims for fraudulent inducement that Ambac asserted in the now-dismissed now dismissed Ambac v. Countrywide III. The complaint seeks damages in excess of $350 million, plus punitive damages. On December 8, 2020, the New York Supreme Court dismissed Ambac’s complaint. On February 8, 2022, the First Department affirmed the dismissal.

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Ambac v. First Franklin
On April 16, 2012, Ambac filed an action against BANA, First Franklin and various Merrill Lynch entities, including Merrill Lynch, Pierce, Fenner & Smith Incorporated, in New York Supreme Court relating to guaranty insurance Ambac provided on a First Franklin securitization sponsored by Merrill Lynch. The complaint alleges fraudulent inducement and breach of contract, including breach of contract claims against BANA based upon its servicing of the loans in the securitization. Ambac seeks as damages hundreds of millions of dollars that Ambac alleges it has paid or will pay in claims.
Deposit Insurance Assessment
On January 9, 2017, the FDICFederal Deposit Insurance Corporation (FDIC) filed suit against BANA in the U.S. District Court for the District of Columbia alleging failure to pay a December 15, 2016 invoice for additional deposit insurance assessments and interest in the amount of $542 million for the quarters ending June 30, 2013 through December 31, 2014.
On April 7, 2017, the FDIC amended its complaint to add a claim for additional deposit insurance and interest in the amount of $583 million for the quarters ending March 31, 2012 through March 31, 2013. The FDIC asserts these claims based on BANA’s alleged underreporting of counterparty exposures that resulted in underpayment of assessments for those quarters and its Enforcement Section is also conducting a parallel investigation related to the same alleged reporting error. BANA disagrees with the FDIC’s interpretation of the regulations as they existed during the relevant time period and is defending itself against the FDIC’s claims. Pending final resolution, BANA has pledged security satisfactory to the FDIC related to the disputed additional assessment amounts.
On March 27, 2018, the U.S. District Court for the District of Columbia denied BANA’s partial motion to dismiss certain of the FDIC’s claims.
Interchange Litigation
In 2005, a group of merchants filed a series of putative class actions and individual actions directed at interchange fees associated with Visa and MasterCard payment card transactions. These actions, which were consolidated in the U.S. District Court for the Eastern District of New York under the caption In re Payment Card Interchange Fee and Merchant Discount Anti-Trust Litigation, named Visa, MasterCard, the Corporation, BANA and other banks as defendants. Plaintiffs alleged antitrust claims and sought compensatory and treble damages as well as injunctive relief.
In 2018, defendants reached a settlement of the putative Rule 23(b)(3) damages class. Defendants agreed to pay an additional amount to participating class members by contribution to the escrow fund established as part of the settlement previously rejected by the U.S. Court of Appeals for the Second Circuit. The
Corporation’s additional contribution was not material. The District Court granted final approval of the settlement in December 2019. Beginning in January 2020, a number of class members who objected to the settlement appealed to the U.S. Court of Appeals for the Second Circuit.
LIBOR, Other Reference Rates, Foreign Exchange (FX) and Bond Trading Matters
Government authorities in the U.S. and various international jurisdictions continue to conduct investigations of, to make inquiries of, and to pursue proceedings against, the Corporation and its subsidiaries regarding FX and other reference rates as well as government, sovereign, supranational and agency bonds in connection with conduct and systems and controls. The Corporation is cooperating with these inquiries and investigations, and responding to the proceedings.
LIBOR
The Corporation, BANA and certain Merrill Lynch entities have been named as defendants along with most of the other London Interbank Offered Rate (LIBOR)LIBOR panel banks in a number of individual and putative class actions by persons alleging they sustained losses on U.S. dollar LIBOR-based financial instruments as a result of collusion or manipulation by defendants regarding the setting of U.S. dollar LIBOR. Plaintiffs assert a variety of claims, including antitrust, Commodity Exchange Act, Racketeer Influenced and Corrupt Organizations (RICO), Securities Exchange Act of 1934, common law fraud and breach of contract claims, and seek compensatory, treble and punitive damages, and injunctive relief. All but one of the cases naming the Corporation and its affiliates relating to U.S. dollar LIBOR are pending in the U.S. District Court for the Southern District of New York.
York (“District Court”). The District Court has dismissed all RICO claims, and dismissed all manipulation claims against Bank of America entities based on alleged trader conduct against Bank of America entities.conduct. The District Court has also substantially limited the scope of antitrust, Commodity Exchange Act and various other claims, including by dismissing in their entirety certain individual and putative class plaintiffs’ antitrust claims for lack of standing and/or personal jurisdiction. Plaintiffs whose antitrust claims were dismissed by the District Court are pursuing appeals in the Second Circuit. Certain individual and putative class actions remain pending in the District Court against the Corporation, BANA and certain Merrill Lynch entities.
standing. On February 28, 2018, the District Court denied certification of proposed classes of lending institutions and persons that transacted in eurodollar futures, andDecember 30, 2021, the U.S. Court of Appeals for the Second Circuit subsequently denied petitions filed by those plaintiffsaffirmed the dismissal of these antitrust claims for interlocutory appealslack of those rulings. Also onstanding. Certain individual and putative class actions remain pending against the Corporation, BANA and certain Merrill Lynch entities. On February 28, 2018, the District Court granted certification of a
class of persons that purchased OTC swaps and notes that referenced U.S. dollar LIBOR from one of the U.S. dollar LIBOR panel banks, limited to claims under Section 1 of the Sherman Act. The U.S. Court of Appeals for the Second Circuit subsequently denied a petition filed by the defendants for interlocutory appeal of that ruling.
Mortgage Appraisal Litigation
The Corporation, Countrywide and certain affiliates are named as defendants in two consolidated putative class action lawsuits filed in the U.S. District Court for the Central District of California (Waldrup and Williams, et al.). Plaintiffs allege that Countrywide and a former Countrywide subsidiary, LandSafe Appraisal Services, Inc., arranged for and completed appraisals that were not in compliance with applicable laws and appraisal standards. Plaintiffs assert a RICO claim and seek, among other forms of relief, compensatory and treble damages. On February 8, 2018,

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the District Court granted plaintiffs’ motion for class certification. On May 22, 2018, the U.S. Court of Appeals for the Ninth Circuit denied defendants’ petition for permission to file an interlocutory appeal of the District Court’s ruling granting class certification.
On January 21, 2020, the parties agreed to resolve the litigation for an amount that is not material to the Corporation, and which was fully accrued as of December 31, 2019. The agreement is subject to court approval.
U.S. Bank - Harborview and SURF/OWNIT Repurchase Litigation
Beginning in 2011, U.S. Bank, National Association (U.S. Bank), as trustee for the HarborView Mortgage Loan Trust 2005-10 and various SURF/OWNIT RMBS trusts filed complaints against the Corporation, Countrywide entities, Merrill Lynch entities and other affiliates in New York Supreme Court alleging breaches of representations and warranties. The defendants and certain certificate-holders in the trusts agreed to settle the respective matters in amounts not material to the Corporation, subject to acceptance by U.S. Bank. The litigations have been stayed pending finalization of the settlements.
NOTE 1413 Shareholders’ Equity
Common Stock
       
Declared Quarterly Cash Dividends on Common Stock (1)
       
Declaration Date Record Date Payment Date Dividend Per Share
January 29, 2020 March 6, 2020 March 27, 2020 $0.18
October 22, 2019 December 6, 2019 December 27, 2019 0.18
July 25, 2019 September 6, 2019 September 27, 2019 0.18
April 24, 2019 June 7, 2019 June 28, 2019 0.15
January 30, 2019 March 1, 2019 March 29, 2019 0.15

(1)
InDeclared Quarterly Cash Dividends on Common Stock 2019, and through February 19, 2020.(1)
Declaration DateRecord DatePayment DateDividend Per Share
February 2, 2022March 4, 2022March 25, 2022$0.21 
October 20, 2021December 3, 2021December 31, 20210.21 
July 21, 2021September 3, 2021September 24, 20210.21 
April 22, 2021June 4, 2021June 25, 20210.18 
January 19, 2021March 5, 2021March 26, 20210.18 
(1)In 2021, and through February 22, 2022.

The cash dividends paid per share of common stock were $0.78 $0.72 and $0.66 $0.54for 2021, 2020 and $0.39 for 2019, 2018 and 2017, respectively.
The following table below summarizes common stock repurchases during 2019, 20182021, 2020 and 2017.2019.
       
Common Stock Repurchase Summary
       
(in millions) 2019 2018 2017
Total share repurchases, including CCAR capital plan repurchases 956
 676
 509
       
Purchase price of shares repurchased and retired      
CCAR capital plan repurchases $25,644
 $16,754
 $9,347
Other authorized repurchases 2,500
 3,340
 3,467
   Total shares repurchased $28,144
 $20,094
 $12,814

Common Stock Repurchase Summary
(in millions)202120202019
Total share repurchases, including CCAR capital plan repurchases615 227 956 
Purchase price of shares repurchased and retired
CCAR capital plan repurchases$25,126 $7,025 $25,644 
Other authorized repurchases — 2,500 
Total shares repurchased$25,126 $7,025 $28,144 
On June 28, 2018, followingDue to uncertainty resulting from the non-objection of the Board of Governors ofpandemic, the Federal Reserve System (Federal Reserve)imposed various restrictions on share repurchase programs and dividends during 2020 and the first half of 2021. Those restrictions ended as of July 1, 2021 for large banks, including the Corporation, and large banks returned to the Corporation’s 2018 Comprehensive Capital Analysis and Review (CCAR) capital plan, the Corporation’s Board of Directors (Board) authorized the repurchase of approximately $20.6 billion in common stock from July 1, 2018 through June 30, 2019, which included approximately $600 million in repurchases to offset shares awardednormal restrictions under equity-based compensation plans during the same period. On February 7, 2019, following approval by the Federal Reserve, the Board authorized the repurchase of an additional $2.5 billion of common stock by June 30, 2019.
On June 27, 2019, following the Federal Reserve's non-objection to the Corporation's 2019 CCARReserve’s stress capital plan, the Board authorized the repurchase of approximately $30.9 billion in
common stock from July 1, 2019 through June 30, 2020, which includes approximately $900 million in repurchases to offset shares awarded under equity-based compensation plans during the same period.
During 2019, the Corporation repurchased 956 million shares of common stock in connection with the Board's 2018 and 2019 repurchase authorizations, which reduced shareholders’ equity by $28.1 billion.buffer (SCB) framework.
InDuring 2021, in connection with employee stock plans, in 2019, the Corporation issued 9168 million shares of its common stock and, to satisfy tax withholding obligations, repurchased 3526 million shares of its common stock. At December 31, 2019,2021, the Corporation had reserved 579562 million unissued shares of common stock for future issuances under employee stock plans, convertible notes and preferred stock.

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Preferred Stock
The cash dividends declared on preferred stock were $1.4 billion $1.5 billionin each of 2021, 2020 and $1.6 billion for 2019, 2018 and 2017, respectively.2019.
On June 20, 2019,January 28, 2021, the Corporation issued 40,000approximately 37,000 shares of 5.125% Fixed-to-Floating Rate4.125% Non-Cumulative Preferred Stock, Series JJPP for $1.0 billion. $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.
On June 25, 2019,October 26, 2021, the Corporation issued 55,90052,000 shares of 5.375%4.250% Non-Cumulative Preferred Stock, Series KKQQ for $1.4 billion. $1.3 billion, with quarterly dividends commencing in February 2022. The Series QQ 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 September 17, 2019,January 25, 2022, the Corporation issued 52,40070,000 shares of 5.000%4.375% Non-Cumulative Preferred Stock, Series LLRR for $1.3$1.8 billion. Additionally, onThe Series RR 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 24, 2020,31, 2022, the Corporation issued 44,00028,000 shares of 4.300% Fixed-to-Floating Rate4.75% Non-Cumulative Preferred Stock, Series MMSS for $1.1 billion.$700 million. The Series SS 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 2019,2021, the Corporation fully redeemed Series VCC, Series EE and Series WT preferred stock at their liquidation preference values for $2.6 billion. Additionally, on January 27, 2020, the Corporation fully redeemed Series Y preferred stock for $1.1a total of $2.0 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 TG Preferred Stock, if any dividend payable on these series is in arrears for 3 or more semi-annual or 6 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 2 additional directors. These voting rights terminate when the Corporation has paid in full dividends on these series for at least 2 semi-annual or 4 quarterly dividend periods, as applicable, following the dividend arrearage.
The 7.25% Non-Cumulative Perpetual Convertible Preferred Stock, Series L (Series L Preferred Stock) does not have early redemption/call rights. Each share of the Series L Preferred Stock may be converted at any time, at the option of the holder, into 20 shares of the Corporation’s common stock plus cash in lieu of fractional shares. The Corporation may cause some or all of the Series L Preferred Stock, at its option, at any time or from time to time, to be converted into shares of common stock at the then-applicable conversion rate if, for 20 trading days during any period

Bank of America 134


of 30 consecutive trading days, the closing price of common stock exceeds 130 percent of the then-applicable conversion price of the Series L Preferred Stock. If a conversion of Series L Preferred Stock occurs at the option of the holder, subsequent to a dividend
record date but prior to the dividend payment date, the Corporation will still pay any accrued dividends payable.
139 Bank of America


The table below presents a summary of perpetual preferred stock outstanding at December 31, 2019.
2021.
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)
1.01 13 On or after
November 15, 2011
Series FFloating Rate Non-CumulativeMarch
2012
1,409 100,000 141 
3-mo. LIBOR + 40 bps (3)
4,055.55 On or after
March 15, 2012
Series GAdjustable Rate Non-CumulativeMarch
2012
4,926 100,000 493 
3-mo. LIBOR + 40 bps (3)
4,055.55 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 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 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 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 %43.00 47 On or after
January 28, 2025
Series NN (2)
4.375% Non-CumulativeOctober
2020
44,000 25,000 1,100 4.375 %1.09 48 On or after
November 3, 2025
Series PP (2)
4.125% Non-Cumulative4.125%January 202136,600 25,000 915 4.125 %1.04 38 On or after
February 2, 2026
Series QQ (2)
4.250% Non-Cumulative4.250%October 202152,000 25,000 1,300 4.250 %— — On or after
November 17, 2026
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 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)
1.01 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)
1.01 17 On or after
May 21, 2012
Issuance costs and certain adjustments(330)
Total  3,939,686  $24,708   
                  
Preferred Stock Summary              
                  
(Dollars in millions, except as noted)                
SeriesDescription Initial
Issuance
Date
 Total
Shares
Outstanding
 Liquidation
Preference
per Share
(in dollars)
 Carrying
Value
 Per Annum
Dividend Rate
 
Dividend per Share
(in dollars)
 Annual Dividend 
Redemption Period (1)
Series B7% Cumulative Redeemable June
1997
 7,110
 $100
 $1
 7.00% $7.00
 $
 n/a
Series E (2)
Floating Rate Non-Cumulative November
2006
 12,691
 25,000
 317
 
3-mo. LIBOR + 35 bps (3)

 1.01
 13
 On or after
November 15, 2011
Series FFloating Rate Non-Cumulative March
2012
 1,409
 100,000
 141
 
3-mo. LIBOR + 40 bps (3)

 4,055.56
 6
 On or after
March 15, 2012
Series GAdjustable Rate Non-Cumulative March
2012
 4,926
 100,000
 493
 
3-mo. LIBOR + 40 bps (3)

 4,055.56
 20
 On or after
March 15, 2012
Series L7.25% Non-Cumulative Perpetual Convertible January
2008
 3,080,182
 1,000
 3,080
 7.25% 72.50
 223
 n/a
Series T6% Non-cumulative September
2011
 354
 100,000
 35
 6.00% 6,000.00
 2
 After May 7, 2019
Series U (4)
Fixed-to-Floating Rate Non-Cumulative May
2013
 40,000
 25,000
 1,000
 5.2% to, but excluding, 6/1/23; 3-mo. LIBOR + 313.5 bps thereafter
 52.00
 52
 On or after
June 1, 2023
Series X (4)
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
 62.50
 125
 On or after
September 5, 2024
Series Y (2)
6.500% Non-Cumulative January 2015 44,000
 25,000
 1,100
 6.500% 1.63
 72
 On or after
January 27, 2020
Series Z (4)
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
 65.00
 91
 On or after
October 23, 2024
Series AA (4)
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
 61.00
 116
 On or after
March 17, 2025
Series CC (2)
6.200% Non-Cumulative January 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-Cumulative March 2016 40,000
 25,000
 1,000
 6.300% to, but excluding, 3/10/26; 3-mo. LIBOR + 455.3 bps thereafter
 63.00
 63
 On or after
March 10, 2026
Series EE (2)
6.000% Non-Cumulative April 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-Cumulative March 2018 94,000
 25,000
 2,350
 5.875% to, but excluding, 3/15/28; 3-mo. LIBOR + 293.1 bps thereafter
 58.75
 138
 On or after
March 15, 2028
Series GG (2)
6.000% Non-Cumulative May
2018
 54,000
 25,000
 1,350
 6.000% 1.50
 81
 On or after
May 16, 2023
Series HH (2)
5.875% Non-Cumulative July
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-Cumulative June
2019
 40,000
 25,000
 1,000
 5.125% to, but excluding, 6/20/24; 3-mo. LIBOR + 329.2 bps thereafter
 25.63
 26
 On or after
June 20, 2024
Series KK (2)
5.375% Non-Cumulative June
2019
 55,900
 25,000
 1,398
 5.375% 0.67
 38
 On or after
June 25, 2024
Series LL (2)
5.000% Non-Cumulative September
2019
 52,400
 25,000
 1,310
 5.000% 0.31
 16
 On or after
September 17, 2024
Series 1 (5)
Floating Rate Non-Cumulative November
2004
 3,275
 30,000
 98
 
3-mo. LIBOR + 75 bps (6)

 0.82
 3
 On or after
November 28, 2009
Series 2 (5)
Floating Rate Non-Cumulative March
2005
 9,967
 30,000
 299
 
3-mo. LIBOR + 65 bps (6)

 0.81
 10
 On or after
November 28, 2009
Series 4 (5)
Floating Rate Non-Cumulative November
2005
 7,010
 30,000
 210
 
3-mo. LIBOR + 75 bps (3)

 1.01
 9
 On or after
November 28, 2010
Series 5 (5)
Floating Rate Non-Cumulative March
2007
 14,056
 30,000
 422
 
3-mo. LIBOR + 50 bps (3)

 1.01
 17
 On or after
May 21, 2012
Issuance costs and certain adjustments     (357)        
Total    3,887,440
  
 $23,401
  
      

(1)
The Corporation may redeem series of preferred stock on or after the redemption date, in whole or in part, at its option, at the liquidation preference plus declared and unpaid dividends. Series B and Series L Preferred Stock do not have early redemption/call rights.
(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%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.
(4)
Ownership is held in the form of depositary shares, each representing a 1/25th interest in a share of preferred stock, paying a semi-annual cash dividend, if and when declared, until the first redemption date at which time, it adjusts to a quarterly cash dividend, if and when declared, thereafter.
(5)
Ownership is held in the form of depositary shares, each representing a 1/1,200th interest in a share of preferred stock, paying a quarterly cash dividend, if and when declared.
(6)
Subject to 3.00% minimum rate per annum.
n/a = not applicable

135Bank of America140







NOTE 1514 Accumulated Other Comprehensive Income (Loss)
The table below presents the changes in accumulated OCI after-tax for 2019, 20182021, 2020 and 2017.2019.
            
(Dollars in millions)Debt Securities Debit Valuation Adjustments Derivatives 
Employee
Benefit Plans
 
Foreign
Currency
 Total
Balance, December 31, 2016$(1,267) $(767) $(895) $(3,480) $(879) $(7,288)
Net change61
 (293) 64
 288
 86
 206
Balance, December 31, 2017$(1,206) $(1,060) $(831) $(3,192) $(793) $(7,082)
Accounting change related to certain tax effects(393) (220) (189) (707) 239
 (1,270)
Cumulative adjustment for hedge accounting change
 
 57
 
 
 57
Net change(3,953) 749
 (53) (405) (254) (3,916)
Balance, December 31, 2018$(5,552) $(531) $(1,016) $(4,304) $(808) $(12,211)
Net change5,875
 (963) 616
 136
 (86) 5,578
Balance, December 31, 2019$323
 $(1,494) $(400) $(4,168) $(894) $(6,633)

(Dollars in millions)Debt SecuritiesDebit Valuation AdjustmentsDerivativesEmployee
Benefit Plans
Foreign
Currency
Total
Balance, December 31, 2018$(5,552)$(531)$(1,016)$(4,304)$(808)$(12,211)
Net change5,875 (963)616 136 (86)5,578 
Balance, December 31, 2019$323 $(1,494)$(400)$(4,168)$(894)$(6,633)
Net change4,799 (498)826 (98)(52)4,977 
Balance, December 31, 2020$5,122 $(1,992)$426 $(4,266)$(946)$(1,656)
Net change(2,077)356 (2,306)624 (45)(3,448)
Balance, December 31, 2021$3,045 $(1,636)$(1,880)$(3,642)$(991)$(5,104)
The table below presents the net change in fair value recorded in accumulated OCI, net realized gains and losses reclassified into earnings and other changes for each component of OCI pre- and after-tax for 2019, 20182021, 2020 and 2017.2019.
PretaxTax
effect
After-
tax
PretaxTax
effect
After-
tax
PretaxTax effectAfter-
tax
(Dollars in millions)202120202019
Debt securities:
Net increase (decrease) in fair value$(2,749)$689 $(2,060)$6,819 $(1,712)$5,107 $8,020 $(2,000)$6,020 
Net realized gains reclassified into earnings (1)
(22)5 (17)(411)103 (308)(193)48 (145)
Net change(2,771)694 (2,077)6,408 (1,609)4,799 7,827 (1,952)5,875 
Debit valuation adjustments:
Net increase (decrease) in fair value449 (103)346 (669)156 (513)(1,276)289 (987)
Net realized losses reclassified into earnings (1)
13 (3)10 19 (4)15 18 24 
Net change462 (106)356 (650)152 (498)(1,258)295 (963)
Derivatives:
Net increase (decrease) in fair value(2,849)703 (2,146)1,098 (268)830 692 (156)536 
Reclassifications into earnings:
Net interest income(166)48 (118)(1)104 (26)78 
Compensation and benefits expense(55)13 (42)(12)(9)— 
Net realized (gains) losses reclassified into earnings(221)61 (160)(6)(4)106 (26)80 
Net change(3,070)764 (2,306)1,092 (266)826 798 (182)616 
Employee benefit plans:
Net increase (decrease) in fair value463 (72)391 (381)80 (301)41 (21)20 
Net actuarial losses and other reclassified into earnings (2)
295 (67)228 261 (63)198 150 (36)114 
Settlements, curtailments and other5  5 — (1)
Net change763 (139)624 (115)17 (98)194 (58)136 
Foreign currency:
Net increase (decrease) in fair value296 (341)(45)(251)199 (52)(13)(52)(65)
Net realized (gains) reclassified into earnings (1)
(5)5  (1)— (110)89 (21)
Net change291 (336)(45)(252)200 (52)(123)37 (86)
Total other comprehensive income (loss)$(4,325)$877 $(3,448)$6,483 $(1,506)$4,977 $7,438 $(1,860)$5,578 
                  
 Pretax 
Tax
effect
 
After-
tax
 Pretax 
Tax
effect
 
After-
tax
 Pretax Tax effect 
After-
tax
(Dollars in millions)2019 2018 2017
Debt securities:                 
Net increase (decrease) in fair value$8,020
 $(2,000) $6,020
 $(5,189) $1,329
 $(3,860) $240
 $14
 $254
Net realized (gains) reclassified into earnings (1)
(193) 48
 (145) (123) 30
 (93) (304) 111
 (193)
Net change7,827
 (1,952) 5,875
 (5,312) 1,359
 (3,953) (64) 125
 61
Debit valuation adjustments:                 
Net increase (decrease) in fair value(1,276) 289
 (987) 952
 (224) 728
 (490) 171
 (319)
Net realized losses reclassified into earnings (1)
18
 6
 24
 26
 (5) 21
 42
 (16) 26
Net change(1,258) 295
 (963) 978
 (229) 749
 (448) 155
 (293)
Derivatives:                 
Net increase (decrease) in fair value692
 (156) 536
 (232) 74
 (158) (50) 1
 (49)
Reclassifications into earnings:                 
Net interest income104
 (26) 78
 165
 (40) 125
 327
 (122) 205
Compensation and benefits expense2
 
 2
 (27) 7
 (20) (148) 56
 (92)
Net realized losses reclassified into earnings106
 (26) 80
 138
 (33) 105
 179
 (66) 113
Net change798
 (182) 616
 (94) 41
 (53) 129
 (65) 64
Employee benefit plans:                 
Net increase (decrease) in fair value41
 (21) 20
 (703) 164
 (539) 223
 (55) 168
Net actuarial losses and other reclassified into earnings (2)
150
 (36) 114
 171
 (46) 125
 179
 (61) 118
Settlements, curtailments and other3
 (1) 2
 11
 (2) 9
 3
 (1) 2
Net change194
 (58) 136
 (521) 116
 (405) 405
 (117) 288
Foreign currency:                 
Net (decrease) in fair value(13) (52) (65) (8) (195) (203) (439) 430
 (9)
Net realized (gains) losses reclassified into earnings (3)
(110) 89
 (21) (149) 98
 (51) (606) 701
 95
Net change(123) 37
 (86) (157) (97) (254) (1,045) 1,131
 86
Total other comprehensive income (loss)$7,438
 $(1,860) $5,578
 $(5,106) $1,190
 $(3,916) $(1,023) $1,229
 $206
(1)    Reclassifications of pretax debt securities, DVA and foreign currency (gains) losses are recorded in other income in the Consolidated Statement of Income.
(1)
(2)    Reclassifications of pretax employee benefit plan costs are recorded in other general operating expense in the Consolidated Statement of Income.
Reclassifications of pretax debt securities and DVA are recorded in other income in the Consolidated Statement of Income.
(2)
Reclassifications of pretax employee benefit plan costs are recorded in other general operating expense in the Consolidated Statement of Income.
(3)
Reclassifications of pretax debt securities, DVA and foreign currency (gains) losses are recorded in other income in the Consolidated Statement of Income.

Bank of America 136


NOTE 1615 Earnings Per Common Share
The calculation of EPS and diluted EPS for 2019, 20182021, 2020 and 20172019 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)202120202019
Earnings per common share 
Net income$31,978 $17,894 $27,430 
Preferred stock dividends(1,421)(1,421)(1,432)
Net income applicable to common shareholders$30,557 $16,473 $25,998 
Average common shares issued and outstanding8,493.3 8,753.2 9,390.5 
Earnings per common share$3.60 $1.88 $2.77 
Diluted earnings per common share  
Net income applicable to common shareholders$30,557 $16,473 $25,998 
Average common shares issued and outstanding8,493.3 8,753.2 9,390.5 
Dilutive potential common shares (1)
65.1 43.7 52.4 
Total diluted average common shares issued and outstanding8,558.4 8,796.9 9,442.9 
Diluted earnings per common share$3.57 $1.87 $2.75 
(1)Includes incremental dilutive shares from preferred stock, RSUs, restricted stock and warrants.

      
(In millions, except per share information)2019 2018 2017
Earnings per common share   
  
Net income$27,430
 $28,147
 $18,232
Preferred stock dividends(1,432) (1,451) (1,614)
Net income applicable to common shareholders$25,998
 $26,696
 $16,618
Average common shares issued and outstanding9,390.5
 10,096.5
 10,195.6
Earnings per common share$2.77
 $2.64
 $1.63
      
Diluted earnings per common share 
  
  
Net income applicable to common shareholders$25,998
 $26,696
 $16,618
Add preferred stock dividends due to assumed conversions (1)

 
 186
Net income allocated to common shareholders$25,998
 $26,696
 $16,804
Average common shares issued and outstanding9,390.5
 10,096.5
 10,195.6
Dilutive potential common shares (2)
52.4
 140.4
 582.8
Total diluted average common shares issued and outstanding9,442.9
 10,236.9
 10,778.4
Diluted earnings per common share$2.75
 $2.61
 $1.56
(1)141 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.
For 2019, 20182021, 2020 and 2017,2019, 62 million average dilutive potential common shares associated with the Series L preferred stock were not included in the diluted share count because the result would have been antidilutive under the “if-converted” method. For 2018 and 2017, average options to purchase 4000000 and 21 million shares of common stock were outstanding but not included in the computation of EPS because the result would have been antidilutive under the treasury stock method. For 2017, average warrants to purchase 122 million shares of common stock were outstanding but not included in the computation of EPS because the result would have been antidilutive under the treasury stock method. These warrants expired on October 29, 2018. For 2019, 2018 and 2017, average warrants to purchase 3000000 136 million and 143 million shares of common stock, respectively, were included in the diluted EPS calculation under the treasury stock method. Substantially all of these warrants were exercised on or before their expiration date of January 16, 2019.
NOTE 1716 Regulatory Requirements and Restrictions
The Federal Reserve, Office of the Comptroller of the Currency (OCC) and FDIC (collectively, U.S. banking regulators) jointly establish regulatory capital adequacy guidelines,rules, including Basel 3, for U.S. banking organizations. As a financial holding company, the Corporation is subject to capital adequacy rules issued by the
Federal Reserve. The Corporation’s banking entity affiliates are subject to capital adequacy rules issued by the OCC.
The Corporation and its primary banking entity affiliate, BANA, are Advanced approaches institutions under Basel 3. As Advanced approaches institutions, the Corporation and its banking entity affiliates are required to report regulatory risk-based capital ratios and risk-weighted assets under both the Standardized and Advanced approaches. The approach that yields the lower ratio is used to assess capital adequacy, including under the Prompt Corrective Action (PCA) framework. At December 31, 2019 and 2018, Common equity tier 1 and Tier 1 capital ratios were lower under the Standardized approach whereas the Advanced approaches yielded a lower result for the Total capital ratio.
The Corporation is required to maintain a minimum supplementary leverage ratio (SLR) of 3.0 percent plus a leverage buffer of 2.0 percent in order to avoid certain restrictions on capital distributions and discretionary bonus payments. The Corporation’s insured depository institution subsidiaries are required to maintain a minimum 6.0 percent SLR to be considered well capitalized under the PCA framework.
The following table below presents capital ratios and related information in accordance with Basel 3 Standardized and Advanced approaches as measured at December 31, 20192021 and 20182020 for the Corporation and BANA.

Regulatory Capital under Basel 3
Bank of America CorporationBank of America, N.A.
Standardized Approach (1)
Advanced Approaches (1)
Regulatory Minimum (2)
Standardized Approach (1)
Advanced Approaches (1)
Regulatory Minimum (3)
(Dollars in millions, except as noted)December 31, 2021
Risk-based capital metrics:  
Common equity tier 1 capital$171,759 $171,759 $182,526 $182,526 
Tier 1 capital196,465 196,465 182,526 182,526 
Total capital (4)
227,592 220,616 194,773 188,091 
Risk-weighted assets (in billions)1,618 1,399 1,352 1,048 
Common equity tier 1 capital ratio10.6 %12.3 %9.5 %13.5 %17.4 %7.0 %
Tier 1 capital ratio12.1 14.0 11.0 13.5 17.4 8.5 
Total capital ratio14.1 15.8 13.0 14.4 17.9 10.5 
Leverage-based metrics:
Adjusted quarterly average assets (in billions) (5)
$3,087 $3,087 $2,414 $2,414 
Tier 1 leverage ratio6.4 %6.4 %4.0 7.6 %7.6 %5.0 
Supplementary leverage exposure (in billions) (6)
$3,604 $2,824 
Supplementary leverage ratio5.5 %5.0 6.5 %6.0 
 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 (4)
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) (5)
$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) (6)
$2,786 $2,525 
Supplementary leverage ratio7.2 %5.0 6.5 %6.0 
(1)As of December 31, 2021 and 2020, capital ratios are calculated using the regulatory capital rule that allows a five-year transition period related to the adoption of the CECL accounting standard.
(2)The capital conservation buffer and global systemically important bank (G-SIB) surcharge were 2.5 percent at both December 31, 2021 and 2020. At December 31, 2021 and 2020 the Corporation's stress capital buffer of 2.5 percent was applied in place of the capital conservation buffer under the Standardized approach. The countercyclical capital buffer for both periods was zero. The CET1 capital regulatory minimum is the sum of the CET1 capital ratio minimum of 4.5 percent, the Corporation’s G-SIB surcharge of 2.5 percent and the Corporation’s SCB or the capital conservation buffer, as applicable, of 2.5 percent. The SLR regulatory minimum includes a leverage buffer of 2.0 percent.
(3)Risk-based capital regulatory minimums at December 31, 2021 and 2020 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.
(6)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. The temporary relief expired after March 31, 2021 and is not reflected in supplementary leverage exposure at December 31, 2021.

137Bank of America






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

Standardized Approach Advanced Approaches 
Regulatory Minimum (1)
 Standardized Approach Advanced Approaches 
Regulatory Minimum (2)
(Dollars in millions, except as noted)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 (3)
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) (4)
$2,374
 $2,374
   $1,780
 $1,780
  
Tier 1 leverage ratio7.9% 7.9% 4.0
 8.7% 8.7% 5.0
            
SLR leverage exposure (in billions)  $2,946
     $2,177
  
SLR  6.4% 5.0
   7.1% 6.0
            
 December 31, 2018
Risk-based capital metrics: 
  
    
  
  
Common equity tier 1 capital$167,272
 $167,272
   $149,824
 $149,824
  
Tier 1 capital189,038
 189,038
   149,824
 149,824
  
Total capital (3)
221,304
 212,878
   161,760
 153,627
  
Risk-weighted assets (in billions)1,437
 1,409
   1,195
 959
  
Common equity tier 1 capital ratio11.6% 11.9% 8.25% 12.5% 15.6% 6.5%
Tier 1 capital ratio13.2
 13.4
 9.75
 12.5
 15.6
 8.0
Total capital ratio15.4
 15.1
 11.75
 13.5
 16.0
 10.0
            
Leverage-based metrics:           
Adjusted quarterly average assets (in billions) (4)
$2,258
 $2,258
   $1,719
 $1,719
  
Tier 1 leverage ratio8.4% 8.4% 4.0
 8.7% 8.7% 5.0
            
SLR leverage exposure (in billions)  $2,791
     $2,112
  
SLR  6.8% 5.0
   7.1% 6.0
(1)
The capital conservation buffer and global systemically important bank surcharge were 2.5 percent at December 31, 2019 and 1.875 percent at December 31, 2018. The countercyclical capital buffer for both periods was 0. The SLR minimum includes a leverage buffer of 2.0 percent.142
(2)


Risk-based capital regulatory minimums at December 31, 2019 are the minimum ratios under Basel 3 including a capital conservation buffer of 2.5 percent. The regulatory minimums for the leverage ratios as of both period ends and risk-based capital ratios as of December 31, 2018 are the percent required to be considered well capitalized under the PCA framework.
(3)
Total capital under the Advanced approaches differs from the Standardized approach due to differences in the amount permitted in Tier 2 capital related to the qualifying allowance for credit losses.
(4)
Reflects total average assets adjusted for certain Tier 1 capital deductions.
The capital adequacy rules issued by the U.S. banking regulators require institutions to meet the established minimums outlined in the table above. Failure to meet the minimum requirements can lead to certain mandatory and discretionary actions by regulators that could have a material adverse impact on the Corporation’s financial position. At December 31, 20192021 and 2018,2020, the Corporation and its banking entity affiliates were well capitalized.
Due to uncertainty from the pandemic, the Federal Reserve imposed various restrictions on share repurchase programs and dividends during 2020 and the first half of 2021. In conjunction with its release of 2021 CCAR supervisory stress test results, the Federal Reserve announced those restrictions would end as of July 1, 2021 for large banks, including the Corporation, and large banks would be subject to the normal restrictions under the Federal Reserve’s SCB framework. 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 $14.6 billion$0 for 2021 and $11.4$3.8 billion for 2019 and 2018.2020. At December 31, 20192021 and 2018,2020, the Corporation had cash and cash equivalents in the amount of $6.3$4.0 billion and $5.8$4.9 billion, and securities with a fair value of $14.7$10.6 billion and $16.6$16.8 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 1110 Federal Funds Sold or Purchased, Securities Financing Agreements, Short-term Borrowings and Restricted Cash. In
addition, at December 31, 20192021 and 2018,2020, the Corporation had cash deposited with clearing organizations of $7.6$28.6 billion and $8.1$10.9 billion primarily recorded in other assets on the Consolidated Balance Sheet.
Bank Subsidiary Distributions
The primary sources of funds for cash distributions by the Corporation to its shareholders are capital distributions received from its bank subsidiaries, BANA and Bank of America California, N.A. In 2019,2021, the Corporation received dividends of $20.5$15.6 billion from BANA and $215$29 million from Bank of America California, N.A. In addition, BANA returned capital of $8.0 billion to the Corporation in 2019.
The amount of dividends that a subsidiary bank may declare in a calendar year without OCC approval is the subsidiary bank’s net profits for that year combined with its retained net profits for the preceding two years. Retained net profits, as defined by the OCC, consist of net income less dividends declared during the period. In 2020,2022, BANA can declare and pay dividends of approximately $9.4$14.7 billion to the Corporation plus an additional amount equal to its retained net profits for 20202022 up to the date of any such dividend declaration. Bank of America California, N.A. can pay dividends of $94$234 million in 20202022 plus an additional amount equal to its retained net profits for 20202022 up to the date of any such dividend declaration.


Bank of America 138


NOTE 1817 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 0no contribution under this agreement in 20192021 or 2018.2020. Contributions may be required in the future under this agreement.
The Corporation’s noncontributory, nonqualified pension plans are unfunded and provide supplemental defined pension benefits to certain eligible employees.
In addition to retirement pension benefits, certain benefits-eligible employees may become eligible to continue participation as retirees in health care and/or life insurance plans sponsored by the Corporation. These plans are referred to as the Postretirement Health and Life Plans.
The Pension and Postretirement Plans table summarizes the changes in the fair value of plan assets, changes in the projected benefit obligation (PBO), the funded status of both the accumulated benefit obligation (ABO) and the PBO, and the weighted-average assumptions used to determine benefit obligations for the pension plans and postretirement plans at December 31, 20192021 and 2018.2020. The estimate of the Corporation’s PBO associated with these plans considers various actuarial assumptions, including assumptions for mortality rates and discount rates. The discount rate assumptions are derived from a cash flow matching technique that utilizes rates that are based on Aa-rated corporate bonds with cash flows that match estimated benefit payments of each of the plans. The increases in the weighted-average discount rates in 2021 resulted in a decrease to the PBO of $895 million at December 31, 2021. The decreases in the weighted-average discount rates in 20192020 resulted in increasesan increase to the PBO of approximately $2.2$1.9 billion at December 31, 2019. The increases in the weighted-average discount rates in 2018 resulted in decreases to the PBO of approximately $1.3 billion at December 31, 2018.2020. Significant gains and losses related to changes in the PBO for 20192021 and 20182020 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)2019 2018 2019 2018 2019 2018 2019 2018
Fair value, January 1$18,178
 $19,708
 $2,461
 $2,943
 $2,584
 $2,724
 $252
 $300
Actual return on plan assets3,187
 (550) 273
 (181) 228
 8
 5
 5
Company contributions
 
 20
 22
 91
 91
 24
 43
Plan participant contributions
 
 1
 1
 
 
 103
 115
Settlements and curtailments
 
 (42) (107) 
 
 
 
Benefits paid(1,090) (980) (108) (52) (237) (239) (185) (214)
Federal subsidy on benefits paid n/a
  n/a
  n/a
  n/a
  n/a
  n/a
 
 3
Foreign currency exchange rate changes n/a
  n/a
 91
 (165)  n/a
  n/a
  n/a
  n/a
Fair value, December 31$20,275
 $18,178
 $2,696
 $2,461
 $2,666
 $2,584
 $199
 $252
Change in projected benefit obligation 
  
  
  
  
  
  
  
Projected benefit obligation, January 1$14,144
 $15,706
 $2,589
 $2,814
 $2,779
 $3,047
 $928
 $1,056
Service cost
 
 17
 19
 1
 1
 5
 6
Interest cost593
 563
 65
 65
 113
 105
 38
 36
Plan participant contributions
 
 1
 1
 
 
 103
 115
Plan amendments
 
 2
 13
 
 
 
 
Settlements and curtailments
 
 (42) (107) 
 
 
 
Actuarial loss (gain)1,714
 (1,145) 288
 (29) 263
 (135) 99
 (73)
Benefits paid(1,090) (980) (108) (52) (237) (239) (185) (214)
Federal subsidy on benefits paid n/a
  n/a
  n/a
  n/a
  n/a
  n/a
 
 3
Foreign currency exchange rate changes n/a
  n/a
 75
 (135)  n/a
  n/a
 1
 (1)
Projected benefit obligation, December 31$15,361
 $14,144
 $2,887
 $2,589
 $2,919
 $2,779
 $989
 $928
Amounts recognized on Consolidated Balance Sheet               
Other assets$4,914
 $4,034
 $364
 $316
 $733
 $754
 $
 $
Accrued expenses and other liabilities
 
 (555) (444) (986) (949) (790) (676)
Net amount recognized, December 31$4,914
 $4,034
 $(191) $(128) $(253) $(195) $(790) $(676)
Funded status, December 31 
  
  
  
  
  
  
  
Accumulated benefit obligation$15,361
 $14,144
 $2,841
 $2,542
 $2,919
 $2,778
  n/a
 n/a
Overfunded (unfunded) status of ABO4,914
 4,034
 (145) (81) (253) (194)  n/a
 n/a
Provision for future salaries
 
 46
 47
 
 1
  n/a
 n/a
Projected benefit obligation15,361
 14,144
 2,887
 2,589
 2,919
 2,779
 $989
 $928
Weighted-average assumptions, December 31 
  
  
  
  
  
  
  
Discount rate3.32% 4.32% 1.81% 2.60% 3.20% 4.26% 3.27% 4.25%
Rate of compensation increase n/a
  n/a
 4.10
 4.49
 4.00
 4.00
  n/a
 n/a
Interest-crediting rate5.06
 5.18
 1.53
 1.47
 4.52
 4.50
 n/a
 n/a
(1)
The measurement date for all of the above plans was December 31 of each year reported.
n/a = not applicable

139143 Bank of America




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)20212020202120202021202020212020
Fair value, January 1$21,776 $20,275 $3,078 $2,696 $2,789 $2,666 $143 $199 
Actual return on plan assets1,215 2,468 62 379 (55)285  
Company contributions — 24 23 87 86 38 
Plan participant contributions — 1  — 107 110 
Settlements and curtailments — (11)(61) —  — 
Benefits paid(913)(967)(84)(57)(236)(248)(171)(174)
Federal subsidy on benefits paid n/an/a n/an/a n/an/a 
Foreign currency exchange rate changes n/an/a(39)97  n/an/a n/an/a
Fair value, December 31$22,078 $21,776 $3,031 $3,078 $2,585 $2,789 $117 $143 
Change in projected benefit obligation        
Projected benefit obligation, January 1$16,427 $15,361 $3,340 $2,887 $3,005 $2,919 $1,007 $989 
Service cost — 28 20  5 
Interest cost414 500 45 49 67 90 24 32 
Plan participant contributions — 1  — 107 110 
Plan amendments —   —  — 
Settlements and curtailments ��� (11)(61) —  — 
Actuarial loss (gain)(252)1,533 (152)396 (83)243 (44)43 
Benefits paid(913)(967)(84)(57)(236)(248)(171)(173)
Federal subsidy on benefits paid n/an/a n/an/a n/an/a 
Foreign currency exchange rate changes n/an/a(51)102  n/an/a — 
Projected benefit obligation, December 31$15,676 $16,427 $3,116 $3,340 $2,753 $3,005 $928 $1,007 
Amounts recognized on Consolidated Balance Sheet
Other assets$6,402 $5,349 $550 $428 $777 $812 $ $— 
Accrued expenses and other liabilities — (635)(690)(945)(1,028)(811)(864)
Net amount recognized, December 31$6,402 $5,349 $(85)$(262)$(168)$(216)$(811)$(864)
Funded status, December 31        
Accumulated benefit obligation$15,676 $16,427 $3,031 $3,253 $2,753 $3,005  n/an/a
Overfunded (unfunded) status of ABO6,402 5,349  (175)(168)(216) n/an/a
Provision for future salaries — 85 87  —  n/an/a
Projected benefit obligation15,676 16,427 3,116 3,340 2,753 3,005 $928 $1,007 
Weighted-average assumptions, December 31        
Discount rate2.86 %2.57 %1.85 %1.37 %2.80 %2.33 %2.85 %2.48 %
Rate of compensation increasen/an/a4.46 4.11 4.00 4.00 n/an/a
Interest-crediting rate4.83 %5.02 %1.90 1.58 4.22 4.49  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 20202022 is $21$30 million, $92$91 million and $15$42 million, respectively. The Corporation does not expect to make a contribution to the Qualified Pension Plan in 2020.2022. 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, 20192021 and 20182020 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)2021202020212020
PBO$841 $900 $945 $1,028 
ABO780 841 945 1,028 
Fair value of plan assets207 211 1 
        
Plans with ABO and PBO in Excess of Plan Assets       
        
 
Non-U.S.
Pension Plans
 
Nonqualified
and Other
Pension Plans
(Dollars in millions)2019 2018 2019 2018
PBO$744
 $615
 $988
 $950
ABO720
 605
 988
 949
Fair value of plan assets191
 173
 1
 1
Bank of America 144


            
Components of Net Periodic Benefit Cost           
            
 Qualified Pension Plan Non-U.S. Pension Plans
(Dollars in millions)2019 2018 2017 2019 2018 2017
Components of net periodic benefit cost (income)           
Service cost$
 $
 $
 $17
 $19
 $24
Interest cost593
 563
 606
 65
 65
 72
Expected return on plan assets(1,088) (1,136) (1,068) (99) (126) (136)
Amortization of net actuarial loss135
 147
 154
 6
 10
 8
Other
 
 
 4
 12
 (7)
Net periodic benefit cost (income)$(360) $(426) $(308) $(7) $(20) $(39)
Weighted-average assumptions used to determine net cost for years ended December 31 
  
  
  
  
  
Discount rate4.32% 3.68% 4.16% 2.60% 2.39% 2.56%
Expected return on plan assets6.00
 6.00
 6.00
 4.13
 4.37
 4.73
Rate of compensation increase n/a
 n/a
 n/a
 4.49
 4.31
 4.51
            
 Nonqualified and
Other Pension Plans
 Postretirement Health
and Life Plans
(Dollars in millions)2019 2018 2017 2019 2018 2017
Components of net periodic benefit cost (income)           
Service cost$1
 $1
 $1
 $5
 $6
 $6
Interest cost113
 105
 117
 38
 36
 43
Expected return on plan assets(95) (84) (95) (5) (6) 
Amortization of net actuarial loss (gain)34
 43
 34
 (24) (27) (21)
Other
 
 
 (2) (3) 4
Net periodic benefit cost (income)$53
 $65
 $57
 $12
 $6
 $32
Weighted-average assumptions used to determine net cost for years ended December 31 
  
  
  
  
  
Discount rate4.26% 3.58% 4.01% 4.25% 3.58% 3.99%
Expected return on plan assets3.73
 3.19
 3.50
 2.00
 2.00
  n/a
Rate of compensation increase4.00
 4.00
 4.00
  n/a
  n/a
  n/a

Components of Net Periodic Benefit Cost
 Qualified Pension PlanNon-U.S. Pension Plans
(Dollars in millions)202120202019202120202019
Components of net periodic benefit cost (income)
Service cost$ $— $— $28 $20 $17 
Interest cost414 500 593 45 49 65 
Expected return on plan assets(1,173)(1,154)(1,088)(70)(66)(99)
Amortization of net actuarial loss193 173 135 19 
Other — — 5 
Net periodic benefit cost (income)$(566)$(481)$(360)$27 $20 $(7)
Weighted-average assumptions used to determine net cost for years ended December 31      
Discount rate2.57 %3.32 %4.32 %1.35 %1.81 %2.60 %
Expected return on plan assets5.75 6.00 6.00 2.30 2.57 4.13 
Rate of compensation increase n/an/an/a4.11 4.10 4.49 
Nonqualified and
Other Pension Plans
Postretirement Health
and Life Plans
(Dollars in millions)202120202019202120202019
Components of net periodic benefit cost (income)
Service cost$ $$$5 $$
Interest cost67 90 113 24 32 38 
Expected return on plan assets(49)(71)(95)(3)(4)(5)
Amortization of net actuarial loss (gain)63 50 34 20 29 (24)
Other — —  (2)(2)
Net periodic benefit cost (income)$81 $70 $53 $46 $60 $12 
Weighted-average assumptions used to determine net cost for years ended December 31      
Discount rate2.33 %3.20 %4.26 %2.48 %3.27 %4.25 %
Expected return on plan assets1.88 2.77 3.73 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 year (or at subsequent remeasurement) is recognized on a level basis during the year.
Assumed health care cost trend rates affect the postretirement benefit obligation and benefit cost reported for the Postretirement Health and Life Plans. The assumed health care cost trend rate used to measure the expected cost of benefits covered by the Postretirement Health and Life Plans is 6.506.25 percent for 2020,2022, reducing in steps to 5.00 percent in 20262027 and later years.
The Corporation’s net periodic benefit cost (income) recognized for the plans is sensitive to the discount rate and expected return on plan assets. For the Qualified Pension Plan, Non-U.S. Pension Plans, Nonqualified and Other Pension Plans, and Postretirement Health and Life Plans, a 25 bp decline in discount rates and expected return on assets would not have had a significant impact on the net periodic benefit cost for 2019.2021.

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)2021202020212020202120202021202020212020
Net actuarial loss (gain)$3,425 $3,912 $456 $628 $945 $987 $4 $66 $4,830 $5,593 
Prior service cost (credits) — 17 18  — (3)(4)14 14 
Amounts recognized in accumulated OCI$3,425 $3,912 $473 $646 $945 $987 $1 $62 $4,844 $5,607 
Current year actuarial loss (gain)$(294)$219 $(154)$79 $21 $29 $(41)$47 $(468)$374 
Amortization of actuarial gain (loss) and
prior service cost
(193)(173)(19)(12)(63)(50)(20)(27)(295)(262)
Current year prior service cost (credit) —   —  —  
Amounts recognized in OCI$(487)$46 $(173)$70 $(42)$(21)$(61)$20 $(763)$115 
145Bank of America140


                    
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)2019 2018 2019 2018 2019 2018 2019 2018 2019 2018
Net actuarial loss (gain)$3,865
 $4,386
 $559
 $454
 $1,008
 $912
 $48
 $(75) $5,480
 $5,677
Prior service cost (credits)
 
 18
 18
 
 
 (6) (9) 12
 9
Amounts recognized in accumulated OCI$3,865

$4,386

$577

$472

$1,008

$912

$42

$(84)
$5,492

$5,686
                    
Current year actuarial loss (gain)$(385) $541
 $110
 $270
 $130
 $(59) $99
 $(73) $(46) $679
Amortization of actuarial gain (loss) and
prior service cost
(135) (147) (7) (11) (34) (43) 26
 30
 (150) (171)
Current year prior service cost (credit)
 
 2
 13
 
 
 
 
 2
 13
Amounts recognized in OCI$(520)
$394

$105

$272

$96

$(102)
$125

$(43)
$(194)
$521

Plan Assets
The Qualified Pension Plan has been established as a retirement vehicle for participants, and trusts have been established to secure benefits promised under the Qualified Pension Plan. The Corporation’s policy is to invest the trust assets in a prudent manner for the exclusive purpose of providing benefits to participants and defraying reasonable expenses of administration. The Corporation’s investment strategy is designed to provide a total return that, over the long term, increases the ratio of assets to liabilities. The strategy attempts to maximize the investment return on assets at a level of risk deemed appropriate by the Corporation while complying with ERISA and any applicable regulations and laws. The investment strategy utilizes asset allocation as a principal determinant for establishing the risk/return profile of the assets. Asset allocation ranges are established, periodically reviewed and adjusted as funding levels and liability characteristics change. Active and passive investment managers are employed to help enhance the risk/return profile of the assets. An additional aspect of the investment strategy used to minimize risk (part of the asset allocation plan) includes matching the exposure of participant-selected investment measures.
The assets of the Non-U.S. Pension Plans are primarily attributable to a U.K. pension plan. This U.K. pension plan’s assets are invested prudently so that the benefits promised to members are provided with consideration given to the nature and the duration
of the plans' liabilities. The selected asset
allocation strategy is designed to achieve a higher return than the lowest risk strategy.
The expected rate of return on plan assets assumption was developed through analysis of historical market returns, historical asset class volatility and correlations, current market conditions, anticipated future asset allocations, the funds’ past experience and expectations on potential future market returns. The expected return on plan assets assumption is determined using the calculated market-related value for the Qualified Pension Plan and the Other Pension Plan and the fair value for the Non-U.S. Pension Plans and Postretirement Health and Life Plans. The expected return on plan assets assumption represents a long-term average view of the performance of the assets in the Qualified Pension Plan, the Non-U.S. Pension Plans, the Other Pension Plan, and Postretirement Health and Life Plans, a return that may or may not be achieved during any one calendar year. The Other Pension Plan is invested solely in an annuity contract, which is primarily invested in fixed-income securities structured such that asset maturities match the duration of the plan’s obligations.
The target allocations for 20202022 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.table below. Equity securities for the Qualified Pension Plan include common stock of the Corporation in the amounts of $315$398 million (1.55(1.80 percent of total plan assets) and $221$274 million (1.22(1.26 percent of total plan assets) at December 31, 20192021 and 2018.2020.
2022 Target Allocation
2020 Target Allocation
Percentage
Asset CategoryPercentageQualified
Pension Plan
Non-U.S.
Pension Plans
Nonqualified
and Other
Pension Plans
Asset Category
Qualified
Pension Plan
Non-U.S.
Pension Plans
Nonqualified
and Other
Pension Plans
Equity securities15 - 50%50 - 30%25%0 - 5%
Debt securities45 - 80%40 - 70%95 - 100%
Real estate0 - 10%0 - 15%0 - 5%
Other0 - 5%10 - 40%0 - 5%

Fair Value Measurements
For more information on fair value measurements, including descriptions of Level 1, 2 and 3 of the fair value hierarchy and the valuation methods employed by the Corporation, see Note 1 – Summary of Significant Accounting Principles and Note 2120 – Fair Value Measurements. Combined plan investment assets measured at fair value by level and in total at December 31, 20192021 and 20182020 are summarized in the Fair Value Measurements table.

141Bank of America






                
Fair Value Measurements               
                
 Level 1 Level 2 Level 3 Total Level 1 Level 2 Level 3 Total
(Dollars in millions)December 31, 2019 December 31, 2018
Cash and short-term investments 
  
  
  
        
Money market and interest-bearing cash$1,426
 $
 $
 $1,426
 $1,530
 $
 $
 $1,530
Cash and cash equivalent commingled/mutual funds
 250
 
 250
 
 644
 
 644
Fixed income 
  
  
 

  
  
  
  
U.S. government and agency securities4,403
 890
 8
 5,301
 3,637
 805
 9
 4,451
Corporate debt securities
 3,676
 
 3,676
 
 2,852
 
 2,852
Asset-backed securities
 2,684
 
 2,684
 
 2,119
 
 2,119
Non-U.S. debt securities748
 1,015
 
 1,763
 539
 961
 
 1,500
Fixed income commingled/mutual funds804
 1,439
 
 2,243
 933
 1,177
 
 2,110
Equity 
  
  
 

  
  
  
  
Common and preferred equity securities4,655
 
 
 4,655
 4,414
 
 
 4,414
Equity commingled/mutual funds147
 1,355
 
 1,502
 288
 1,275
 
 1,563
Public real estate investment trusts91
 
 
 91
 104
 
 
 104
Real estate 
  
  
 

  
  
  
  
Private real estate
 
 
 
 
 
 5
 5
Real estate commingled/mutual funds
 18
 927
 945
 
 13
 885
 898
Limited partnerships
 173
 90
 263
 
 158
 82
 240
Other investments (1)
11
 390
 636
 1,037
 93
 364
 588
 1,045
Total plan investment assets, at fair value$12,285

$11,890

$1,661

$25,836
 $11,538
 $10,368
 $1,569
 $23,475
(1)
Other investments include commodity and balanced funds of $233 million and $305 million, insurance annuity contracts of $614 million and $562 million and other various investments of $190 million and $178 million at December 31, 2019 and 2018.146


Fair Value Measurements
Level 1Level 2Level 3TotalLevel 1Level 2Level 3Total
(Dollars in millions)December 31, 2021December 31, 2020
Money market and interest-bearing cash$1,339 $ $ $1,339 $1,380 $— $— $1,380 
U.S. government and government agency obligations4,948 934 6 5,888 4,590 1,238 5,835 
Corporate debt 4,900  4,900 — 5,021 — 5,021 
Non-U.S. debt securities925 1,165  2,090 1,021 1,122 — 2,143 
Asset-backed securities 1,485  1,485 — 1,967 — 1,967 
Mutual and exchange traded funds1,395   1,395 1,362 — — 1,362 
Collective investment funds 3,419  3,419 — 3,199 — 3,199 
Common and preferred stocks4,826   4,826 4,438 — — 4,438 
Real estate investment trusts87   87 73 — — 73 
Participant loans  7 7 — — 
Other investments (1)
1 29 630 660 29 684 714 
Total plan investment assets, at fair value (2)
$13,521 $11,932 $643 $26,096 $12,865 $12,576 $698 $26,139 
(1)Other investments includes insurance annuity contracts of $612 million and $664 million and other various investments of $48 million and $50 million at December 31, 2021 and 2020.
(2)At December 31, 2021 and 2020, excludes $1.7 billion and $1.6 billion of certain investments that are measured at fair value using the net asset value per share (or its equivalent) as a practical expedient and are not required to be classified in the fair value hierarchy. Prior period has been revised to conform to current-period presentation.
The Level 3 Fair Value Measurements table presents a reconciliation of all plan investment assets measured at fair value using significant unobservable inputs (Level 3) during 2019, 20182021, 2020 and 2017.2019.
        
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
(Dollars in millions)2019
Fixed income 
  
  
  
U.S. government and agency securities$9
 $
 $(1) $8
Real estate   
   

Private real estate5
 
 (5) 
Real estate commingled/mutual funds885
 33
 9
 927
Limited partnerships82
 
 8
 90
Other investments588
 6
 42
 636
Total$1,569

$39

$53

$1,661
        
 2018
Fixed income 
  
  
  
U.S. government and agency securities$9
 $
 $
 $9
Real estate   
   

Private real estate93
 (7) (81) 5
Real estate commingled/mutual funds831
 52
 2
 885
Limited partnerships85
 (12) 9
 82
Other investments74
 
 514
 588
Total$1,092

$33

$444
 $1,569
        
 2017
Fixed income       
U.S. government and agency securities$10
 $
 $(1) $9
Real estate 
  
   

Private real estate150
 8
 (65) 93
Real estate commingled/mutual funds748
 63
 20
 831
Limited partnerships38
 14
 33
 85
Other investments83
 5
 (14) 74
Total$1,029

$90

$(27)
$1,092


Bank of America 142


Level 3 Fair Value Measurements
 Balance
January 1
Actual Return on
Plan Assets Still
Held at the
Reporting Date
Purchases, Sales and SettlementsBalance
December 31
(Dollars in millions)2021
U.S. government and government agency obligations$7 $ $(1)$6 
Participant Loans7   7 
Other investments684 (5)(49)630 
Total$698 $(5)$(50)$643 
 2020
U.S. government and government agency obligations$$— $(1)$
Participant Loans— (1)
Other investments628 50 684 
Total$644 $$48 $698 
2019
U.S. government and government agency obligations$$— $(1)$
Private real estate— (5)— 
Participant loans12 — (4)
Other investments576 46 628 
Total$602 $$36 $644 
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)
2022$948 $134 $239 $78 
2023938 142 244 74 
2024949 135 225 71 
2025936 142 223 67 
2026941 140 218 64 
2027 - 20314,395 668 940 275 
(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.

        
Projected Benefit Payments  
        
(Dollars in millions)
Qualified
Pension Plan (1)
 
Non-U.S.
Pension Plans (2)
 
Nonqualified
and Other
Pension Plans (2)
 
Postretirement Health and Life Plans (3)
2020$917
 $108
 $242
 $83
2021926
 107
 245
 80
2022927
 110
 232
 77
2023917
 116
 230
 74
2024924
 126
 223
 72
2025 - 20294,409
 594
 1,011
 313
(1)147 Bank of America
Benefit payments expected to be made from the plan’s assets.
(2)


Benefit payments expected to be made from a combination of the plans’ and the Corporation’s assets.
(3)
Benefit payments (net of retiree contributions) expected to be made from a combination of the plans’ and the Corporation’s assets.
Defined Contribution Plans
The Corporation maintains qualified and non-qualified defined contribution retirement plans. The Corporation recorded expense of $1.2 billion in both 2021 and 2020 and $1.0 billion in each of 2019 2018 and 2017 related to the qualified defined contribution plans. At December 31, 20192021 and 2018, 1892020, 173 million and 212189 million shares of the Corporation’s common stock were held by these plans. Payments to the plans for dividends on common stock were $139 million, $138 million and $133 million $115 millionin 2021, 2020 and $86 million in 2019, 2018 and 2017, respectively.
Certain non-U.S. employees are covered under defined contribution pension plans that are separately administered in accordance with local laws.
NOTE 1918 Stock-based Compensation Plans
The Corporation administers a number of equity compensation plans, with awards being granted predominantly from the Bank of America Key Employee Equity Plan (KEEP). On April 24, 2019,20, 2021, Bank of America'sAmerica’s shareholders approved anthe amendment and restatement of the KEEP, changing its name to the KEEP to increase“Bank of America Corporation Equity Plan” and increasing the number of shares available for grant by 150115 million. Subsequent to thisthe amendment 600and restatement, 715 million shares of the Corporation’s common stock are authorized to be used for grants of awards.awards under this plan.
During 20192021 and 2018,2020, the Corporation granted 9499 million and 7186 million RSU awards to certain employees under the KEEP. These RSUs were authorized to settle predominantly in shares of common stock of the Corporation. Certain RSUs will be settled in cash or contain settlement provisions that subject these awards to variable accounting whereby compensation expense is adjusted to fair value based on changes in the share price of the Corporation’s common stock up to the settlement date. Of the RSUs granted in 20192021 and 2018, 712020, 81 million and 6329 million will generally vest over four years and 18 million and 57 million will vest predominantly over three years with most vesting occurringyears. The four-year awards vest primarily in one-fourth increments on each of the first four anniversaries of the grant date while the three-year awards vest primarily in one-third increments on each of the first three anniversaries of the grant date, provided that the employee remains continuously employed with the Corporation during that time, and will be expensed ratably over the vesting period, net of estimated forfeitures, for non-retirement eligible employees based on the grant-date fair value of the shares. Of the RSUs granted in 2021 and 2020 that vest over four years, 27 million and 25 million do not include retirement eligibility. For all other RSUs granted to employees who are retirement eligible, the awardsthey are deemed authorized as of the beginning of the year preceding the grant date when the incentive award plans are generally approved. As a result, the estimated value is expensed ratably over the year preceding the grant date. Additionally, 23 million and eight million of the RSUs granted in 2019 and 2018 will vest predominantly over four years with most vesting occurring in one-fourth increments on each of the first four
anniversaries of the grant date provided that the employee remains continuously employed with the Corporation during that time, and will be expensed ratably over the vesting period, net of estimated forfeitures, based on the grant-date fair value of the shares.
The compensation cost for the stock-based plans was $3.0 billion, $2.1 billion $1.8 billion and $2.2$2.1 billion, and the related income tax benefit was $723 million, $505 million and $511 million $433 millionfor 2021, 2020 and $829 million for 2019, 2018 and 2017, respectively.
Restricted Stock/Units
The table below presents the status at December 31, 2019 of the share-settled restricted stock/units and changes during 2019.
    
 Stock-settled Restricted Stock/Units
    
 Shares/Units 
Weighted-
average Grant Date Fair Value
Outstanding at January 1, 2019165,621,246
 $23.22
Granted91,164,482
 27.72
Vested(92,215,549) 19.30
Canceled(6,660,864) 27.49
Outstanding at December 31, 2019157,909,315
 27.93
The table below presents the status at December 31, 2019 of the cash-settled RSUs and changes during 2019.
Cash-settled Restricted Units
Units
Outstanding at January 1, 20192,609,122
Granted2,455,177
Vested(3,006,707)
Canceled(93,170)
Outstanding at December 31, 20191,964,422

At December 31, 2019,2021, there was an estimated $1.6$2.3 billion of total unrecognized compensation cost related to certain share-based compensation awards that is expected to be recognized over a period of up to four years, with a weighted-average period of 2.22.4 years.

Restricted Stock and Restricted Stock Units
The total fair value of restricted stock and restricted stock units vested in 2021, 2020 and 2019 2018 and 2017 was $2.6$2.3 billion, $2.3 billion and $1.3$2.6 billion, respectively. The table below presents the status at December 31, 2021 of the share-settled restricted stock and restricted stock units and changes during 2021.
 Stock-settled Restricted Stock and Restricted Stock Units
Shares/UnitsWeighted-
average Grant Date Fair Value
Outstanding at January 1, 2021167,953,229 $30.60 
Granted96,804,487 32.32 
Vested(69,337,350)30.19 
Canceled(10,369,524)32.58 
Outstanding at December 31, 2021185,050,842 31.54 
Cash-settled Restricted Units
At December 31, 2021, approximately 2 million cash-settled restricted units remain outstanding. In 2019, 20182021, 2020 and 2017,2019, the amount of cash paid to settle equity-based awards for all equity compensation plansthe RSUs that vested was $72 million, $81 million and $84 million, $1.3 billion and $1.9 billion, respectively.


143Bank of America






NOTE 2019 Income Taxes
The components of income tax expense for 2019, 20182021, 2020 and 20172019 are presented in the table below.
      
Income Tax Expense    
      
(Dollars in millions)2019 2018 2017
Current income tax expense 
  
  
U.S. federal$1,136
 $816
 $1,310
U.S. state and local901
 1,377
 557
Non-U.S. 852
 1,203
 939
Total current expense2,889
 3,396
 2,806
Deferred income tax expense 
  
  
U.S. federal2,001
 2,579
 7,238
U.S. state and local223
 240
 835
Non-U.S. 211
 222
 102
Total deferred expense2,435
 3,041
 8,175
Total income tax expense$5,324
 $6,437
 $10,981

Income Tax Expense
(Dollars in millions)202120202019
Current income tax expense   
U.S. federal$1,076 $1,092 $1,136 
U.S. state and local775 1,076 901 
Non-U.S. 985 670 852 
Total current expense2,836 2,838 2,889 
Deferred income tax expense   
U.S. federal962 (799)2,001 
U.S. state and local491 (233)223 
Non-U.S. (2,291)(705)211 
Total deferred expense(838)(1,737)2,435 
Total income tax expense$1,998 $1,101 $5,324 
Total income tax expense does not reflect the tax effects of items that are included in OCI each period. For more information, see Note 1514 – Accumulated Other Comprehensive Income (Loss). Other tax effects included in OCI each period resulted in ana benefit of $877 million in 2021 and expense of $1.5 billion, and $1.9 billion in 20192020 and a benefit of $1.2 billion in both 2018 and 2017.2019.
Income tax expense for 2019, 20182021, 2020 and 20172019 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 20192021, 2020 and 2018, and 35 percent for 2017.2019. A reconciliation of the expected U.S. federal income tax expense, calculated by applying the federal statutory tax rate, to the Corporation’s actual income tax expense, and the effective tax rates for 2019, 20182021, 2020 and 20172019 are presented in the table below.
On December 22, 2017, the President signed into law the Tax Act which made significant changes to federal income tax law including, among other things, reducing the statutory corporate income tax rate to 21 percent from 35 percent and changing the taxation of the Corporation’s non-U.S. business activities. The impact on net income in 2017 was $2.9 billion, driven by $2.3 billion in income tax expense, largely from a lower valuation of certain U.S. deferred tax assets and liabilities. The change in the statutory tax rate also impacted the Corporation’s tax-advantaged energy investments, resulting in a downward valuation adjustment of $946 million recorded in other income and a related income tax benefit of $347 million, which when netted against the $2.3 billion, resulted in a net impact on income tax expense of $1.9 billion.following table.
            
Reconciliation of Income Tax Expense          
            
 Amount Percent Amount Percent Amount Percent
(Dollars in millions)2019 2018 2017
Expected U.S. federal income tax expense$6,878
 21.0 % $7,263
 21.0 % $10,225
 35.0 %
Increase (decrease) in taxes resulting from:           
State tax expense, net of federal benefit1,283
 3.9
 1,367
 4.0
 881
 3.0
Affordable housing/energy/other credits(2,365) (7.2) (1,888) (5.5) (1,406) (4.8)
Changes in prior-period UTBs, including interest(613) (1.9) 144
 0.4
 133
 0.5
Tax-exempt income, including dividends(433) (1.3) (413) (1.2) (672) (2.3)
Stock-based compensation(225) (0.7) (257) (0.7) (236) (0.8)
Rate differential on non-U.S. earnings504
 1.5
 98
 0.3
 (272) (0.9)
Nondeductible expenses290
 0.9
 302
 0.9
 97
 0.3
Tax law changes
 
 
 
 2,281
 7.8
Other5
 0.1
 (179) (0.6) (50) (0.2)
Total income tax expense$5,324
 16.3 % $6,437
 18.6 % $10,981
 37.6 %
Bank of America 148


Reconciliation of Income Tax Expense
 AmountPercentAmountPercentAmountPercent
(Dollars in millions)202120202019
Expected U.S. federal income tax expense$7,135 21.0 %$3,989 21.0 %$6,878 21.0 %
Increase (decrease) in taxes resulting from:
State tax expense, net of federal benefit1,087 3.2 728 3.8 1,283 3.9 
Affordable housing/energy/other credits(3,795)(11.2)(2,869)(15.1)(2,365)(7.2)
Tax law changes(2,050)(6.0)(699)(3.7)— — 
Tax-exempt income, including dividends(352)(1.0)(346)(1.8)(433)(1.3)
Changes in prior-period UTBs, including interest(155)(0.5)(41)(0.2)(613)(1.9)
Nondeductible expenses206 0.6 324 1.7 290 0.9 
Rate differential on non-U.S. earnings45 0.1 218 1.1 504 1.5 
Other(123)(0.3)(203)(1.0)(220)(0.6)
Total income tax expense$1,998 5.9 %$1,101 5.8 %$5,324 16.3 %
The reconciliation of the beginning unrecognized tax benefits (UTB) balance to the ending balance is presented in the followingtable below.
Reconciliation of the Change in Unrecognized Tax Benefits
(Dollars in millions)202120202019
Balance, January 1$1,340 $1,175 $2,197 
Increases related to positions taken during the current year208 238 238 
Increases related to positions taken during prior years (1)
265 99 401 
Decreases related to positions taken during prior years (1)
(413)(172)(1,102)
Settlements(23)— (541)
Expiration of statute of limitations(55)— (18)
Balance, December 31$1,322 $1,340 $1,175 
(1)    The sum of the positions taken during prior years differs from the $(155) million, $(41) million and $(613) 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.
      
Reconciliation of the Change in Unrecognized Tax Benefits
      
(Dollars in millions)2019 2018 2017
Balance, January 1$2,197
 $1,773
 $875
Increases related to positions taken during the current year238
 395
 292
Increases related to positions taken during prior years (1)
401
 406
 750
Decreases related to positions taken during prior years (1)
(1,102) (371) (122)
Settlements(541) (6) (17)
Expiration of statute of limitations(18) 
 (5)
Balance, December 31$1,175
 $2,197
 $1,773

(1)
The sum of the positions taken during prior years differs from the $(613) million, $144 million and $133 million in the Reconciliation of Income Tax Expense table due to temporary items, state items and jurisdictional offsets, as well as the inclusion of interest in the Reconciliation of Income Tax Expense table.
At December 31, 2019, 20182021, 2020 and 2017,2019, the balance of the Corporation’s UTBs which would, if recognized, affect the Corporation’s effective tax rate was $959 million, $976 million and $814 million, $1.6 billion and $1.2 billion, respectively. Included in the UTB balance are some items the recognition of which would not affect the effective tax rate, such as the tax effect of certain temporary differences, the portion of gross state UTBs that would be offset by the tax benefit of the associated federal deduction and the portion of gross non-U.S. UTBs that would be offset by tax reductions in other jurisdictions.
It is reasonably possible that the UTB balance may decrease by as much as $64$398 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 $32 million and $9 million in 2021 and 2020 and an interest benefit of $19 million in 2019 and interest expense of $43 million and $1 million in 2018 and 2017.2019. At December 31, 20192021 and 2018,2020, the Corporation’s accrual for interest and penalties that related to income taxes, net of taxes and remittances, was $147$167 million and $218$130 million.
The Corporation files income tax returns in more than 100 state and non-U.S. jurisdictions each year. The IRS and other tax authorities in countries and states in which the Corporation has

Bank of America 144


significant business operations examine tax returns
periodically (continuously in some jurisdictions). The following table below summarizes the status of examinations by major jurisdiction for the Corporation and various subsidiaries at December 31, 2019.2021.
Tax Examination Status
Years under
Examination (1)
Status at December 31 20192021
United States2017-20182017-2021To begin in 2020Field Examination
California2012-20172012-2014Field examinationAppeals
New YorkCalifornia2016-20182015-2017Field examinationExamination
United KingdomNew York20182016-2018Field examination

Field Examination
(1)United Kingdom (2)
All tax years subsequent to the years shown remain subject to examination.2019Field Examination
(1)    All tax years subsequent to the years shown remain subject to examination.
(2) Field examination for tax year 2020 to begin in 2022.
Significant components of the Corporation’s net deferred tax assets and liabilities at December 31, 20192021 and 20182020 are presented in the following table.table below.
Deferred Tax Assets and Liabilities
 December 31
(Dollars in millions)20212020
Deferred tax assets  
Net operating loss carryforwards$9,360 $7,717 
Allowance for credit losses3,097 4,701 
Security, loan and debt valuations2,746 2,571 
Lease liability2,508 2,400 
Accrued expenses1,626 1,481 
Employee compensation and retirement benefits1,392 1,582 
Credit carryforwards705 484 
Other1,160 1,412 
Gross deferred tax assets22,594 22,348 
Valuation allowance(1,988)(2,346)
Total deferred tax assets, net of valuation
   allowance
20,606 20,002 
  
Deferred tax liabilities
Equipment lease financing3,083 3,101 
Right-to-use asset2,358 2,296 
Fixed assets2,082 1,957 
ESG-related tax credit investments1,387 1,930 
Available-for-sale securities
1,016 1,701 
Other1,527 1,570 
Gross deferred tax liabilities11,453 12,555 
Net deferred tax assets$9,153 $7,447 

    
Deferred Tax Assets and Liabilities
    
 December 31
(Dollars in millions)2019 2018
Deferred tax assets 
  
Net operating loss carryforwards$7,417
 $7,993
Allowance for credit losses2,354
 2,400
Lease liability2,321
 
Security, loan and debt valuations1,860
 1,818
Accrued expenses1,719
 1,875
Employee compensation and retirement benefits1,622
 1,564
Credit carryforwards183
 623
Available-for-sale securities
 1,854
Other1,203
 1,037
Gross deferred tax assets18,679
 19,164
Valuation allowance(1,989) (1,569)
Total deferred tax assets, net of valuation allowance16,690
 17,595
  
  
Deferred tax liabilities   
Equipment lease financing2,933
 2,684
Right-to-use asset2,246
 
Tax credit investments1,577
 940
Fixed assets1,505
 1,104
Available-for-sale securities
100
 
Other1,885
 2,126
Gross deferred tax liabilities10,246
 6,854
Net deferred tax assets$6,444
 $10,741
149 Bank of America


The table below summarizes the deferred tax assets and related valuation allowances recognized for the net operating loss (NOL) and tax credit carryforwards at December 31, 2019.2021.
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.K. (1)
$7,713 $— $7,713 None
Net operating losses - other non-U.S. 494 (253)241 Various
Net operating losses - U.S. states (2)
1,153 (610)543 Various
Foreign tax credits705 (705) 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. $312
 $
 $312
 After 2028
Net operating losses - U.K. (1)
5,276
 
 5,276
 None
Net operating losses - other non-U.S. 493
 (423) 70
 Various
Net operating losses - U.S. states (2)
1,336
 (580) 756
 Various
Foreign tax credits183
 (183) 
 2028
(1)Represents U.K. broker-dealer net operating losses that may be carried forward indefinitely.
(1)
(2)The net operating losses and related valuation allowances for U.S. states before considering the benefit of federal deductions were $1.5 billion and $772 million.
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 $1.7 billion and $734 million.
Management concluded that 0no valuation allowance was necessary to reduce the deferred tax assets related to the U.K. NOL carryforwards and U.S. federal and certain state NOL carryforwards since estimated future taxable income will be sufficient to utilize these assets prior to their expiration. The majority of the Corporation’s U.K. net deferred tax assets, which consist primarily of NOLs, are expected to be realized by certain subsidiaries over an extended number of years. Management’s conclusion is supported by financial results, profit forecasts for the relevant entities and the indefinite period to carry forward NOLs. However, a material change in those estimates could lead management to reassess such valuation allowance conclusions.
At December 31, 2019,2021, U.S. federal income taxes had not been provided on approximately $5.0 billion of temporary differences associated with investments in non-U.S. subsidiaries that are essentially permanent in duration. If the Corporation were to record the associated deferred tax liability, the amount would be approximately $1.0 billion.
NOTE 2120 Fair Value Measurements
Under applicable accounting standards, fair value is defined as the exchange price that would be received for an asset or paid to transfer a liability (an exit price) in the principal or most advantageous market for the asset or liability in an orderly transaction between market participants on the measurement date. The Corporation determines the fair values of its financial instruments under applicable accounting standards that require an entity to maximize the use of observable inputs and minimize the use of unobservable inputs. The Corporation categorizes its financial instruments into three levels based on the established fair value hierarchy and conducts a review of fair value hierarchy classifications on a quarterly basis. Transfers into or out of fair value hierarchy classifications are made if the significant inputs used in the financial models measuring the fair values of the assets and liabilities become unobservable or observable in the current marketplace. For more information regarding the fair value hierarchy and how the Corporation measures fair value, see Note 1 – Summary of Significant Accounting Principles. The
Corporation accounts for certain financial instruments under the
fair value option. For more information, see Note 2221 – Fair Value Option.
Valuation Techniques
The following sections outline the valuation methodologies for the Corporation’s assets and liabilities. While the Corporation believes its valuation methods are appropriate and consistent with other market participants, the use of different methodologies or assumptions to determine the fair value of certain financial instruments could result in a different estimate of fair value at the reporting date.
During 2019,2021, 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

145Bank of America






cash flow model, which estimates the fair value of the securities using internal credit risk, and interest rate and prepayment risk models that incorporate management’s best estimate of current key assumptions such as default rates, loss severity and prepayment rates. Principal and interest cash flows are discounted using an observable discount rate for similar instruments with adjustments that management believes a market participant would consider in determining fair value for the specific security. Other instruments are valued using a net asset value approach which considers the value of the underlying securities. Underlying assets are valued using external pricing services, where available, or matrix pricing based on the vintages and ratings. Situations of illiquidity generally are triggered by the market’s perception of credit uncertainty regarding a single company or a specific market sector. In these instances, fair value is determined based on limited available market information and other factors, principally from reviewing the issuer’s financial statements and changes in credit ratings made by one or more rating agencies.
Derivative Assets and Liabilities
The fair values of derivative assets and liabilities traded in the OTC market are determined using quantitative models that utilize multiple market inputs including interest rates, prices and indices to generate continuous yield or pricing curves and volatility factors to value the position. The majority of market inputs are actively quoted and can be validated through external sources, including brokers, market transactions and third-party pricing services. When third-party pricing services are used, the methods and assumptions are reviewed by the Corporation. Estimation risk is greater for derivative asset and liability positions that are either option-based or have longer maturity
Bank of America 150


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 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.



151Bank of America146


Recurring Fair Value
Assets and liabilities carried at fair value on a recurring basis at December 31, 20192021 and 2018,2020, including financial instruments that the Corporation accounts for under the fair value option, are summarized in the following tables.
December 31, 2021
 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$707 $ $ $ $707 
Federal funds sold and securities borrowed or purchased under agreements to resell 150,665   150,665 
Trading account assets:     
U.S. Treasury and government agencies44,599 803   45,402 
Corporate securities, trading loans and other 31,601 2,110  33,711 
Equity securities61,425 38,383 190  99,998 
Non-U.S. sovereign debt3,822 25,612 396  29,830 
Mortgage trading loans, MBS and ABS:
U.S. government-sponsored agency guaranteed 25,645 109  25,754 
Mortgage trading loans, ABS and other MBS 10,967 1,418  12,385 
Total trading account assets (2)
109,846 133,011 4,223  247,080 
Derivative assets34,748 310,581 3,133 (313,118)35,344 
AFS debt securities:     
U.S. Treasury and government agencies198,071 1,074   199,145 
Mortgage-backed securities:     
Agency 46,339   46,339 
Agency-collateralized mortgage obligations 3,380   3,380 
Non-agency residential 267 316  583 
Commercial 19,604   19,604 
Non-U.S. securities 11,933   11,933 
Other taxable securities 2,690 71  2,761 
Tax-exempt securities 15,381 52  15,433 
Total AFS debt securities198,071 100,668 439  299,178 
Other debt securities carried at fair value:
U.S. Treasury and government agencies575    575 
Non-agency residential MBS 343 242  585 
Non-U.S. and other securities2,580 5,155   7,735 
Total other debt securities carried at fair value3,155 5,498 242  8,895 
Loans and leases 7,071 748  7,819 
Loans held-for-sale 4,138 317  4,455 
Other assets (3)
7,657 2,915 1,572  12,144 
Total assets (4)
$354,184 $714,547 $10,674 $(313,118)$766,287 
Liabilities     
Interest-bearing deposits in U.S. offices$ $408 $ $ $408 
Federal funds purchased and securities loaned or sold under agreements to repurchase 139,641   139,641 
Trading account liabilities:    
U.S. Treasury and government agencies19,826 313   20,139 
Equity securities41,744 6,491   48,235 
Non-U.S. sovereign debt10,400 13,781   24,181 
Corporate securities and other 8,124 11  8,135 
Total trading account liabilities71,970 28,709 11  100,690 
Derivative liabilities35,282 314,380 5,795 (317,782)37,675 
Short-term borrowings 4,279   4,279 
Accrued expenses and other liabilities8,359 3,130   11,489 
Long-term debt 28,633 1,075  29,708 
Total liabilities (4)
$115,611 $519,180 $6,881 $(317,782)$323,890 
          
 December 31, 2019
 Fair Value Measurements    
(Dollars in millions)Level 1 Level 2 Level 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 resell
 50,364
 
 
 50,364
Trading account assets: 
  
  
  
  
U.S. Treasury and agency securities (2)
49,517
 4,157
 
 
 53,674
Corporate securities, trading loans and other
 25,226
 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 MBS
 8,786
 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: 
  
  
  
  
Agency
 122,528
 
 
 122,528
Agency-collateralized mortgage obligations
 4,641
 
 
 4,641
Non-agency residential
 653
 424
 
 1,077
Commercial
 15,021
 
 
 15,021
Non-U.S. securities
 11,989
 2
 
 11,991
Other taxable securities
 3,876
 65
 
 3,941
Tax-exempt securities
 17,804
 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 securities3
 
 
 
 3
Agency MBS
 3,003
 
 
 3,003
Non-agency residential MBS
 1,035
 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 leases
 7,642
 693
 
 8,335
Loans held-for-sale
 3,334
 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 repurchase
 16,008
 
 
 16,008
Trading account liabilities: 
  
  
  
  
U.S. Treasury and agency securities13,140
 282
 
 
 13,422
Equity securities38,148
 4,144
 2
 
 42,294
Non-U.S. sovereign debt10,751
 11,310
 
 
 22,061
Corporate securities and other
 5,478
 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 borrowings
 3,941
 
 
 3,941
Accrued expenses and other liabilities13,927
 1,507
 
 
 15,434
Long-term debt
 33,826
 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 billionwhich 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 0.27Amounts represent the impact of legally enforceable master netting agreements and also cash collateral held or placed with the same counterparties.
(2)Includes securities with a fair value of $10.6 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. Trading account assets also includes certain commodities inventory of $752 million that is accounted for at the lower of cost or net realizable value, which is the current selling price less any costs to sell.
(3)Includes MSRs of $818 million which are classified as Level 3 assets.
(4)Total recurring Level 3 assets were 0.34 percent of total consolidated assets, and total recurring Level 3 liabilities were 0.24 percent of total consolidated liabilities.

147Bank of America






          
 December 31, 2018
 Fair Value Measurements    
(Dollars in millions)Level 1 Level 2 Level 3 
Netting Adjustments (1)
 Assets/Liabilities at Fair Value
Assets 
  
  
  
  
Time deposits placed and other short-term investments$1,214
 $
 $
 $
 $1,214
Federal funds sold and securities borrowed or purchased under agreements to resell
 56,399
 
 
 56,399
Trading account assets: 
  
  
  
  
U.S. Treasury and agency securities (2)
53,131
 1,593
 
 
 54,724
Corporate securities, trading loans and other
 24,630
 1,558
 
 26,188
Equity securities53,840
 23,163
 276
 
 77,279
Non-U.S. sovereign debt5,818
 19,210
 465
 
 25,493
Mortgage trading loans, MBS and ABS:         
U.S. government-sponsored agency guaranteed (2)

 19,586
 
 
 19,586
Mortgage trading loans, ABS and other MBS
 9,443
 1,635
 
 11,078
Total trading account assets (3)
112,789
 97,625
 3,934
 
 214,348
Derivative assets9,967
 315,413
 3,466
 (285,121) 43,725
AFS debt securities: 
  
  
  
  
U.S. Treasury and agency securities53,663
 1,260
 
 
 54,923
Mortgage-backed securities: 
  
  
  
  
Agency
 121,826
 
 
 121,826
Agency-collateralized mortgage obligations
 5,530
 
 
 5,530
Non-agency residential
 1,320
 597
 
 1,917
Commercial
 14,078
 
 
 14,078
Non-U.S. securities
 9,304
 2
 
 9,306
Other taxable securities
 4,403
 7
 
 4,410
Tax-exempt securities
 17,376
 
 
 17,376
Total AFS debt securities53,663
 175,097
 606
 
 229,366
Other debt securities carried at fair value:         
U.S. Treasury and agency securities1,282
 
 
 
 1,282
Non-agency residential MBS
 1,434
 172
 
 1,606
Non-U.S. and other securities490
 5,357
 
 
 5,847
Total other debt securities carried at fair value1,772
 6,791
 172
 
 8,735
Loans and leases
 4,011
 338
 
 4,349
Loans held-for-sale
 2,400
 542
 
 2,942
Other assets (4)
15,032
 1,775
 2,932
 
 19,739
Total assets (5)
$194,437
 $659,511
 $11,990
 $(285,121) $580,817
Liabilities 
  
  
  
  
Interest-bearing deposits in U.S. offices$
 $492
 $
 $
 $492
Federal funds purchased and securities loaned or sold under agreements to repurchase
 28,875
 
 
 28,875
Trading account liabilities: 
  
  
  
  
U.S. Treasury and agency securities7,894
 761
 
 
 8,655
Equity securities33,739
 4,070
 
 
 37,809
Non-U.S. sovereign debt7,452
 9,182
 
 
 16,634
Corporate securities and other
 5,104
 18
 
 5,122
Total trading account liabilities49,085
 19,117
 18
 
 68,220
Derivative liabilities9,931
 303,441
 4,401
 (279,882) 37,891
Short-term borrowings
 1,648
 
 
 1,648
Accrued expenses and other liabilities18,096
 1,979
 
 
 20,075
Long-term debt
 26,872
 817
 
 27,689
Total liabilities (5)
$77,112
 $382,424
 $5,236
 $(279,882) $184,890

(1)
Amounts represent the impact of legally enforceable master netting agreements and also cash collateral held or placed with the same counterparties.
(2)
Includes $20.2 billion of GSE obligations.
(3)
Includes securities with a fair value of $16.6 billion that were segregated in compliance with securities regulations or deposited with clearing organizations. This amount is included in the parenthetical disclosure on the Consolidated Balance Sheet.
(4)
Includes MSRs of $2.0 billion which are classified as Level 3 assets.
(5)
Total recurring Level 3 assets were 0.51 percent of total consolidated assets, and total recurring Level 3 liabilities were 0.25 percent of total consolidated liabilities.


Bank of America 148152


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 $— $— $— $1,649 
Federal funds sold and securities borrowed or purchased under agreements to resell— 108,856 — — 108,856 
Trading account assets:     
U.S. Treasury and government agencies45,219 3,051 — — 48,270 
Corporate securities, trading loans and other— 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— 21,566 75 — 21,641 
Mortgage trading loans, ABS and other MBS— 8,440 1,365 — 9,805 
Total trading account assets (2)
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 government agencies115,266 1,114 — — 116,380 
Mortgage-backed securities:     
Agency— 61,849 — — 61,849 
Agency-collateralized mortgage obligations— 5,260 — — 5,260 
Non-agency residential— 631 378 — 1,009 
Commercial— 16,491 — — 16,491 
Non-U.S. securities— 13,999 18 — 14,017 
Other taxable securities— 2,640 71 — 2,711 
Tax-exempt securities— 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 government agencies93 — — — 93 
Non-agency residential MBS— 506 267 — 773 
Non-U.S. and other securities2,619 8,625 — — 11,244 
Total other debt securities carried at fair value2,712 9,131 267 — 12,110 
Loans and leases— 5,964 717 — 6,681 
Loans held-for-sale— 1,349 236 — 1,585 
Other assets (3)
9,898 3,850 1,970 — 15,718 
Total assets (4)
$232,493 $772,037 $9,964 $(387,371)$627,123 
Liabilities     
Interest-bearing deposits in U.S. offices$— $481 $— $— $481 
Federal funds purchased and securities loaned or sold under agreements to repurchase— 135,391 — — 135,391 
Trading account liabilities:    
U.S. Treasury and government agencies9,425 139 — — 9,564 
Equity securities38,189 4,235 — — 42,424 
Non-U.S. sovereign debt5,853 8,043 — — 13,896 
Corporate securities and other— 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 borrowings— 5,874 — — 5,874 
Accrued expenses and other liabilities12,297 4,014 — — 16,311 
Long-term debt— 31,036 1,164 — 32,200 
Total liabilities (5)
$80,671 $607,514 $7,399 $(388,481)$307,103 
(1)Amounts represent the impact of legally enforceable master netting agreements and also cash collateral held or placed with the same counterparties.
(2)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 certain commodities inventory of $576 million that is accounted for at the lower of cost or net realizable value, which is the current selling price less any costs to sell.
(3)Includes MSRs of $1.0 billion which are classified as Level 3 assets.
(4)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.


153 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 2019, 20182021, 2020 and 2017,2019, including net realized and unrealized gains (losses) included in earnings and accumulated OCI. Transfers into Level 3 occur
primarily due to decreased price observability, and
transfers out of Level 3 occur primarily due to increased price observability. Transfers occur on a regular basis for long-term debt instruments due to changes in the impact of unobservable inputs on the value of the embedded derivative in relation to the instrument as a whole.
Level 3 – Fair Value Measurements (1)
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, 2021
Trading account assets:       
Corporate securities, trading loans and other$1,359 $(17)$ $765 $(437)$ $(327)$1,218 $(451)$2,110 $(79)
Equity securities227 (18) 103 (68)  112 (166)190 (44)
Non-U.S. sovereign debt354 31 (20)18   (13)26  396 34 
Mortgage trading loans, ABS and other MBS1,440 (58) 518 (721)7 (167)771 (263)1,527 (91)
Total trading account assets3,380 (62)(20)1,404 (1,226)7 (507)2,127 (880)4,223 (180)
Net derivative assets (liabilities) (4)
(3,468)927  521 (653) 293 (74)(208)(2,662)800 
AFS debt securities:          
Non-agency residential MBS378 (11)(111) (98) (45)304 (101)316 8 
Non-U.S. securities18 (4)  (10) (4)    
Other taxable securities71  (7)8     (1)71  
Tax-exempt securities176 20     (2) (142)52 (19)
Total AFS debt securities643 5 (118)8 (108) (51)304 (244)439 (11)
Other debt securities carried at fair value – Non-agency residential MBS267 1   (45) (37)101 (45)242 10 
Loans and leases (5,6)
717 62  59 (13)70 (180)46 (13)748 65 
Loans held-for-sale (5,6)
236 13 (6)132 (1) (79)26 (4)317 18 
Other assets (6,7)
1,970 7 3 26 (202)144 (383)9 (2)1,572 3 
Trading account liabilities – Corporate securities
   and other
(16)6    (1)   (11) 
Long-term debt (5)
(1,164)(92)13 (6)15 (12)98 (65)138 (1,075)(113)
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)— 78 (53)— (3)58 (49)227 (31)
Non-U.S. sovereign debt482 45 (46)76 (61)— (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)— 120 (646)— (112)(235)178 (3,468)(953)
AFS debt securities:       
Non-agency residential MBS424 (2)23 (54)— (44)158 (130)378 (2)
Non-U.S. securities— — (1)— (1)17 — 18 
Other taxable securities65 — — (4)— — — 71 — 
Tax-exempt securities108 (21)— — — (169)265 (10)176 (20)
Total AFS debt securities599 (22)32 (59)— (214)441 (140)643 (21)
Other debt securities carried at fair value – Non-agency residential MBS299 26 — — (180)— (24)190 (44)267 
Loans and leases (5,6)
693 (4)— 145 (76)22 (161)98 — 717 
Loans held-for-sale (5,6)
375 26 (28)— (489)691 (119)93 (313)236 (5)
Other assets (6,7)
2,360 (288)178 (4)224 (506)(2)1,970 (374)
Trading account liabilities – Equity securities(2)— — — — — — — — 
Trading account liabilities – Corporate securities
   and other
(15)— (7)(3)— — — (16)— 
Long-term debt (5)
(1,149)(46)(104)— (47)218 (52)14 (1,164)(5)
            
Level 3 – Fair Value Measurements (1)
   
 
Balance
January 1
Total Realized/Unrealized Gains (Losses) in Net Income (2)
Gains
(Losses)
in OCI
(3)
Gross
Gross
Transfers
into
Level 3 
Gross
Transfers
out of
Level 3 
Balance
December 31
Change in Unrealized Gains (Losses) in Net Income Related to Financial Instruments Still Held (2)
(Dollars in millions)

PurchasesSalesIssuancesSettlements
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)1


(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) (4,5)
(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. securities2








2

Other taxable securities7
2




(5)61

65

Tax-exempt securities






108

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 (6,7)
338


230
(35)217
(57)

693
(1)
Loans held-for-sale (6,7)
542
48
(6)12
(71)36
(245)59

375
22
Other assets (7)
2,932
(81)19

(10)179
(683)5
(1)2,360
(267)
Trading account liabilities – Equity securities
(2)






(2)(2)
Trading account liabilities – Corporate securities
   and other
(18)8

(1)(3)(1)


(15)
Long-term debt (5,6)
(817)(59)(64)

(40)180
(350)1
(1,149)(55)
            
Year Ended December 31, 2018           
Trading account assets: 
 
    
  
 
  
Corporate securities, trading loans and other$1,864
$(32)$(1)$436
$(403)$5
$(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
3
585
(910)
(158)705
(236)1,635
97
Total trading account assets4,153
146
(42)1,078
(1,381)5
(760)1,704
(969)3,934
6
Net derivative assets (liabilities) (4)
(1,714)106

531
(1,179)
778
39
504
(935)(116)
AFS debt securities: 
 
 
    
 
 
 
 
Non-agency residential MBS
27
(33)
(71)
(25)774
(75)597

Non-U.S. securities25

(1)
(10)
(15)3

2

Other taxable securities509
1
(3)
(23)
(11)60
(526)7

Tax-exempt securities469





(1)1
(469)

Total AFS debt securities (8)
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

1
(201)23
(60)542
31
Other assets (7,8)
2,425
414
(38)2
(69)96
(792)929
(35)2,932
149
Trading account liabilities – Corporate securities
   and other
(24)11

9
(12)(2)


(18)(7)
Accrued expenses and other liabilities (6)
(8)




8




Long-term debt (6)
(1,863)103
4
9

(141)486
(262)847
(817)95
(1)(1)Assets (liabilities). For assets, increase (decrease) to Level 3 and for liabilities, (increase) decrease to Level 3.
Assets (liabilities). For assets, increase (decrease) to Level 3 and for liabilities, (increase) decrease to Level 3.
(2)
Includes gains (losses) reported in earnings in the following income statement line items: Trading account assets/liabilities - predominantly market making and similar activities; Net derivative assets (liabilities) - market making and similar activities and other income; Other debt securities carried at fair value - other income; Loans and leases - predominantly other income; Loans held-for-sale - other income; Other assets - primarily other income related to MSRs; Long-term debt - primarily market making and similar activities.
(3)
Includes unrealized gains (losses) in OCI on AFS debt securities, foreign currency translation adjustments and the impact of changes in the Corporation’s credit spreads on long-term debt accounted for under the fair value option. Amounts include net unrealized gains (losses) of $3 million and $(105) million related to financial instruments still held at December 31, 2019 and 2018.
(4)
Net derivative assets (liabilities) include derivative assets of $2.2 billion and $3.5 billion and derivative liabilities of $4.8 billion and $4.4 billion at December 31, 2019 and 2018.
(5)
Transfers into long-term debt include a $1.4 billion transfer in of Level 3 derivative assets to reflect the Corporation's change to present bifurcated embedded derivatives with their respective host instruments.
(6)
Amounts represent instruments that are accounted for under the fair value option.
(7)
Issuances represent loan originations and MSRs recognized following securitizations or whole-loan sales.
(8)
Transfers out of AFS debt securities and into other assets primarily relate to the reclassification of certain securities.


(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 - 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 market making and similar activities and other income related to MSRs; Long-term debt - market making and similar activities.
149(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 $19 million and $41 million related to financial instruments still held at December 31, 2021 and 2020.Bank of America


(4)Net derivative assets (liabilities) include derivative assets of $3.1 billion and $2.8 billion and derivative liabilities of $5.8 billion and $6.2 billion at December 31, 2021 and 2020.

(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.
            
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, 2017           
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 (liabilities) (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)
720
15

3
(34)
(126)
(7)571
11
Loans held-for-sale (5,6)
656
100
(3)3
(189)
(346)501
(32)690
14
Other assets (6)
2,986
144
(57)2
(214)258
(758)64

2,425
(226)
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 - market making and similar activities; Net derivative assets (liabilities) - primarily market making and similar activities and other income; Other debt securities carried at fair value - other income; Loans and leases - other income; Loans held-for-sale - other income; Other assets - primarily other income related to MSRs; Long-term debt - predominantly market making and similar activities.   
(3)
Includes unrealized gains (losses) in OCI on AFS debt securities, foreign currency translation adjustments and the impact of changes in the Corporation’s credit spreads on long-term debt accounted for under the fair value option.
(4)
Net derivative assets (liabilities) include derivative assets of $4.1 billion and derivative liabilities of $5.8 billion.
(5)
Amounts represent instruments that are accounted for under the fair value option.
(6)
Issuances represent loan originations and MSRs recognized following securitizations or whole-loan sales.


Bank of America 150154


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, 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 securities— — — — — — — 108 — 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)
(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 of $3 million related to financial instruments still held at December 31, 2019.
(4)Net derivative assets (liabilities) include derivative assets of $2.2 billion and derivative liabilities of $4.8 billion at December 31, 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 derivative assets to reflect the Corporation's change to present bifurcated embedded derivatives with their respective host instruments.


155 Bank of America


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, 20192021 and 2018.2020.
Quantitative Information about Level 3 Fair Value Measurements at December 31, 2021
(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$1,269 Discounted cash flow, Market comparablesYield0% to 25%%
Trading account assets – Mortgage trading loans, ABS and other MBS338 Prepayment speed1% to 40% CPR19% CPR
Loans and leases373 Default rate0% to 3% CDR1% CDR
AFS debt securities – Non-agency residential316 Price$0 to $168$92
Other debt securities carried at fair value – Non-agency residential242 Loss severity0% to 43%13 %
Instruments backed by commercial real estate assets$298 Discounted cash
flow
Yield0% to 25%%
Trading account assets – Corporate securities, trading loans and other138 Price$0 to $101$57
Trading account assets – Mortgage trading loans, ABS and other MBS77 
AFS debt securities – Other taxable securities71 
Loans held-for-sale12 
Commercial loans, debt securities and other$4,212 Discounted cash flow, Market comparablesYield0% to 19%10 %
Trading account assets – Corporate securities, trading loans and other1,972 Prepayment speed10% to 20%16 %
Trading account assets – Non-U.S. sovereign debt396 Default rate3% to 4%%
Trading account assets – Mortgage trading loans, ABS and other MBS1,112 Loss severity35% to 40%37 %
AFS debt securities – Tax-exempt securities52 Price$0 to $189$73
Loans and leases375 Long-dated equity volatilities45%n/a
Loans held-for-sale305 
Other assets, primarily auction rate securities$754 Discounted cash flow, Market comparablesPrice$10 to $96$91

Discount rate%n/a
MSRs$818 Discounted cash
flow
Weighted-average life, fixed rate (5)
0 to 14 years4 years
Weighted-average life, variable rate (5)
0 to 10 years3 years
Option-adjusted spread, fixed rate7% to 14%%
Option-adjusted spread, variable rate9% to 15%12 %
Structured liabilities
Long-term debt$(1,075)
Discounted cash flow, Market comparables, Industry standard derivative pricing (3)
Yield0% to 19%18 %
Equity correlation3% to 100%80 %
Long-dated equity volatilities5% to 78%36 %
Price$0 to $125$82
Natural gas forward price$2/MMBtu to $8/MMBtu$4 /MMBtu
Net derivative assets (liabilities)
Credit derivatives$(104)Discounted cash flow, Stochastic recovery correlation modelCredit spreads7 to 155 bps61 bps
Upfront points16 to 100 points 68 points
Prepayment speed15% CPRn/a
Default rate2% CDRn/a
Credit correlation20% to 60%55 %
Price$0 to $120$53
Equity derivatives$(1,710)
Industry standard derivative pricing (3)
Equity correlation3% to 100%80 %
Long-dated equity volatilities5% to 78%36 %
Commodity derivatives$(976)
Discounted cash flow, Industry standard derivative pricing (3)
Natural gas forward price$2/MMBtu to $8/MMBtu$4 /MMBtu
Correlation65% to 85%76 %
Power forward price$11 to $103$32
Volatilities41% to 69%63 %
Interest rate derivatives$128 
Industry standard derivative pricing (4)
Correlation (IR/IR)(1)% to 90%54 %
Correlation (FX/IR)(1)% to 58%44 %
Long-dated inflation rates
 (10)% to 11%
%
Long-dated inflation volatilities0% to 2%%
Interest rate volatilities0% to 2%%
Total net derivative assets (liabilities)$(2,662)
      
Quantitative Information about Level 3 Fair Value Measurements at December 31, 2019 
     
(Dollars in millions)  Inputs
Financial Instrument
Fair
Value
Valuation
Technique
Significant Unobservable
Inputs
Ranges of
Inputs
Weighted Average (1)
Loans and Securities (2)
     
Instruments backed by residential real estate assets$1,407
Discounted cash flow, Market comparablesYield0% to 25%6%
Trading account assets – Mortgage trading loans, ABS and other MBS332
Prepayment speed1% to 27% CPR17% CPR
Loans and leases281
Default rate0% to 3% CDR1% CDR
Loans held-for-sale4
Loss severity0% to 47%14%
AFS debt securities, primarily non-agency residential491
Price$0 to $160$94
Other debt securities carried at fair value - Non-agency residential299
   
Instruments backed by commercial real estate assets$303
Discounted cash flowYield0% to 30%14%
Trading account assets – Corporate securities, trading loans and other201
Price$0 to $100$55
Trading account assets – Mortgage trading loans, ABS and other MBS85
   
Loans held-for-sale17
   
Commercial loans, debt securities and other$3,798
Discounted cash flow, Market comparablesYield1% to 20%6%
Trading account assets – Corporate securities, trading loans and other1,306
Prepayment speed10% to 20%13%
Trading account assets – Non-U.S. sovereign debt482
Default rate3% to 4%4%
Trading account assets – Mortgage trading loans, ABS and other MBS1,136
Loss severity35% to 40%38%
AFS debt securities – Other taxable securities108
Price$0 to $142$72
Loans and leases412
Long-dated equity volatilities35%n/a
Loans held-for-sale354
   
Other assets, primarily auction rate securities$815
Discounted cash flow, Market comparablesPrice$10 to $100$96

    

    
MSRs$1,545
Discounted cash flow
Weighted-average life, fixed rate (5)
0 to 14 years5 years
  
Weighted-average life, variable rate (5)
0 to 9 years3 years
  Option-adjusted spread, fixed rate7% to 14%9%
  Option-adjusted spread, variable rate9% to 15%11%
Structured liabilities     
Long-term debt$(1,149)
Discounted cash flow, Market comparables, Industry standard derivative pricing (3)
Yield2% to 6%5%
  Equity correlation9% to 100%63%
  Long-dated equity volatilities4% to 101%32%
  Price$0 to $116$74
  Natural gas forward price$1/MMBtu to $5/MMBtu$3/MMBtu
Net derivative assets (liabilities)     
Credit derivatives$13
Discounted cash flow, Stochastic recovery correlation modelYield5%n/a
  Upfront points0 to 100 points63 points
  Prepayment speed15% to 100% CPR22% CPR
  Default rate1% to 4% CDR2% CDR
  Loss severity35%n/a
  Price$0 to $104$73
Equity derivatives$(1,081)
Industry standard derivative pricing (3)
Equity correlation9% to 100%63%
  Long-dated equity volatilities4% to 101%32%
Commodity derivatives$(1,357)
Discounted cash flow, Industry standard derivative pricing (3)
Natural gas forward price$1/MMBtu to $5/MMBtu$3/MMBtu
  Correlation30% to 69%68%
  Volatilities14% to 54%27%
Interest rate derivatives$(113)
Industry standard derivative pricing (4)
Correlation (IR/IR)15% to 94%52%
  Correlation (FX/IR)0% to 46%2%
  Long-dated inflation rates-23% to 56%16%
  Long-dated inflation volatilities0% to 1%1%
Total net derivative assets (liabilities)$(2,538)    
(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 152: Trading account assets – Corporate securities, trading loans and other of $2.1 billion, Trading account assets – Non-U.S. sovereign debt of $396 million, Trading account assets – Mortgage trading loans, MBS and ABS of $1.5 billion, AFS debt securities of $439 million, Other debt securities carried at fair value - Non-agency residential of $242 million, Other assets, including MSRs, of $1.6 billion, Loans and leases of $748 million and LHFS of $317 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.
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 147: 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.
CPR = Constant Prepayment Rate
CDR = Constant Default Rate
MMBtu = Million British thermal units
IR = Interest Rate
FX = Foreign Exchange
n/a = not applicable

151Bank of America






      
Quantitative Information about Level 3 Fair Value Measurements at December 31, 2018
     
(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$1,536
Discounted cash flow, Market comparablesYield0% to 25%8%
Trading account assets – Mortgage trading loans, ABS and other MBS419
Prepayment speed0% to 21% CPR12% CPR
Loans and leases338
Default rate0% to 3% CDR1% CDR
Loans held-for-sale1
Loss severity0% to 51%17%
AFS debt securities, primarily non-agency residential606
Price$0 to $128$72
Other debt securities carried at fair value - Non-agency residential172
   
Instruments backed by commercial real estate assets$291
Discounted cash flowYield0% to 25%7%
Trading account assets – Corporate securities, trading loans and other200
Price$0 to $100$79
Trading account assets – Mortgage trading loans, ABS and other MBS91
   
Commercial loans, debt securities and other$3,489
Discounted cash flow, Market comparablesYield1% to 18%13%
Trading account assets – Corporate securities, trading loans and other1,358
Prepayment speed10% to 20%15%
Trading account assets – Non-U.S. sovereign debt465
Default rate3% to 4%4%
Trading account assets – Mortgage trading loans, ABS and other MBS1,125
Loss severity35% to 40%38%
Loans held-for-sale541
Price$0 to $141$68
Other assets, primarily auction rate securities$890
Discounted cash flow, Market comparablesPrice$10 to $100$95
     
     
MSRs$2,042
Discounted cash flow
Weighted-average life, fixed rate (5)
0 to 14 years5 years
  
Weighted-average life, variable rate (5)
0 to 10 years3 years
  Option-adjusted spread, fixed rate7% to 14%9%
  Option-adjusted spread, variable rate9% to 15%12%
Structured liabilities     
Long-term debt$(817)
Discounted cash flow, Market comparables, Industry standard derivative pricing (3)
Equity correlation11% to 100%67%
  Long-dated equity volatilities4% to 84%32%
  Yield7% to 18%16%
  Price$0 to $100$72
Net derivative assets (liabilities)     
Credit derivatives$(565)Discounted cash flow, Stochastic recovery correlation modelYield0% to 5%4%
  Upfront points0 points to 100 points70 points
  Credit correlation70%n/a
  Prepayment speed15% to 20% CPR15% CPR
  Default rate1% to 4% CDR2% CDR
  Loss severity35%n/a
  Price$0 to $138$93
Equity derivatives$(348)
Industry standard derivative pricing (3)
Equity correlation11% to 100%67%
  Long-dated equity volatilities4% to 84%32%
Commodity derivatives$10
Discounted cash flow, Industry standard derivative pricing (3)
Natural gas forward price$1/MMBtu to $12/MMBtu$3/MMBtu
  Correlation38% to 87%71%
  Volatilities15% to 132%38%
Interest rate derivatives$(32)
Industry standard derivative pricing (4)
Correlation (IR/IR)15% to 70%61%
  Correlation (FX/IR)0% to 46%1%
  Long-dated inflation rates-20% to 38%2%
  Long-dated inflation volatilities0% to 1%1%
Total net derivative assets (liabilities)$(935)    

(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 148: Trading account assets – Corporate securities, trading loans and other of $1.6 billion, Trading account assets – Non-U.S. sovereign debt of $465 million, Trading account assets – Mortgage trading loans, ABS and other MBS of $1.6 billion, AFS debt securities of $606 million, Other debt securities carried at fair value - Non-agency residential of $172 million, Other assets, including MSRs, of $2.9 billion, Loans and leases of $338 million and LHFS of $542 million.156
(3)


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 comparables
Yield(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 comparablesYield 0% 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 rate8%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)
Yield 0% to 11%%
Equity correlation 2% 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
G(7)% to 84%
14 %
Long-dated inflation volatilities0% to 1%%
Interest rates volatilities0% to 2%%
Total net derivative assets (liabilities)$(3,468)
(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 153: 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, MBS and ABS 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.
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.
CPR = Constant Prepayment Rate
CDR = Constant Default Rate
MMBtu = Million British thermal units
IR = Interest Rate
FX = Foreign Exchange
n/a = not applicable



157Bank of America152


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 levellevels of aggregation and diversity within the products disclosed in the tables result in certain ranges of inputs being wide and unevenly distributed across asset and liability categories.
Uncertainty of Fair Value Measurements from Unobservable Inputs
Loans and SecuritiesLoan Commitments
A significant increase inThe fair values of loans and loan commitments are based on market yields, default rates, loss severitiesprices, where available, or duration would have resulted in a significantly lowerdiscounted 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 value for long positions. Short positions would have been impacted in a directionally opposite way. The impactvalues of changesMSRs are primarily determined using an option-adjusted spread valuation approach, which factors in prepayment speeds would have resulted in differing impacts depending on the seniority of the instrument and, in the case of CLOs, whether prepayments can be reinvested. A significant increase in price would have resulted in a significantly higher fair value for long positions, and short positions would have been impacted in a directionally opposite way.
Structured Liabilities and Derivatives
For credit derivatives, a significant increase in market yield, upfront points (i.e., a single upfront payment made by a protection buyer at inception), credit spreads, default rates or loss severities would
have resulted in a significantly lower fair value for protection sellers and higher fair value for protection buyers. The impact of changes in prepayment speeds would have resulted in differing impacts depending on the seniority of the instrument.
Structured credit derivatives are impacted by credit correlation. Default correlation is a parameter that describes the degree of dependence among credit default rates within a credit portfolio that underlies a credit derivative instrument. The sensitivity of this input onrisk to determine the fair value varies dependingof 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 levelCorporation’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 subordinationdebt 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 tranche. For senior tranches that are net purchases of protection, a significant increasenotes. These models incorporate observable and, in default correlation would have resulted in a significantly higher fair value. Net short protection positions would have been impacted in a directionally opposite way.
For equity derivatives, commodity derivatives,some instances, unobservable inputs including security prices, interest rate derivatives and structured liabilities, a significant change in long-datedyield curves, option volatility, currency, commodity or equity rates and volatilitiescorrelations 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 correlationsecurities borrowed transactions are determined using quantitative models, including discounted cash flow models that require the use of multiple market inputs (i.e., the degree of correlation between an equity security and an index, between two different commodities, between two different interest rates, or betweenincluding interest rates and foreign exchange rates) would have resulted in a significant impactspreads 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 fair value; however, the magnitudeuse of multiple market inputs including interest rates and directionspreads 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 dependof 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 whetherexternal broker bids, where available, or are determined by discounting estimated cash flows using interest rates approximating the Corporation is long or shortCorporation’s current origination rates for similar loans adjusted to reflect the exposure. For structured liabilities, a significant increase in yield or decrease in price would have resulted in a significantly lower fair value.
Nonrecurring Fair Valueinherent credit risk.
The Corporation holds certain assets that are measured at fair value only in certain situations (e.g., the impairment of an asset), and these measurements are referred to herein as nonrecurring. The amounts below represent assets still held as of the reporting date for which a nonrecurring fair value adjustment was recorded during 2019, 2018 and 2017. In the tables below, other assets includes the measurement of the Corporation's merchant services equity method investment on which the Corporation recorded an impairment charge of $2.1 billion during 2019. For more information, see Note 13 – Commitments and Contingencies.
       
Assets Measured at Fair Value on a Nonrecurring Basis
  
 December 31, 2019December 31, 2018
(Dollars in millions)
 
Level 2 Level 3Level 2 Level 3
Assets 
  
   
Loans held-for-sale$53
 $102
$274
 $
Loans and leases (1)

 257

 474
Foreclosed properties (2, 3)

 17

 42
Other assets178
 646
331
 14
       
   Gains (Losses)
   20192018 2017
Assets   
 
  
Loans held-for-sale  $(14)$(18) $(6)
Loans and leases (1)
  (81)(202) (336)
Foreclosed properties  (9)(24) (41)
Other assets  (2,145)(64) (124)
(1)151 Bank of America
Includes $36 million, $83 million and $135 million of losses on loans that were written down to a collateral value of zero during 2019, 2018 and 2017, respectively.


Recurring Fair Value
Assets and liabilities carried at fair value on a recurring basis at December 31, 2021 and 2020, including financial instruments that the Corporation accounts for under the fair value option, are summarized in the following tables.
December 31, 2021
 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$707 $ $ $ $707 
Federal funds sold and securities borrowed or purchased under agreements to resell 150,665   150,665 
Trading account assets:     
U.S. Treasury and government agencies44,599 803   45,402 
Corporate securities, trading loans and other 31,601 2,110  33,711 
Equity securities61,425 38,383 190  99,998 
Non-U.S. sovereign debt3,822 25,612 396  29,830 
Mortgage trading loans, MBS and ABS:
U.S. government-sponsored agency guaranteed 25,645 109  25,754 
Mortgage trading loans, ABS and other MBS 10,967 1,418  12,385 
Total trading account assets (2)
109,846 133,011 4,223  247,080 
Derivative assets34,748 310,581 3,133 (313,118)35,344 
AFS debt securities:     
U.S. Treasury and government agencies198,071 1,074   199,145 
Mortgage-backed securities:     
Agency 46,339   46,339 
Agency-collateralized mortgage obligations 3,380   3,380 
Non-agency residential 267 316  583 
Commercial 19,604   19,604 
Non-U.S. securities 11,933   11,933 
Other taxable securities 2,690 71  2,761 
Tax-exempt securities 15,381 52  15,433 
Total AFS debt securities198,071 100,668 439  299,178 
Other debt securities carried at fair value:
U.S. Treasury and government agencies575    575 
Non-agency residential MBS 343 242  585 
Non-U.S. and other securities2,580 5,155   7,735 
Total other debt securities carried at fair value3,155 5,498 242  8,895 
Loans and leases 7,071 748  7,819 
Loans held-for-sale 4,138 317  4,455 
Other assets (3)
7,657 2,915 1,572  12,144 
Total assets (4)
$354,184 $714,547 $10,674 $(313,118)$766,287 
Liabilities     
Interest-bearing deposits in U.S. offices$ $408 $ $ $408 
Federal funds purchased and securities loaned or sold under agreements to repurchase 139,641   139,641 
Trading account liabilities:    
U.S. Treasury and government agencies19,826 313   20,139 
Equity securities41,744 6,491   48,235 
Non-U.S. sovereign debt10,400 13,781   24,181 
Corporate securities and other 8,124 11  8,135 
Total trading account liabilities71,970 28,709 11  100,690 
Derivative liabilities35,282 314,380 5,795 (317,782)37,675 
Short-term borrowings 4,279   4,279 
Accrued expenses and other liabilities8,359 3,130   11,489 
Long-term debt 28,633 1,075  29,708 
Total liabilities (4)
$115,611 $519,180 $6,881 $(317,782)$323,890 
(1)Amounts represent the impact of legally enforceable master netting agreements and also cash collateral held or placed with the same counterparties.
(2)Includes securities with a fair value of $10.6 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. Trading account assets also includes certain commodities inventory of $752 million that is accounted for at the lower of cost or net realizable value, which is the current selling price less any costs to sell.
(3)Includes MSRs of $818 million which are classified as Level 3 assets.
(4)Total recurring Level 3 assets were 0.34 percent of total consolidated assets, and total recurring Level 3 liabilities were 0.24 percent of total consolidated liabilities.
(2)Bank of America 152
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.


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 $— $— $— $1,649 
Federal funds sold and securities borrowed or purchased under agreements to resell— 108,856 — — 108,856 
Trading account assets:     
U.S. Treasury and government agencies45,219 3,051 — — 48,270 
Corporate securities, trading loans and other— 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— 21,566 75 — 21,641 
Mortgage trading loans, ABS and other MBS— 8,440 1,365 — 9,805 
Total trading account assets (2)
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 government agencies115,266 1,114 — — 116,380 
Mortgage-backed securities:     
Agency— 61,849 — — 61,849 
Agency-collateralized mortgage obligations— 5,260 — — 5,260 
Non-agency residential— 631 378 — 1,009 
Commercial— 16,491 — — 16,491 
Non-U.S. securities— 13,999 18 — 14,017 
Other taxable securities— 2,640 71 — 2,711 
Tax-exempt securities— 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 government agencies93 — — — 93 
Non-agency residential MBS— 506 267 — 773 
Non-U.S. and other securities2,619 8,625 — — 11,244 
Total other debt securities carried at fair value2,712 9,131 267 — 12,110 
Loans and leases— 5,964 717 — 6,681 
Loans held-for-sale— 1,349 236 — 1,585 
Other assets (3)
9,898 3,850 1,970 — 15,718 
Total assets (4)
$232,493 $772,037 $9,964 $(387,371)$627,123 
Liabilities     
Interest-bearing deposits in U.S. offices$— $481 $— $— $481 
Federal funds purchased and securities loaned or sold under agreements to repurchase— 135,391 — — 135,391 
Trading account liabilities:    
U.S. Treasury and government agencies9,425 139 — — 9,564 
Equity securities38,189 4,235 — — 42,424 
Non-U.S. sovereign debt5,853 8,043 — — 13,896 
Corporate securities and other— 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 borrowings— 5,874 — — 5,874 
Accrued expenses and other liabilities12,297 4,014 — — 16,311 
Long-term debt— 31,036 1,164 — 32,200 
Total liabilities (5)
$80,671 $607,514 $7,399 $(388,481)$307,103 
(1)Amounts represent the impact of legally enforceable master netting agreements and also cash collateral held or placed with the same counterparties.
(2)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 certain commodities inventory of $576 million that is accounted for at the lower of cost or net realizable value, which is the current selling price less any costs to sell.
(3)Includes MSRs of $1.0 billion which are classified as Level 3 assets.
(4)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.


(3)
Excludes $260 million and $488 million of properties acquired upon foreclosure of certain government-guaranteed loans (principally FHA-insured loans) at December 31, 2019 and 2018.

153 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 2021, 2020 and 2019, including net realized and unrealized gains (losses) included in earnings and accumulated OCI. Transfers into Level 3 occur primarily due to decreased price observability, and

transfers out of Level 3 occur primarily due to increased price observability. Transfers occur on a regular basis for long-term debt instruments due to changes in the impact of unobservable inputs on the value of the embedded derivative in relation to the instrument as a whole.
Level 3 – Fair Value Measurements (1)
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, 2021
Trading account assets:       
Corporate securities, trading loans and other$1,359 $(17)$ $765 $(437)$ $(327)$1,218 $(451)$2,110 $(79)
Equity securities227 (18) 103 (68)  112 (166)190 (44)
Non-U.S. sovereign debt354 31 (20)18   (13)26  396 34 
Mortgage trading loans, ABS and other MBS1,440 (58) 518 (721)7 (167)771 (263)1,527 (91)
Total trading account assets3,380 (62)(20)1,404 (1,226)7 (507)2,127 (880)4,223 (180)
Net derivative assets (liabilities) (4)
(3,468)927  521 (653) 293 (74)(208)(2,662)800 
AFS debt securities:          
Non-agency residential MBS378 (11)(111) (98) (45)304 (101)316 8 
Non-U.S. securities18 (4)  (10) (4)    
Other taxable securities71  (7)8     (1)71  
Tax-exempt securities176 20     (2) (142)52 (19)
Total AFS debt securities643 5 (118)8 (108) (51)304 (244)439 (11)
Other debt securities carried at fair value – Non-agency residential MBS267 1   (45) (37)101 (45)242 10 
Loans and leases (5,6)
717 62  59 (13)70 (180)46 (13)748 65 
Loans held-for-sale (5,6)
236 13 (6)132 (1) (79)26 (4)317 18 
Other assets (6,7)
1,970 7 3 26 (202)144 (383)9 (2)1,572 3 
Trading account liabilities – Corporate securities
   and other
(16)6    (1)   (11) 
Long-term debt (5)
(1,164)(92)13 (6)15 (12)98 (65)138 (1,075)(113)
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)— 78 (53)— (3)58 (49)227 (31)
Non-U.S. sovereign debt482 45 (46)76 (61)— (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)— 120 (646)— (112)(235)178 (3,468)(953)
AFS debt securities:       
Non-agency residential MBS424 (2)23 (54)— (44)158 (130)378 (2)
Non-U.S. securities— — (1)— (1)17 — 18 
Other taxable securities65 — — (4)— — — 71 — 
Tax-exempt securities108 (21)— — — (169)265 (10)176 (20)
Total AFS debt securities599 (22)32 (59)— (214)441 (140)643 (21)
Other debt securities carried at fair value – Non-agency residential MBS299 26 — — (180)— (24)190 (44)267 
Loans and leases (5,6)
693 (4)— 145 (76)22 (161)98 — 717 
Loans held-for-sale (5,6)
375 26 (28)— (489)691 (119)93 (313)236 (5)
Other assets (6,7)
2,360 (288)178 (4)224 (506)(2)1,970 (374)
Trading account liabilities – Equity securities(2)— — — — — — — — 
Trading account liabilities – Corporate securities
   and other
(15)— (7)(3)— — — (16)— 
Long-term debt (5)
(1,149)(46)(104)— (47)218 (52)14 (1,164)(5)
(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 - 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 market making and similar activities and 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 losses of $19 million and $41 million related to financial instruments still held at December 31, 2021 and 2020.
(4)Net derivative assets (liabilities) include derivative assets of $3.1 billion and $2.8 billion and derivative liabilities of $5.8 billion and $6.2 billion at December 31, 2021 and 2020.
(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.

Bank of America 154


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, 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 securities— — — — — — — 108 — 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)
(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 of $3 million related to financial instruments still held at December 31, 2019.
(4)Net derivative assets (liabilities) include derivative assets of $2.2 billion and derivative liabilities of $4.8 billion at December 31, 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 derivative assets to reflect the Corporation's change to present bifurcated embedded derivatives with their respective host instruments.


155 Bank of America


The table below presentsfollowing tables present information about significant unobservable inputs related to the Corporation’s material categories of Level 3 financial assets and liabilities at December 31, 20192021 and 2018.2020.
Quantitative Information about Level 3 Fair Value Measurements at December 31, 2021
(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$1,269 Discounted cash flow, Market comparablesYield0% to 25%%
Trading account assets – Mortgage trading loans, ABS and other MBS338 Prepayment speed1% to 40% CPR19% CPR
Loans and leases373 Default rate0% to 3% CDR1% CDR
AFS debt securities – Non-agency residential316 Price$0 to $168$92
Other debt securities carried at fair value – Non-agency residential242 Loss severity0% to 43%13 %
Instruments backed by commercial real estate assets$298 Discounted cash
flow
Yield0% to 25%%
Trading account assets – Corporate securities, trading loans and other138 Price$0 to $101$57
Trading account assets – Mortgage trading loans, ABS and other MBS77 
AFS debt securities – Other taxable securities71 
Loans held-for-sale12 
Commercial loans, debt securities and other$4,212 Discounted cash flow, Market comparablesYield0% to 19%10 %
Trading account assets – Corporate securities, trading loans and other1,972 Prepayment speed10% to 20%16 %
Trading account assets – Non-U.S. sovereign debt396 Default rate3% to 4%%
Trading account assets – Mortgage trading loans, ABS and other MBS1,112 Loss severity35% to 40%37 %
AFS debt securities – Tax-exempt securities52 Price$0 to $189$73
Loans and leases375 Long-dated equity volatilities45%n/a
Loans held-for-sale305 
Other assets, primarily auction rate securities$754 Discounted cash flow, Market comparablesPrice$10 to $96$91

Discount rate%n/a
MSRs$818 Discounted cash
flow
Weighted-average life, fixed rate (5)
0 to 14 years4 years
Weighted-average life, variable rate (5)
0 to 10 years3 years
Option-adjusted spread, fixed rate7% to 14%%
Option-adjusted spread, variable rate9% to 15%12 %
Structured liabilities
Long-term debt$(1,075)
Discounted cash flow, Market comparables, Industry standard derivative pricing (3)
Yield0% to 19%18 %
Equity correlation3% to 100%80 %
Long-dated equity volatilities5% to 78%36 %
Price$0 to $125$82
Natural gas forward price$2/MMBtu to $8/MMBtu$4 /MMBtu
Net derivative assets (liabilities)
Credit derivatives$(104)Discounted cash flow, Stochastic recovery correlation modelCredit spreads7 to 155 bps61 bps
Upfront points16 to 100 points 68 points
Prepayment speed15% CPRn/a
Default rate2% CDRn/a
Credit correlation20% to 60%55 %
Price$0 to $120$53
Equity derivatives$(1,710)
Industry standard derivative pricing (3)
Equity correlation3% to 100%80 %
Long-dated equity volatilities5% to 78%36 %
Commodity derivatives$(976)
Discounted cash flow, Industry standard derivative pricing (3)
Natural gas forward price$2/MMBtu to $8/MMBtu$4 /MMBtu
Correlation65% to 85%76 %
Power forward price$11 to $103$32
Volatilities41% to 69%63 %
Interest rate derivatives$128 
Industry standard derivative pricing (4)
Correlation (IR/IR)(1)% to 90%54 %
Correlation (FX/IR)(1)% to 58%44 %
Long-dated inflation rates
 (10)% to 11%
%
Long-dated inflation volatilities0% to 2%%
Interest rate volatilities0% to 2%%
Total net derivative assets (liabilities)$(2,662)
(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 152: Trading account assets – Corporate securities, trading loans and other of $2.1 billion, Trading account assets – Non-U.S. sovereign debt of $396 million, Trading account assets – Mortgage trading loans, MBS and ABS of $1.5 billion, AFS debt securities of $439 million, Other debt securities carried at fair value - Non-agency residential of $242 million, Other assets, including MSRs, of $1.6 billion, Loans and leases of $748 million and LHFS of $317 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.
CPR = Constant Prepayment Rate
CDR = Constant Default Rate
MMBtu = Million British thermal units
IR = Interest Rate
FX = Foreign Exchange
n/a = not applicable
      
Quantitative Information about Nonrecurring Level 3 Fair Value Measurements
      
   Inputs
Financial InstrumentFair Value
Valuation
Technique
Significant Unobservable
Inputs
Ranges of
Inputs
Weighted
Average (1)
(Dollars in millions)December 31, 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%9%
Other assets (3)
640
Discounted cash flowCustomer attrition0% to 19%5%
   Costs to service11% to 19%15%
 December 31, 2018
Loans and leases (2)
$474
Market comparablesOREO discount13% to 59%25%
   Costs to sell8% to 26%9%
Bank of America 156


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 comparables
Yield(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 comparablesYield 0% 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 rate8%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)
Yield 0% to 11%%
Equity correlation 2% 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
G(7)% to 84%
14 %
Long-dated inflation volatilities0% to 1%%
Interest rates volatilities0% to 2%%
Total net derivative assets (liabilities)$(3,468)
(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 153: 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, MBS and ABS 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.
CPR = Constant Prepayment Rate
CDR = Constant Default Rate
MMBtu = Million British thermal units
IR = Interest Rate
FX = Foreign Exchange
n/a = not applicable



(1)157 Bank of America
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


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 levels of aggregation and diversity within the products disclosed in the tables result in certain ranges of inputs being wide and unevenly distributed across asset and liability categories.
Uncertainty of the underlying collateral.
(3)
The fair value of the merchant services joint venture was measured using a discounted cash flow method in which the two primary drivers of fair value were the customer attrition rate and certain costs to service the customers. The weighted averages are calculated based on variations of the attrition rates and costs to service the customers.
NOTE 22 Fair Value OptionMeasurements from Unobservable Inputs
Loans and Loan Commitments
The fair values of loans and loan commitments are based on market prices, where available, or discounted cash flow analyses using market-based credit spreads of comparable debt instruments or credit derivatives of the specific borrower or comparable borrowers. Results of discounted cash flow analyses may be adjusted, as appropriate, to reflect other market conditions or the perceived credit risk of the borrower.
Mortgage Servicing Rights
The fair values of MSRs are primarily determined using an option-adjusted spread valuation approach, which factors in prepayment risk to determine the fair value of MSRs. This approach consists of projecting servicing cash flows under multiple interest rate scenarios and discounting these cash flows using risk-adjusted discount rates.
Loans Held-for-sale
The fair values of LHFS are based on quoted market prices, where available, or are determined by discounting estimated cash flows using interest rates approximating the Corporation’s current origination rates for similar loans adjusted to reflect the inherent credit risk. The borrower-specific credit risk is embedded within the quoted market prices or is implied by considering loan performance when selecting comparables.

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

151 Bank of America


Recurring Fair Value
Assets and liabilities carried at fair value on a recurring basis at December 31, 2021 and 2020, including financial instruments that the Corporation accounts for under the fair value option, are summarized in the following tables.
December 31, 2021
 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$707 $ $ $ $707 
Federal funds sold and securities borrowed or purchased under agreements to resell 150,665   150,665 
Trading account assets:     
U.S. Treasury and government agencies44,599 803   45,402 
Corporate securities, trading loans and other 31,601 2,110  33,711 
Equity securities61,425 38,383 190  99,998 
Non-U.S. sovereign debt3,822 25,612 396  29,830 
Mortgage trading loans, MBS and ABS:
U.S. government-sponsored agency guaranteed 25,645 109  25,754 
Mortgage trading loans, ABS and other MBS 10,967 1,418  12,385 
Total trading account assets (2)
109,846 133,011 4,223  247,080 
Derivative assets34,748 310,581 3,133 (313,118)35,344 
AFS debt securities:     
U.S. Treasury and government agencies198,071 1,074   199,145 
Mortgage-backed securities:     
Agency 46,339   46,339 
Agency-collateralized mortgage obligations 3,380   3,380 
Non-agency residential 267 316  583 
Commercial 19,604   19,604 
Non-U.S. securities 11,933   11,933 
Other taxable securities 2,690 71  2,761 
Tax-exempt securities 15,381 52  15,433 
Total AFS debt securities198,071 100,668 439  299,178 
Other debt securities carried at fair value:
U.S. Treasury and government agencies575    575 
Non-agency residential MBS 343 242  585 
Non-U.S. and other securities2,580 5,155   7,735 
Total other debt securities carried at fair value3,155 5,498 242  8,895 
Loans and leases 7,071 748  7,819 
Loans held-for-sale 4,138 317  4,455 
Other assets (3)
7,657 2,915 1,572  12,144 
Total assets (4)
$354,184 $714,547 $10,674 $(313,118)$766,287 
Liabilities     
Interest-bearing deposits in U.S. offices$ $408 $ $ $408 
Federal funds purchased and securities loaned or sold under agreements to repurchase 139,641   139,641 
Trading account liabilities:    
U.S. Treasury and government agencies19,826 313   20,139 
Equity securities41,744 6,491   48,235 
Non-U.S. sovereign debt10,400 13,781   24,181 
Corporate securities and other 8,124 11  8,135 
Total trading account liabilities71,970 28,709 11  100,690 
Derivative liabilities35,282 314,380 5,795 (317,782)37,675 
Short-term borrowings 4,279   4,279 
Accrued expenses and other liabilities8,359 3,130   11,489 
Long-term debt 28,633 1,075  29,708 
Total liabilities (4)
$115,611 $519,180 $6,881 $(317,782)$323,890 
(1)Amounts represent the impact of legally enforceable master netting agreements and also cash collateral held or placed with the same counterparties.
(2)Includes securities with a fair value of $10.6 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. Trading account assets also includes certain commodities inventory of $752 million that is accounted for at the lower of cost or net realizable value, which is the current selling price less any costs to sell.
(3)Includes MSRs of $818 million which are classified as Level 3 assets.
(4)Total recurring Level 3 assets were 0.34 percent of total consolidated assets, and total recurring Level 3 liabilities were 0.24 percent of total consolidated liabilities.
Bank of America 152


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 $— $— $— $1,649 
Federal funds sold and securities borrowed or purchased under agreements to resell— 108,856 — — 108,856 
Trading account assets:     
U.S. Treasury and government agencies45,219 3,051 — — 48,270 
Corporate securities, trading loans and other— 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— 21,566 75 — 21,641 
Mortgage trading loans, ABS and other MBS— 8,440 1,365 — 9,805 
Total trading account assets (2)
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 government agencies115,266 1,114 — — 116,380 
Mortgage-backed securities:     
Agency— 61,849 — — 61,849 
Agency-collateralized mortgage obligations— 5,260 — — 5,260 
Non-agency residential— 631 378 — 1,009 
Commercial— 16,491 — — 16,491 
Non-U.S. securities— 13,999 18 — 14,017 
Other taxable securities— 2,640 71 — 2,711 
Tax-exempt securities— 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 government agencies93 — — — 93 
Non-agency residential MBS— 506 267 — 773 
Non-U.S. and other securities2,619 8,625 — — 11,244 
Total other debt securities carried at fair value2,712 9,131 267 — 12,110 
Loans and leases— 5,964 717 — 6,681 
Loans held-for-sale— 1,349 236 — 1,585 
Other assets (3)
9,898 3,850 1,970 — 15,718 
Total assets (4)
$232,493 $772,037 $9,964 $(387,371)$627,123 
Liabilities     
Interest-bearing deposits in U.S. offices$— $481 $— $— $481 
Federal funds purchased and securities loaned or sold under agreements to repurchase— 135,391 — — 135,391 
Trading account liabilities:    
U.S. Treasury and government agencies9,425 139 — — 9,564 
Equity securities38,189 4,235 — — 42,424 
Non-U.S. sovereign debt5,853 8,043 — — 13,896 
Corporate securities and other— 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 borrowings— 5,874 — — 5,874 
Accrued expenses and other liabilities12,297 4,014 — — 16,311 
Long-term debt— 31,036 1,164 — 32,200 
Total liabilities (5)
$80,671 $607,514 $7,399 $(388,481)$307,103 
(1)Amounts represent the impact of legally enforceable master netting agreements and also cash collateral held or placed with the same counterparties.
(2)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 certain commodities inventory of $576 million that is accounted for at the lower of cost or net realizable value, which is the current selling price less any costs to sell.
(3)Includes MSRs of $1.0 billion which are classified as Level 3 assets.
(4)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.


153 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 2021, 2020 and 2019, including net realized and unrealized gains (losses) included in earnings and accumulated OCI. Transfers into Level 3 occur primarily due to decreased price observability, and
transfers out of Level 3 occur primarily due to increased price observability. Transfers occur on a regular basis for long-term debt instruments due to changes in the impact of unobservable inputs on the value of the embedded derivative in relation to the instrument as a whole.
Level 3 – Fair Value Measurements (1)
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, 2021
Trading account assets:       
Corporate securities, trading loans and other$1,359 $(17)$ $765 $(437)$ $(327)$1,218 $(451)$2,110 $(79)
Equity securities227 (18) 103 (68)  112 (166)190 (44)
Non-U.S. sovereign debt354 31 (20)18   (13)26  396 34 
Mortgage trading loans, ABS and other MBS1,440 (58) 518 (721)7 (167)771 (263)1,527 (91)
Total trading account assets3,380 (62)(20)1,404 (1,226)7 (507)2,127 (880)4,223 (180)
Net derivative assets (liabilities) (4)
(3,468)927  521 (653) 293 (74)(208)(2,662)800 
AFS debt securities:          
Non-agency residential MBS378 (11)(111) (98) (45)304 (101)316 8 
Non-U.S. securities18 (4)  (10) (4)    
Other taxable securities71  (7)8     (1)71  
Tax-exempt securities176 20     (2) (142)52 (19)
Total AFS debt securities643 5 (118)8 (108) (51)304 (244)439 (11)
Other debt securities carried at fair value – Non-agency residential MBS267 1   (45) (37)101 (45)242 10 
Loans and leases (5,6)
717 62  59 (13)70 (180)46 (13)748 65 
Loans held-for-sale (5,6)
236 13 (6)132 (1) (79)26 (4)317 18 
Other assets (6,7)
1,970 7 3 26 (202)144 (383)9 (2)1,572 3 
Trading account liabilities – Corporate securities
   and other
(16)6    (1)   (11) 
Long-term debt (5)
(1,164)(92)13 (6)15 (12)98 (65)138 (1,075)(113)
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)— 78 (53)— (3)58 (49)227 (31)
Non-U.S. sovereign debt482 45 (46)76 (61)— (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)— 120 (646)— (112)(235)178 (3,468)(953)
AFS debt securities:       
Non-agency residential MBS424 (2)23 (54)— (44)158 (130)378 (2)
Non-U.S. securities— — (1)— (1)17 — 18 
Other taxable securities65 — — (4)— — — 71 — 
Tax-exempt securities108 (21)— — — (169)265 (10)176 (20)
Total AFS debt securities599 (22)32 (59)— (214)441 (140)643 (21)
Other debt securities carried at fair value – Non-agency residential MBS299 26 — — (180)— (24)190 (44)267 
Loans and leases (5,6)
693 (4)— 145 (76)22 (161)98 — 717 
Loans held-for-sale (5,6)
375 26 (28)— (489)691 (119)93 (313)236 (5)
Other assets (6,7)
2,360 (288)178 (4)224 (506)(2)1,970 (374)
Trading account liabilities – Equity securities(2)— — — — — — — — 
Trading account liabilities – Corporate securities
   and other
(15)— (7)(3)— — — (16)— 
Long-term debt (5)
(1,149)(46)(104)— (47)218 (52)14 (1,164)(5)
(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 - 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 market making and similar activities and 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 losses of $19 million and $41 million related to financial instruments still held at December 31, 2021 and 2020.
(4)Net derivative assets (liabilities) include derivative assets of $3.1 billion and $2.8 billion and derivative liabilities of $5.8 billion and $6.2 billion at December 31, 2021 and 2020.
(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.

Bank of America 154


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, 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 securities— — — — — — — 108 — 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)
(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 of $3 million related to financial instruments still held at December 31, 2019.
(4)Net derivative assets (liabilities) include derivative assets of $2.2 billion and derivative liabilities of $4.8 billion at December 31, 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 derivative assets to reflect the Corporation's change to present bifurcated embedded derivatives with their respective host instruments.


155 Bank of America


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, 2021 and 2020.
Quantitative Information about Level 3 Fair Value Measurements at December 31, 2021
(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$1,269 Discounted cash flow, Market comparablesYield0% to 25%%
Trading account assets – Mortgage trading loans, ABS and other MBS338 Prepayment speed1% to 40% CPR19% CPR
Loans and leases373 Default rate0% to 3% CDR1% CDR
AFS debt securities – Non-agency residential316 Price$0 to $168$92
Other debt securities carried at fair value – Non-agency residential242 Loss severity0% to 43%13 %
Instruments backed by commercial real estate assets$298 Discounted cash
flow
Yield0% to 25%%
Trading account assets – Corporate securities, trading loans and other138 Price$0 to $101$57
Trading account assets – Mortgage trading loans, ABS and other MBS77 
AFS debt securities – Other taxable securities71 
Loans held-for-sale12 
Commercial loans, debt securities and other$4,212 Discounted cash flow, Market comparablesYield0% to 19%10 %
Trading account assets – Corporate securities, trading loans and other1,972 Prepayment speed10% to 20%16 %
Trading account assets – Non-U.S. sovereign debt396 Default rate3% to 4%%
Trading account assets – Mortgage trading loans, ABS and other MBS1,112 Loss severity35% to 40%37 %
AFS debt securities – Tax-exempt securities52 Price$0 to $189$73
Loans and leases375 Long-dated equity volatilities45%n/a
Loans held-for-sale305 
Other assets, primarily auction rate securities$754 Discounted cash flow, Market comparablesPrice$10 to $96$91

Discount rate%n/a
MSRs$818 Discounted cash
flow
Weighted-average life, fixed rate (5)
0 to 14 years4 years
Weighted-average life, variable rate (5)
0 to 10 years3 years
Option-adjusted spread, fixed rate7% to 14%%
Option-adjusted spread, variable rate9% to 15%12 %
Structured liabilities
Long-term debt$(1,075)
Discounted cash flow, Market comparables, Industry standard derivative pricing (3)
Yield0% to 19%18 %
Equity correlation3% to 100%80 %
Long-dated equity volatilities5% to 78%36 %
Price$0 to $125$82
Natural gas forward price$2/MMBtu to $8/MMBtu$4 /MMBtu
Net derivative assets (liabilities)
Credit derivatives$(104)Discounted cash flow, Stochastic recovery correlation modelCredit spreads7 to 155 bps61 bps
Upfront points16 to 100 points 68 points
Prepayment speed15% CPRn/a
Default rate2% CDRn/a
Credit correlation20% to 60%55 %
Price$0 to $120$53
Equity derivatives$(1,710)
Industry standard derivative pricing (3)
Equity correlation3% to 100%80 %
Long-dated equity volatilities5% to 78%36 %
Commodity derivatives$(976)
Discounted cash flow, Industry standard derivative pricing (3)
Natural gas forward price$2/MMBtu to $8/MMBtu$4 /MMBtu
Correlation65% to 85%76 %
Power forward price$11 to $103$32
Volatilities41% to 69%63 %
Interest rate derivatives$128 
Industry standard derivative pricing (4)
Correlation (IR/IR)(1)% to 90%54 %
Correlation (FX/IR)(1)% to 58%44 %
Long-dated inflation rates
 (10)% to 11%
%
Long-dated inflation volatilities0% to 2%%
Interest rate volatilities0% to 2%%
Total net derivative assets (liabilities)$(2,662)
(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 152: Trading account assets – Corporate securities, trading loans and other of $2.1 billion, Trading account assets – Non-U.S. sovereign debt of $396 million, Trading account assets – Mortgage trading loans, MBS and ABS of $1.5 billion, AFS debt securities of $439 million, Other debt securities carried at fair value - Non-agency residential of $242 million, Other assets, including MSRs, of $1.6 billion, Loans and leases of $748 million and LHFS of $317 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.
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 156


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 comparables
Yield(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 comparablesYield 0% 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 rate8%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)
Yield 0% to 11%%
Equity correlation 2% 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
G(7)% to 84%
14 %
Long-dated inflation volatilities0% to 1%%
Interest rates volatilities0% to 2%%
Total net derivative assets (liabilities)$(3,468)
(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 153: 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, MBS and ABS 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.
CPR = Constant Prepayment Rate
CDR = Constant Default Rate
MMBtu = Million British thermal units
IR = Interest Rate
FX = Foreign Exchange
n/a = not applicable



157 Bank of America


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 levels of aggregation and diversity within the products disclosed in the tables result in certain ranges of inputs being wide and unevenly distributed across asset and liability categories.
Uncertainty of Fair Value Measurements from Unobservable Inputs
Loans and Securities
A significant increase in market yields, default rates, loss severities or duration would have resulted in a significantly lower fair value for long positions. Short positions would have been impacted in a directionally opposite way. The impact of changes in prepayment speeds would have resulted in differing impacts depending on the seniority of the instrument and, in the case of CLOs, whether prepayments can be reinvested. A significant increase in price would have resulted in a significantly higher fair value for long positions, and short positions would have been impacted in a directionally opposite way.
Structured Liabilities and Derivatives
For credit derivatives, a significant increase in market yield,
upfront points (i.e., a single upfront payment made by a protection buyer at inception), credit spreads, default rates or loss severities would have resulted in a significantly lower fair value for protection sellers and higher fair value for protection buyers. The impact of changes in prepayment speeds would have resulted in differing impacts depending on the seniority of the instrument.
Structured credit derivatives are impacted by credit correlation. Default correlation is a parameter that describes the degree of dependence among credit default rates within a credit portfolio that underlies a credit derivative instrument. The sensitivity of this input on the fair value varies depending on the level of subordination of the tranche. For senior tranches that are net purchases of protection, a significant increase in default correlation would have resulted in a significantly higher fair value. Net short protection positions would have been impacted in a directionally opposite way.
For equity derivatives, commodity derivatives, interest rate derivatives and structured liabilities, a significant change in long-dated rates and volatilities and correlation inputs (i.e., the degree of correlation between an equity security and an index, between two different commodities, between two different interest rates, or between interest rates and foreign exchange rates) would have resulted in a significant impact to the fair value; however, the magnitude and direction of the impact depend on whether the Corporation is long or short the exposure. For structured liabilities, a significant increase in yield or decrease in price would have resulted in a significantly lower fair value.
Nonrecurring Fair Value
The Corporation holds certain assets that are measured at fair value only in certain situations (e.g., the impairment of an asset), and these measurements are referred to herein as nonrecurring. The amounts below represent assets still held as of the reporting date for which a nonrecurring fair value adjustment was recorded during 2021, 2020 and 2019.
Assets Measured at Fair Value on a Nonrecurring Basis
December 31, 2021December 31, 2020
(Dollars in millions)
 
Level 2Level 3Level 2Level 3
Assets   
Loans held-for-sale$634 $24 $1,020 $792 
Loans and leases (1)
 213 — 301 
Foreclosed properties (2, 3)
 5 — 17 
Other assets256 2,046 323 576 
Gains (Losses)
202120202019
Assets   
Loans held-for-sale$(44)$(79)$(14)
Loans and leases (1)
(60)(73)(81)
Foreclosed properties(2)(6)(9)
Other assets(492)(98)(2,145)
(1)Includes $24 million, $30 million and $36 million of losses on loans that were written down to a collateral value of zero during 2021, 2020 and 2019, 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 $52 million and $119 million of properties acquired upon foreclosure of certain government-guaranteed loans (principally FHA-insured loans) at December 31, 2021 and 2020.

Bank of America 158


The table below presents information about significant unobservable inputs utilized in the Corporation's nonrecurring Level 3 fair value measurements at December 31, 2021 and 2020.
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)Year Ended December 31, 2021
Loans and leases (2)
$213 Market comparablesOREO discount13% to 59%24 %
Costs to sell8% to 26%%
Other assets (3)
1,875 Discounted cash flowDiscount rate%n/a
166 Market comparablesEstimated appraisal valuen/an/a
Year Ended December 31, 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 (4)
576 Discounted cash flowRevenue attrition2% to 19%%
Discount rate11% to 14%12 %
(1)The weighted average is calculated based upon the fair value of the loans.
(2)Represents residential mortgages where the loan has been written down to the fair value of the underlying collateral.
(3)Represents the fair value of certain impaired renewable energy investments and impaired assets related to the Corporation’s real estate rationalization.
(4)Represents the fair value of the intangible asset related to the merchant contracts received from the dissolution of the Corporation's merchant services joint venture.
n/a = not applicable
NOTE 21 Fair Value Option
Loans and Loan Commitments
The Corporation elects to account for certain loans and loan commitments that exceed the Corporation’s single-name credit risk concentration guidelines under the fair value option. Lending commitments are actively managed and, as appropriate, credit risk for these lending relationships may be mitigated through the use of credit derivatives, with the Corporation’s public side credit view and market perspectives determining the size and timing of the hedging activity. These credit derivatives do not meet the requirements for designation as accounting hedges and therefore are carried at fair value. The fair value option allows the Corporation to carry these loans and loan commitments at fair value, which is more consistent with management’s view of the underlying economics and the manner in which they are managed. In addition, the fair value option allows the Corporation to reduce the accounting volatility that would otherwise result from the asymmetry created by accounting for the financial instruments at historical cost and the credit derivatives at fair value.
Loans Held-for-sale
The Corporation elects to account for residential mortgage LHFS, commercial mortgage LHFS and certain other LHFS under the fair value option. These loans are actively managed and monitored and, as appropriate, certain market risks of the loans may be mitigated through the use of derivatives. The Corporation has elected not to designate the derivatives as qualifying accounting hedges, and therefore, they are carried at fair value. The changes in fair value of the loans are largely offset by changes in the fair value of the derivatives. The fair value option allows the Corporation to reduce the accounting volatility that would otherwise result from the asymmetry created by accounting for the financial instruments at the lower of cost or fair value and the derivatives at fair value. The Corporation has not elected to account for certain other LHFS under the fair value option primarily because these loans are floating-rate loans that are not hedged using derivative instruments.
Loans Reported as Trading Account Assets
The Corporation elects to account for certain loans that are held for the purpose of trading and are risk-managed on a fair value basis under the fair value option.
Other Assets
The Corporation elects to account for certain long-term fixed-rate margin loans that are hedged with derivatives under the fair value option. Election of the fair value option allows the Corporation to reduce the accounting volatility that would otherwise result from the asymmetry created by accounting for the financial instruments at historical cost and the derivatives at fair value.
Securities Financing Agreements
The Corporation elects to account for certain securities financing agreements, including resale and repurchase agreements, under the fair value option based on the tenor of the agreements, which reflects the magnitude of the interest rate risk. The majority of securities 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.
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.

159 Bank of America


The Corporation also elects to account for certain asset-backed secured financings, which are also classified in short-term borrowings, under the fair value option. Election of the fair value option allows the Corporation to reduce the accounting volatility that would otherwise result from the asymmetry created by accounting for the asset-backed secured financings at historical cost and the corresponding mortgage LHFS securing these financings at fair value.

Bank of America 154


Long-term Debt
The Corporation elects to account for certain long-term debt, primarily structured liabilities, under the fair value option. This
long-term debt is either risk-managed on a fair value basis or the related hedges do not qualify for hedge accounting.
Fair Value Option Elections
The following tables provide information about the fair value carrying amount and the contractual principal outstanding of
assets and liabilities accounted for under the fair value option at December 31, 20192021 and 2018,2020, and information about where changes in the fair value of assets and liabilities accounted for under the fair value option are included in the Consolidated Statement of Income for 2019, 20182021, 2020 and 2017.2019.
Fair Value Option Elections
December 31, 2021December 31, 2020
(Dollars in millions)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
Federal funds sold and securities borrowed or purchased under agreements to resell$150,665 $150,677 $(12)$108,856 $108,811 $45 
Loans reported as trading account assets (1)
10,864 18,895 (8,031)7,967 17,372 (9,405)
Trading inventory – other21,986 n/an/a22,790 n/an/a
Consumer and commercial loans7,819 7,888 (69)6,681 6,778 (97)
Loans held-for-sale (1)
4,455 5,343 (888)1,585 2,521 (936)
Other assets544 n/an/a200 n/an/a
Long-term deposits408 401 7 481 448 33 
Federal funds purchased and securities loaned or sold under agreements to repurchase139,641 139,682 (41)135,391 135,390 
Short-term borrowings4,279 4,127 152 5,874 5,178 696 
Unfunded loan commitments97 n/an/a99 n/an/a
Long-term debt29,708 30,903 (1,195)32,200 33,470 (1,270)
            
Fair Value Option Elections
            
 December 31, 2019 December 31, 2018
(Dollars in millions)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
Federal funds sold and securities borrowed or purchased under agreements to resell$50,364
 $50,318
 $46
 $56,399
 $56,376
 $23
Loans reported as trading account assets (1)
6,989
 14,703
 (7,714) 6,195
 13,088
 (6,893)
Trading inventory – other19,574
 n/a
 n/a
 13,778
 n/a
 n/a
Consumer and commercial loans8,335
 8,372
 (37) 4,349
 4,399
 (50)
Loans held-for-sale (1)
3,709
 4,879
 (1,170) 2,942
 4,749
 (1,807)
Other assets4
 n/a
 n/a
 3
 n/a
 n/a
Long-term deposits508
 496
 12
 492
 454
 38
Federal funds purchased and securities loaned or sold under agreements to repurchase16,008
 16,029
 (21) 28,875
 28,881
 (6)
Short-term borrowings3,941
 3,930
 11
 1,648
 1,648
 
Unfunded loan commitments90
 n/a
 n/a
 169
 n/a
 n/a
Long-term debt (2)
34,975
 35,730
 (755) 27,689
 29,198
 (1,509)

(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.
(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.
(2)
Includes structured liabilities with a fair value of $34.6 billion and $27.3 billion, and contractual principal outstanding of $35.3 billion and $28.8 billion at December 31, 2019 and 2018.
n/a = not applicable
      
Gains (Losses) Relating to Assets and Liabilities Accounted for Under the Fair Value Option
      
 Market making and similar activities 
Other
Income
 Total
(Dollars in millions)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
Long-term debt (3)
(1,098) (78) (1,176)
Other (4)
(15) 52
 37
Total (5)
$4,977

$84

$5,061
      
 2018
Loans reported as trading account assets$8
 $
 $8
Trading inventory – other (1)
1,750
 
 1,750
Consumer and commercial loans(422) (53) (475)
Loans held-for-sale (2)
1
 24
 25
Long-term debt (3)
2,157
 (93) 2,064
Other (4)
8
 (31) (23)
Total (5)
$3,502
 $(153) $3,349
      
 2017
Loans reported as trading account assets$318
 $
 $318
Trading inventory – other (1)
3,821
 
 3,821
Consumer and commercial loans(9) 35
 26
Loans held-for-sale (2)

 298
 298
Long-term debt (3)
(1,044) (146) (1,190)
Other (4)
(93) 49
 (44)
Total (5)
$2,993
 $236
 $3,229

(1)
The gains in market making and similar activities are primarily offset by losses on trading liabilities that hedge these assets.
(2)
Includes the value of IRLCs on funded loans, including those sold during the period.
(3)
The net gains (losses) in market making and similar activities relate to the embedded derivatives in structured liabilities and are typically offset by (losses) gains on derivatives and securities that hedge these liabilities. For the cumulative impact of changes in the Corporation’s own credit spreads and the amount recognized in accumulated OCI, see Note 15 – Accumulated Other Comprehensive Income (Loss). For more information on how the Corporation’s own credit spread is determined, see Note 21 – Fair Value Measurements.
(4)
Includes gains (losses) on federal funds sold and securities borrowed or purchased under agreements to resell, long-term deposits, federal funds purchased and securities loaned or sold under agreements to repurchase, short-term borrowings and unfunded loan commitments.
(5)
Gains (losses) related to borrower-specific credit risk were $194 million, $(148) million and $38 million in 2019, 2018 and 2017, respectively.

155Bank of America160




Gains (Losses) Related to Assets and Liabilities Accounted for Under the Fair Value Option
Market making
 and similar
 activities
Other
Income
Total
(Dollars in millions)2021
Loans reported as trading account assets$275 $ $275 
Trading inventory – other (1)
(211) (211)
Consumer and commercial loans78 40 118 
Loans held-for-sale (2)
 58 58 
Short-term borrowings883  883 
Long-term debt (3)
(604)(41)(645)
Other (4)
18 (23)(5)
Total (5)
$439 $34 $473 
2020
Loans reported as trading account assets$107 $— $107 
Trading inventory – other (1)
3,216 — 3,216 
Consumer and commercial loans22 (3)19 
Loans held-for-sale (2)
— 103 103 
Short-term borrowings(170)— (170)
Unfunded loan commitments— (65)(65)
Long-term debt (3)
(2,175)(53)(2,228)
Other (4)
35 (22)13 
Total (5)
$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 commitments— 79 79 
Long-term debt (3)
(1,098)(78)(1,176)
Other (4)
(27)(18)
Total (5)
$4,977 $84 $5,061 

(1)    The gains (losses) in market making and similar activities are primarily offset by (losses) gains 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 losses in market making and similar activities relate to the embedded derivatives in structured liabilities and are typically offset by 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, other assets, long-term deposits and federal funds purchased and securities loaned or sold under agreements to repurchase.
(5)    Gains (losses) related to borrower-specific credit risk were $162 million, $(361) million and $194 million in 2021, 2020 and 2019, respectively.
NOTE 2322 Fair Value of Financial Instruments
Financial instruments are classified within the fair value hierarchy using the methodologies described in Note 2120 – Fair Value Measurements. Certain loans, deposits, long-term debt, and unfunded lending commitments and other financial instruments are accounted for under the fair value option. For more information, see Note 2221 – Fair Value Option. The following disclosures include financial instruments that are not carried at fair value or only a portion of the ending balance is carried at fair value on the Consolidated Balance Sheet.
Short-term Financial Instruments
The carrying value of short-term financial instruments, including cash and cash equivalents, certain time deposits placed and other short-term investments, federal funds sold and purchased, certain resale and repurchase agreements and short-term borrowings, approximates the fair value of these instruments. These financial instruments generally expose the Corporation to
limited credit risk and have no stated maturities or have short-term maturities and carry interest rates that approximate market. The Corporation accounts for certain resale and repurchase agreements under the fair value option.
Under the fair value hierarchy, cash and cash equivalents are classified as Level 1. Time deposits placed and other short-term investments, such as U.S. government securities and short-term commercial paper, are classified as Level 1 or Level 2. Federal funds sold and purchased are classified as Level 2. Resale and repurchase agreements are classified as Level 2 because they are generally short-dated and/or variable-rate instruments collateralized by U.S. government or agency securities. Short-term borrowings are classified as Level 2.
Fair Value of Financial Instruments
The carrying values and fair values by fair value hierarchy of certain financial instruments where only a portion of the ending balance was carried at fair value at December 31, 20192021 and 20182020 are presented in the following table.
        
Fair Value of Financial Instruments
    
   Fair Value
 Carrying Value Level 2 Level 3 Total
(Dollars in millions)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
        
 December 31, 2018
Financial assets       
Loans$911,520
 $58,228
 $859,160
 $917,388
Loans held-for-sale10,367
 9,592
 775
 10,367
Financial liabilities 
      
Deposits (1)
1,381,476
 1,381,239
 
 1,381,239
Long-term debt229,392
 230,019
 817
 230,836
Commercial unfunded lending commitments (2)
966
 169
 5,558
 5,727

(1)161 Bank of America
Includes demand deposits of $545.5 billion and $531.9 billion with no stated maturities at December 31, 2019 and 2018.
(2)


The carrying value of commercial unfunded lending commitments is included in accrued expenses and other liabilities on the Consolidated Balance Sheet. The Corporation does not estimate the fair value of consumer unfunded lending commitments because, in many instances, the Corporation can reduce or cancel these commitments by providing notice to the borrower. For more information on commitments, see Note 13 – Commitments and Contingencies.
Fair Value of Financial Instruments
Fair Value
Carrying ValueLevel 2Level 3Total
(Dollars in millions)December 31, 2021
Financial assets
Loans$946,142 $53,544 $919,980 $973,524 
Loans held-for-sale15,635 15,016 627 15,643 
Financial liabilities
Deposits (1)
2,064,446 2,064,438  2,064,438 
Long-term debt280,117 286,802 1,288 288,090 
Commercial unfunded lending commitments (2)
1,554 97 6,384 6,481 
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 — 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 
(1) Includes demand deposits of $1.0 trillion and $799.0 billion with no stated maturities at December 31, 2021 and 2020.
(2) The carrying value of commercial unfunded lending commitments is included in accrued expenses and other liabilities on the Consolidated Balance Sheet. The Corporation does not estimate the fair value of consumer unfunded lending commitments because, in many instances, the Corporation can reduce or cancel these commitments by providing notice to the borrower. For more information on commitments, see Note 12 – Commitments and Contingencies.
NOTE 2423 Business Segment Information
The Corporation reports its results of operations through the following 4 business segments: Consumer Banking, GWIM, Global Banking and Global Markets, with the remaining operations recorded in All Other.
Consumer Banking
Consumer Banking offers a diversified range of credit, banking and investment products and services to consumers and small businesses. Consumer Banking product offerings include traditional savings accounts, money market savings accounts, CDs and IRAs, checking accounts, and investment accounts and products, as well as credit and debit cards, residential mortgages and home equity loans, and direct and indirect loans to consumers and small businesses in the U.S. Consumer Banking includes the impact of servicing residential mortgages and home equity loans in the core portfolio.loans.
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 and Global Markets under an internal revenue-sharing arrangement. Global Banking clients generally include middle-market companies, commercial real estate firms, not-for-profit companies, large global corporations, financial institutions, leasing clients, and mid-sized U.S.-based businesses requiring customized and integrated financial advice and solutions.
Global Markets
Global Markets offers sales and trading services and research services to institutional clients across fixed-income, credit, currency, commodity and equity businesses. Global Markets provides market-making, financing, securities clearing, settlement and custody services globally to institutional investor clients in support of their investing and trading activities. Global Markets product coverage includes securities and derivative products in both the primary and secondary markets. Global Markets also works with commercial and corporate clients to provide risk management products. As a result of market-making activities, Global Markets may be required to manage risk in a broad range of financial products. In addition, the economics of certain investment banking and underwriting activities are shared primarily between Global Markets and Global Banking under an internal revenue-sharing arrangement.

Bank of America 156


All Other
All Other primarily consists of ALM activities, equity investments, non-core mortgage loans and servicing activities, liquidating businesses and certain expenses not otherwise allocated to a business segments.segment. ALM activities encompass certain residential mortgages, debt securities, interest rate and foreign currency risk management activities. Substantiallyactivities for which substantially all of the results of ALM activities are allocated to the business segments. Equity investments include the merchant services joint venture as well as a portfolio of equity, real estate and other alternative investments.
Basis of Presentation
The management accounting and reporting process derives segment and business results by utilizing allocation methodologies for revenue and expense. The net income derived for the businesses is dependent upon revenue and cost allocations using an activity-based costing model, funds transfer pricing, and other methodologies and assumptions management believes are appropriate to reflect the results of the business.
Total revenue, net of interest expense, includes net interest income on an FTE basis and noninterest income. The adjustment of net interest income to an FTE basis results in a corresponding increase in income tax expense. The segment results also reflect certain revenue and expense methodologies that are utilized to determine net income. The net interest income of the businesses includes the results of a funds transfer pricing process that matches assets and liabilities with similar interest rate sensitivity
and maturity characteristics. In segments where the total of liabilities and equity exceeds assets, which are generally deposit-taking segments, the Corporation allocates assets to match liabilities. Net interest income of the business segments also includes an allocation of net interest income generated by certain of the Corporation’s ALM activities.
The Corporation’s ALM activities include an overall interest rate risk management strategy that incorporates the use of various derivatives and cash instruments to manage fluctuations in earnings and capital that are caused by interest rate volatility. The Corporation’s goal is to manage interest rate sensitivity so that movements in interest rates do not significantly adversely affect earnings and capital. The results of
Bank of America 162


substantially all of the Corporation’s ALM activities are allocated to the business segments and fluctuate based on the performance of the ALM activities. ALM activities include external product pricing decisions including deposit pricing strategies, the effects of the Corporation’s internal funds transfer pricing process and the net effects of other ALM activities.
Certain expenses not directly attributable to a specific business segment are allocated to the segments. The costs of certain centralized or shared functions are allocated based on methodologies that reflect utilization.
Effective October 1, 2021, a business activity previously included in the Global Markets segment is being reported as a liquidating business in All Other, consistent with a realignment
in performance reporting to senior management. While this activity was not material to Global Markets’ results of operations and historical results have not been restated, this activity’s noninterest expense of $309 million and $473 million for the three months ended September 30, 2021 and June 30, 2021 was elevated and would have been excluded from Global Markets’ results of operations for those periods under the new basis of presentation.
The following table below presents net income (loss) and the components thereto (with net interest income on an FTE basis for the business segments, All Other and the total Corporation) for 2019, 20182021, 2020 and 2017,2019, and total assets at December 31, 20192021 and 20182020 for each business segment, as well as All Other.
Results of Business Segments and All Other
At and for the year ended December 31
Total Corporation (1)
Consumer Banking
(Dollars in millions)202120202019202120202019
Net interest income$43,361 $43,859 $49,486 $24,929 $24,698 $28,158 
Noninterest income46,179 42,168 42,353 9,076 8,564 10,429 
Total revenue, net of interest expense89,540 86,027 91,839 34,005 33,262 38,587 
Provision for credit losses(4,594)11,320 3,590 (1,035)5,765 3,772 
Noninterest expense59,731 55,213 54,900 19,290 18,882 17,646 
Income before income taxes34,403 19,494 33,349 15,750 8,615 17,169 
Income tax expense2,425 1,600 5,919 3,859 2,111 4,207 
Net income$31,978 $17,894 $27,430 $11,891 $6,504 $12,962 
Period-end total assets$3,169,495 $2,819,627 0$1,131,142 $988,580 
 Global Wealth & Investment ManagementGlobal Banking
 202120202019202120202019
Net interest income$5,664 $5,468 $6,504 $8,511 $9,013 $10,675 
Noninterest income15,084 13,116 13,034 12,364 9,974 9,808 
Total revenue, net of interest expense20,748 18,584 19,538 20,875 18,987 20,483 
Provision for credit losses(241)357 82 (3,201)4,897 414 
Noninterest expense15,258 14,160 13,825 10,632 9,342 9,011 
Income before income taxes5,731 4,067 5,631 13,444 4,748 11,058 
Income tax expense1,404 996 1,380 3,630 1,282 2,985 
Net income$4,327 $3,071 $4,251 $9,814 $3,466 $8,073 
Period-end total assets$438,275 $369,736 0$638,131 $580,561 
 Global MarketsAll Other
 202120202019202120202019
Net interest income$4,011 $4,646 $3,915 $246 $34 $234 
Noninterest income15,244 14,119 11,699 (5,589)(3,605)(2,617)
Total revenue, net of interest expense19,255 18,765 15,614 (5,343)(3,571)(2,383)
Provision for credit losses65 251 (9)(182)50 (669)
Noninterest expense13,032 11,417 10,728 1,519 1,412 3,690 
Income (loss) before income taxes6,158 7,097 4,895 (6,680)(5,033)(5,404)
Income tax expense (benefit)1,601 1,845 1,395 (8,069)(4,634)(4,048)
Net income (loss)$4,557 $5,252 $3,500 $1,389 $(399)$(1,356)
Period-end total assets$747,794 $616,609 0$214,153 $264,141 
(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) 2019 2018 2017 2019 2018 2017
Net interest income $49,486
 $48,772
 $46,164
 $28,158
 $27,025
 $24,203
Noninterest income 42,353
 42,858
 41,887
 10,429
 10,593
 10,101
Total revenue, net of interest expense 91,839
 91,630
 88,051
 38,587
 37,618
 34,304
Provision for credit losses 3,590
 3,282
 3,396
 3,772
 3,664
 3,525
Noninterest expense 54,900
 53,154
 54,517
 17,618
 17,672
 17,847
Income before income taxes 33,349
 35,194
 30,138
 17,197
 16,282
 12,932
Income tax expense 5,919
 7,047
 11,906
 4,213
 4,150
 4,897
Net income $27,430
 $28,147
 $18,232
 $12,984
 $12,132
 $8,035
Period-end total assets $2,434,079
 $2,354,507
   $804,019
 $768,881
  
             
  
Global Wealth &
Investment Management
 Global Banking
  2019 2018 2017 2019 2018 2017
Net interest income $6,504
 $6,265
 $6,152
 $10,675
 $10,993
 $10,615
Noninterest income 13,033
 13,188
 12,447
 9,808
 9,008
 9,510
Total revenue, net of interest expense 19,537
 19,453
 18,599
 20,483
 20,001
 20,125
Provision for credit losses 82
 86
 56
 414
 8
 212
Noninterest expense 13,823
 14,015
 13,770
 9,017
 8,745
 8,811
Income before income taxes 5,632
 5,352
 4,773
 11,052
 11,248
 11,102
Income tax expense 1,380
 1,364
 1,807
 2,984
 2,923
 4,204
Net income $4,252
 $3,988
 $2,966
 $8,068
 $8,325
 $6,898
Period-end total assets $299,756
 $305,907
  
 $464,032
 $442,330
  
             
  Global Markets All Other
  2019 2018 2017 2019 2018 2017
Net interest income $3,915
 $3,857
 $4,264
 $234

$632

$930
Noninterest income 11,699
 12,326
 11,698
 (2,616)
(2,257)
(1,869)
Total revenue, net of interest expense 15,614
 16,183
 15,962
 (2,382) (1,625) (939)
Provision for credit losses (9) 
 164
 (669) (476) (561)
Noninterest expense 10,722
 10,835
 10,997
 3,720
 1,887
 3,092
Income (loss) before income taxes 4,901
 5,348
 4,801
 (5,433) (3,036) (3,470)
Income tax expense (benefit) 1,397
 1,390
 1,666
 (4,055) (2,780) (668)
Net income (loss) $3,504
 $3,958
 $3,135
 $(1,378) $(256) $(2,802)
Period-end total assets $641,806
 $641,923
   $224,466
 $195,466
  
(1)
There were no material intersegment revenues.

157163 Bank of America






The tabletables below presentspresent noninterest income and the associated components thereto for 2019, 20182021, 2020 and 20172019 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)202120202019202120202019202120202019
Fees and commissions:
Card income
Interchange fees$4,560 $3,954 $3,834 $3,597 $3,027 $3,174 $43 $36 $59 
Other card income1,658 1,702 1,963 1,575 1,646 1,910 42 42 42 
Total card income6,218 5,656 5,797 5,172 4,673 5,084 85 78 101 
Service charges
Deposit-related fees6,271 5,991 6,588 3,538 3,417 4,218 72 67 68 
Lending-related fees1,233 1,150 1,086  — —  — — 
Total service charges7,504 7,141 7,674 3,538 3,417 4,218 72 67 68 
Investment and brokerage services
Asset management fees12,729 10,708 10,241 188 146 144 12,541 10,578 10,130 
Brokerage fees3,961 3,866 3,661 132 127 149 1,771 1,692 1,740 
Total investment and brokerage services16,690 14,574 13,902 320 273 293 14,312 12,270 11,870 
Investment banking fees
Underwriting income5,077 4,698 2,998  — — 388 391 401 
Syndication fees1,499 861 1,184  — —  — — 
Financial advisory services2,311 1,621 1,460  — —  — — 
Total investment banking fees8,887 7,180 5,642  — — 388 391 401 
Total fees and commissions39,299 34,551 33,015 9,030 8,363 9,595 14,857 12,806 12,440 
Market making and similar activities8,691 8,355 9,034 1 40 63 113 
Other income (loss)(1,811)(738)304 45 199 828 187 247 481 
Total noninterest income$46,179 $42,168 $42,353 $9,076 $8,564 $10,429 $15,084 $13,116 $13,034 
Global BankingGlobal Markets
All Other (1)
202120202019202120202019202120202019
Fees and commissions:
Card income
Interchange fees$700 $499 $519 $220 $391 $81 $ $$
Other card income13 14 13  — (1)28 — (1)
Total card income713 513 532 220 391 80 28 — 
Service charges
Deposit-related fees2,508 2,298 2,121 146 177 156 7 32 25 
Lending-related fees1,015 940 894 218 210 192  — — 
Total service charges3,523 3,238 3,015 364 387 348 7 32 25 
Investment and brokerage services
Asset management fees — —  — —  (16)(33)
Brokerage fees104 74 34 1,979 1,973 1,738 (25)— — 
Total investment and brokerage services104 74 34 1,979 1,973 1,738 (25)(16)(33)
Investment banking fees
Underwriting income2,187 2,070 1,227 2,725 2,449 1,555 (223)(212)(185)
Syndication fees781 482 574 718 379 610  — — 
Financial advisory services2,139 1,458 1,336 173 163 123 (1)— 
Total investment banking fees5,107 4,010 3,137 3,616 2,991 2,288 (224)(212)(184)
Total fees and commissions9,447 7,835 6,718 6,179 5,742 4,454 (214)(195)(192)
Market making and similar activities145 103 235 8,760 8,471 7,065 (255)(284)1,615 
Other income (loss)2,772 2,036 2,855 305 (94)180 (5,120)(3,126)(4,040)
Total noninterest income$12,364 $9,974 $9,808 $15,244 $14,119 $11,699 $(5,589)$(3,605)$(2,617)
                  
Noninterest Income by Business Segment and All Other          
                  
 Total Corporation Consumer Banking 
Global Wealth &
Investment Management
(Dollars in millions)2019 2018 2017 2019 2018 2017 2019 2018 2017
Fees and commissions:                 
Card income                 
Interchange fees$3,834
 $3,866
 $3,777
 $3,174
 $3,196
 $3,038
 $60
 $81
 $109
Other card income1,963
 1,958
 1,899
 1,910

1,906

1,846

41

46

44
Total card income5,797

5,824
 5,676
 5,084
 5,102
 4,884
 101
 127
 153
Service charges                 
Deposit-related fees6,588
 6,667
 6,708
 4,219
 4,300
 4,266
 68
 73
 77
Lending-related fees1,086
 1,100
 1,110
 










Total service charges7,674

7,767
 7,818
 4,219
 4,300
 4,266
 68
 73
 77
Investment and brokerage services                 
Asset management fees10,241
 10,189
 9,310
 144
 147
 133
 10,130
 10,042
 9,177
Brokerage fees3,661
 3,971
 4,526
 149

172

184

1,740

1,917

2,217
Total investment and brokerage services13,902

14,160
 13,836
 293
 319
 317
 11,870
 11,959
 11,394
Investment banking fees                 
Underwriting income2,998
 2,722
 2,821
 
 (1) 
 401
 335
 316
Syndication fees1,184
 1,347
 1,499
 
 
 
 
 
 
Financial advisory services1,460
 1,258
 1,691
 


 



2
 2
Total investment banking fees5,642

5,327
 6,011



(1)


401

337

318
Total fees and commissions33,015

33,078

33,341

9,596

9,720

9,467

12,440

12,496

11,942
Market making and similar activities9,034
 9,008
 7,102
 6
 8
 3
 113
 112
 144
Other income304
 772
 1,444
 827
 865
 631
 480
 580
 361
Total noninterest income$42,353

$42,858

$41,887

$10,429

$10,593

$10,101

$13,033

$13,188
 $12,447
                  
 Global Banking Global Markets 
All Other (1)
 2019 2018 2017 2019 2018 2017 2019 2018 2017
Fees and commissions:                 
Card income                 
Interchange fees$519
 $503
 $478
 $81
 $86
 $86
 $
 $

$66
Other card income13

8

12

(1)
(2)
(2)

 
 (1)
Total card income532
 511
 490
 80
 84
 84
 
 
 65
Service charges            

 

 

Deposit-related fees2,121
 2,111
 2,197
 156
 161
 147
 24
 22
 21
Lending-related fees894

916

928

192

184

182


 
 
Total service charges3,015
 3,027
 3,125
 348
 345
 329
 24
 22
 21
Investment and brokerage services            

 

 

Asset management fees
 
 
 
 
 
 (33) 
 
Brokerage fees34

94

97

1,738

1,780

2,049


 8
 (21)
Total investment and brokerage services34
 94
 97
 1,738
 1,780
 2,049
 (33) 8
 (21)
Investment banking fees            

 

 

Underwriting income1,227
 1,090
 1,172
 1,555
 1,495
 1,588
 (185) (197) (255)
Syndication fees574
 648
 742
 610
 698
 756
 
 1
 1
Financial advisory services1,336

1,153

1,557

123

103

133

1
 
 (1)
Total investment banking fees3,137
 2,891
 3,471
 2,288
 2,296
 2,477
 (184) (196) (255)
Total fees and commissions6,718

6,523

7,183

4,454

4,505

4,939

(193) (166) (190)
Market making and similar activities235
 260
 134
 7,065
 7,260
 6,203
 1,615
 1,368
 618
Other income2,855
 2,225
 2,193
 180
 561
 556
 (4,038) (3,459) (2,297)
Total noninterest income$9,808

$9,008

$9,510

$11,699

$12,326

$11,698

$(2,616) $(2,257) $(1,869)
(1)All Other includes eliminations of intercompany transactions.
(1)

All Other includes eliminations of intercompany transactions.

Bank of America 158164


      
Business Segment Reconciliations     
      
(Dollars in millions)2019 2018 2017
Segments’ total revenue, net of interest expense$94,221
 $93,255
 $88,990
Adjustments (1):
 
  
  
ALM activities241
 (325) 161
Liquidating businesses, eliminations and other(2,623) (1,300) (1,100)
FTE basis adjustment(595) (610) (925)
Consolidated revenue, net of interest expense$91,244
 $91,020
 $87,126
Segments’ total net income28,808
 28,403
 21,034
Adjustments, net-of-tax (1):
   
  
ALM activities202
 (222) 154
Liquidating businesses, eliminations and other(1,580) (34) (2,956)
Consolidated net income$27,430
 $28,147
 $18,232
      
   December 31
   2019 2018
Segments’ total assets  $2,209,613
 $2,159,041
Adjustments (1):
   
  
ALM activities, including securities portfolio  721,806
 669,204
Elimination of segment asset allocations to match liabilities  (565,346) (540,798)
Other  68,006
 67,060
Consolidated total assets  $2,434,079
 $2,354,507

(1)
Adjustments include consolidated income, expense and asset amounts not specifically allocated to individual business segments.

Business Segment Reconciliations
(Dollars in millions)202120202019
Segments’ total revenue, net of interest expense$94,883 $89,598 $94,222 
Adjustments (1):
   
Asset and liability management activities(4)375 241 
Liquidating businesses, eliminations and other(5,339)(3,946)(2,624)
FTE basis adjustment(427)(499)(595)
Consolidated revenue, net of interest expense$89,113 $85,528 $91,244 
Segments’ total net income30,589 18,293 28,786 
Adjustments, net-of-tax (1):
  
Asset and liability management activities11 279 202 
Liquidating businesses, eliminations and other1,378 (678)(1,558)
Consolidated net income$31,978 $17,894 $27,430 
December 31
20212020
Segments’ total assets$2,955,342 $2,555,486 
Adjustments (1):
 
Asset and liability management activities, including securities portfolio1,363,626 1,176,071 
Elimination of segment asset allocations to match liabilities(1,216,891)(977,685)
Other67,418 65,755 
Consolidated total assets$3,169,495 $2,819,627 
(1)Adjustments include consolidated income, expense and asset amounts not specifically allocated to individual business segments.
NOTE 2524 Parent Company Information
The following tables present the Parent Company-only financial information.
      
Condensed Statement of Income     
      
(Dollars in millions)2019 2018 2017
Income 
  
  
Dividends from subsidiaries: 
  
  
Bank holding companies and related subsidiaries$27,820
 $28,575
 $12,088
Nonbank companies and related subsidiaries
 91
 202
Interest from subsidiaries9,502
 8,425
 7,043
Other income (loss)74
 (1,025) 28
Total income37,396
 36,066
 19,361
Expense 
  
  
Interest on borrowed funds from related subsidiaries451
 235
 189
Other interest expense5,899
 6,425
 5,555
Noninterest expense1,641
 1,600
 1,672
Total expense7,991
 8,260
 7,416
Income before income taxes and equity in undistributed earnings of subsidiaries29,405
 27,806
 11,945
Income tax expense (benefit)341
 (281) 950
Income before equity in undistributed earnings of subsidiaries29,064
 28,087
 10,995
Equity in undistributed earnings (losses) of subsidiaries: 
  
  
Bank holding companies and related subsidiaries(1,717) 306
 8,725
Nonbank companies and related subsidiaries83
 (246) (1,488)
Total equity in undistributed earnings of subsidiaries(1,634) 60
 7,237
Net income$27,430
 $28,147
 $18,232


159Bank of America






    
Condensed Balance Sheet   
    
 December 31
(Dollars in millions)2019 2018
Assets 
  
Cash held at bank subsidiaries (1)
$5,695
 $5,141
Securities656
 628
Receivables from subsidiaries:   
Bank holding companies and related subsidiaries173,301
 152,905
Banks and related subsidiaries51
 195
Nonbank companies and related subsidiaries391
 969
Investments in subsidiaries:   
Bank holding companies and related subsidiaries297,465
 293,045
Nonbank companies and related subsidiaries3,663
 3,432
Other assets9,438
 14,696
Total assets$490,660
 $471,011
Liabilities and shareholders’ equity 
  
Accrued expenses and other liabilities$13,381
 $8,828
Payables to subsidiaries:   
Banks and related subsidiaries458
 349
Nonbank companies and related subsidiaries12,102
 13,301
Long-term debt199,909
 183,208
Total liabilities225,850
 205,686
Shareholders’ equity264,810
 265,325
Total liabilities and shareholders’ equity$490,660
 $471,011
(1)
Balance includes third-party cash held of $4 million and $389 million at December 31, 2019 and 2018.
      
Condensed Statement of Cash Flows     
      
(Dollars in millions)2019 2018 2017
Operating activities 
  
  
Net income$27,430
 $28,147
 $18,232
Reconciliation of net income to net cash provided by (used in) operating activities: 
  
  
Equity in undistributed (earnings) losses of subsidiaries1,634
 (60) (7,237)
Other operating activities, net16,973
 (3,706) (2,593)
Net cash provided by operating activities46,037
 24,381
 8,402
Investing activities 
  
  
Net sales (purchases) of securities(17) 51
 312
Net payments to subsidiaries(19,121) (2,262) (7,087)
Other investing activities, net7
 48
 (1)
Net cash used in investing activities(19,131) (2,163) (6,776)
Financing activities 
  
  
Net increase (decrease) in other advances(1,625) 3,867
 (6,672)
Proceeds from issuance of long-term debt29,315
 30,708
 37,704
Retirement of long-term debt(21,039) (29,413) (29,645)
Proceeds from issuance of preferred stock3,643
 4,515
 
Redemption of preferred stock(2,568) (4,512) 
Common stock repurchased(28,144) (20,094) (12,814)
Cash dividends paid(5,934) (6,895) (5,700)
Net cash used in financing activities(26,352) (21,824) (17,127)
Net increase (decrease) in cash held at bank subsidiaries554
 394
 (15,501)
Cash held at bank subsidiaries at January 15,141
 4,747
 20,248
Cash held at bank subsidiaries at December 31$5,695
 $5,141
 $4,747


Condensed Statement of Income
(Dollars in millions)202120202019
Income   
Dividends from subsidiaries:   
Bank holding companies and related subsidiaries$15,621 $10,352 $27,820 
Interest from subsidiaries8,362 8,825 9,502 
Other income (loss)(114)(138)74 
Total income23,869 19,039 37,396 
Expense   
Interest on borrowed funds from subsidiaries54 136 451 
Other interest expense3,383 4,119 5,899 
Noninterest expense1,531 1,651 1,641 
Total expense4,968 5,906 7,991 
Income before income taxes and equity in undistributed earnings of subsidiaries18,901 13,133 29,405 
Income tax expense886 649 341 
Income before equity in undistributed earnings of subsidiaries18,015 12,484 29,064 
Equity in undistributed earnings (losses) of subsidiaries:   
Bank holding companies and related subsidiaries14,078 5,372 (1,717)
Nonbank companies and related subsidiaries(115)38 83 
Total equity in undistributed earnings (losses) of subsidiaries13,963 5,410 (1,634)
Net income$31,978 $17,894 $27,430 
165 Bank of America


Condensed Balance Sheet
 December 31
(Dollars in millions)20212020
Assets  
Cash held at bank subsidiaries$5,011 $5,893 
Securities671 701 
Receivables from subsidiaries:
Bank holding companies and related subsidiaries217,447 206,566 
Banks and related subsidiaries347 213 
Nonbank companies and related subsidiaries368 410 
Investments in subsidiaries:
Bank holding companies and related subsidiaries316,497 305,818 
Nonbank companies and related subsidiaries3,645 3,715 
Other assets8,602 9,850 
Total assets$552,588 $533,166 
Liabilities and shareholders’ equity  
Accrued expenses and other liabilities$17,394 $15,965 
Payables to subsidiaries:
Banks and related subsidiaries107 129 
Bank holding companies and related subsidiaries3 — 
Nonbank companies and related subsidiaries11,564 11,067 
Long-term debt253,454 233,081 
Total liabilities282,522 260,242 
Shareholders’ equity270,066 272,924 
Total liabilities and shareholders’ equity$552,588 $533,166 
Condensed Statement of Cash Flows
(Dollars in millions)202120202019
Operating activities   
Net income$31,978 $17,894 $27,430 
Reconciliation of net income (loss) to net cash provided by (used in) operating activities:   
Equity in undistributed (earnings) losses of subsidiaries(13,963)(5,410)1,634 
Other operating activities, net(7,144)14,303 16,973 
Net cash provided by operating activities10,871 26,787 46,037 
Investing activities   
Net purchases of securities(14)(4)(17)
Net payments to subsidiaries(10,796)(33,111)(19,121)
Other investing activities, net(26)(7)
Net cash used in investing activities(10,836)(33,122)(19,131)
Financing activities   
Net increase (decrease) in other advances503 (422)(1,625)
Proceeds from issuance of long-term debt56,106 43,766 29,315 
Retirement of long-term debt(24,544)(23,168)(21,039)
Proceeds from issuance of preferred stock and warrants2,170 2,181 3,643 
Redemption of preferred stock(1,971)(1,072)(2,568)
Common stock repurchased(25,126)(7,025)(28,144)
Cash dividends paid(8,055)(7,727)(5,934)
Net cash provided by (used in) financing activities(917)6,533 (26,352)
Net increase (decrease) in cash held at bank subsidiaries(882)198 554 
Cash held at bank subsidiaries at January 15,893 5,695 5,141 
Cash held at bank subsidiaries at December 31$5,011 $5,893 $5,695 
Bank of America 160166



NOTE 2625 Performance by Geographical Area
The Corporation’s operations are highly integrated with operations in both U.S. and non-U.S. markets. The non-U.S. business activities are largely conducted in Europe, the Middle East and Africa and in Asia. The Corporation identifies its geographic performance based on the business unit structure used to manage the capital or expense deployed in the region
as applicable. This
requires certain judgments related to the allocation of revenue so that revenue can be appropriately matched with the related capital or expense deployed in the region. Certain asset, liability, income and expense amounts have been allocated to arrive at total assets, total revenue, net of interest expense, income before income taxes and net income by geographic area as presented below.
(Dollars in millions) 
Total Assets at Year End (1)
Total Revenue, Net of Interest Expense (2)
Income Before Income TaxesNet Income
U.S. (3)
2021$2,789,862 $78,012 $31,392 $27,781 
 20202,490,247 75,576 18,247 16,692 
 201981,236 30,699 25,937 
Asia2021117,085 4,439 988 733 
 202099,283 4,232 1,051 788 
 20193,491 765 570 
Europe, Middle East and Africa2021233,356 5,423 1,097 3,134 
 2020202,701 4,491 (596)264 
 20195,310 921 672 
Latin America and the Caribbean202129,192 1,239 499 330 
 202027,396 1,229 293 150 
 20191,207 369 251 
Total Non-U.S. 2021379,633 11,101 2,584 4,197 
 2020329,380 9,952 748 1,202 
 201910,008 2,055 1,493 
Total Consolidated2021$3,169,495 $89,113 $33,976 $31,978 
 20202,819,627 85,528 18,995 17,894 
 201991,244 32,754 27,430 
(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.
          
(Dollars in millions)  
Total Assets at Year End (1)
 
Total Revenue, Net of Interest Expense (2)
 Income Before Income Taxes Net Income
U.S. (3)
2019 $2,122,734
 $81,236
 $30,699
 $25,937
 2018 2,051,182
 80,777
 31,904
 26,407
 2017   74,604
 25,108
 15,550
Asia2019 102,440
 3,491
 765
 570
 2018 94,865
 3,507
 865
 520
 2017   3,405
 676
 464
Europe, Middle East and Africa2019 178,889
 5,310
 921
 672
 2018 185,285
 5,632
 1,543
 1,126
 2017   7,907
 2,990
 1,926
Latin America and the Caribbean2019 30,016
 1,207
 369
 251
 2018 23,175
 1,104
 272
 94
 2017   1,210
 439
 292
Total Non-U.S. 2019 311,345
 10,008
 2,055
 1,493
 2018 303,325
 10,243
 2,680
 1,740
 2017   12,522
 4,105
 2,682
Total Consolidated2019 $2,434,079
 $91,244
 $32,754
 $27,430
 2018 2,354,507
 91,020
 34,584
 28,147
 2017   87,126
 29,213
 18,232
(1)
Total assets include long-lived assets, which are primarily located in the U.S.
(2)
There were no material intercompany revenues between geographic regions for any of the periods presented.
(3)
Substantially reflects the U.S.

161167 Bank of America






Glossary
Alt-A Mortgage A type of U.S. mortgage that is considered riskier than A-paper, or “prime,” and less risky than “subprime,” the riskiest category. Typically, Alt-A mortgages are characterized by borrowers with less than full documentation, lower credit scores and higher LTVs.
Assets Under Management (AUM) – The total market value of assets under the investment advisory and/or discretion of GWIM which generate asset management fees based on a percentage of the assets’ market values. AUM reflects assets that are generally managed for institutional, high net worth and retail clients, and are distributed through various investment products including mutual funds, other commingled vehicles and separate accounts.
Banking Book – All on- and off-balance sheet financial instruments of the Corporation except for those positions that are held for trading purposes.
Brokerage and Other Assets – Non-discretionary client assets which are held in brokerage accounts or held for safekeeping.
Committed Credit Exposure – Any funded portion of a facility plus the unfunded portion of a facility on which the lender is legally bound to advance funds during a specified period under prescribed conditions.
Credit Derivatives – Contractual agreements that provide protection against a specified credit event on one or more referenced obligations.
Credit Valuation Adjustment (CVA) – A portfolio adjustment required to properly reflect the counterparty credit risk exposure as part of the fair value of derivative instruments.
Debit Valuation Adjustment (DVA) – A portfolio adjustment required to properly reflect the Corporation’s own credit risk exposure as part of the fair value of derivative instruments and/or structured liabilities.
Funding Valuation Adjustment (FVA) – A portfolio adjustment required to include funding costs on uncollateralized derivatives and derivatives where the Corporation is not permitted to use the collateral it receives.
Interest Rate Lock Commitment (IRLC) – Commitment with a loan applicant in which the loan terms are guaranteed for a designated period of time subject to credit approval.
Letter of Credit – A document issued on behalf of a customer to a third party promising to pay the third party upon presentation of specified documents. A letter of credit effectively substitutes the issuer’s credit for that of the customer.

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



Bank of America 162168


Key Metrics
Active Digital Banking Users Mobile and/or online active users over the past 90 days.
Active Mobile Banking Users – Mobile active users over the past 90 days.
Book Value – Ending common shareholders’ equity divided by ending common shares outstanding.
Deposit Spread Annualized net interest income divided by average deposits.
Dividend Payout Ratio – Common dividends declared divided by net income applicable to common shareholders.
Efficiency Ratio – Noninterest expense divided by total revenue, net of interest expense.
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.
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.
Risk-adjusted Margin – Difference between total revenue, net of interest expense, and net credit losses divided by average loans.
169 Bank of America


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
ARRAlternative reference rates
AUMAssets under management
AVMAutomated valuation model
BANABank of America, National Association
BHCBank holding company
BofAS
BofASBofA Securities, Inc.
BofASEBofA Securities Europe SA
bpsbasisBasis points
CAEChief Audit Executive
CAOChief Administrative Officer
CCARComprehensive Capital Analysis and Review
CDOCollateralized debt obligation
CDSCredit default swap
CET1CECLCurrent expected credit losses
CET1Common equity tier 1
CFPBConsumer Financial Protection Bureau
CLOCFTCCollateralized loan obligation
CFTCCommodity Futures Trading Commission
CLTVCombined loan-to-value
CROCLOCollateralized loan obligation
CLTVCombined loan-to-value
CROChief Risk Officer
CVACredit valuation adjustment
DIFDeposit Insurance Fund
DVADebit valuation adjustment
EADExposure at default
EMRCECLExpected credit losses
EMRCEnterprise Model Risk Committee
EPSEarnings per common share
ERCEnterprise Risk Committee
EUESGEuropean UnionEnvironmental, social and governance
FCAEUEuropean Union
FCAFinancial Conduct Authority
FDICFederal Deposit Insurance Corporation
FDICIAFederal Deposit Insurance Corporation Improvement Act of 1991
FHA
FHAFederal Housing Administration
FHFAFederal Housing Finance Agency
FHLBFederal Home Loan Bank
FHLMCFreddie Mac
FICCFixed-income,Fixed income, currencies and commodities
FICOFair Isaac Corporation (credit score)
FLUsFront line units
FNMAFannie Mae
FTEFNMAFully taxable-equivalentFannie Mae
FVAFTEFully taxable-equivalent
FVAFunding valuation adjustment
GAAPAccounting principles generally accepted in the United States of America
GDPRGeneral Data Protection Regulation
GLSGlobal Liquidity Sources
GNMAGovernment National Mortgage Association
GRMGlobal Risk Management
GSEGovernment-sponsored enterprise
G-SIBGlobal systemically important bank
GWIMGlobal Wealth & Investment Management
HELOCHome equity line of credit
HQLAHigh Quality Liquid Assets
HTMHeld-to-maturity
IBORInterbank Offered Rates
ICAAPInternal Capital Adequacy Assessment Process
IRMIndependent Risk Management
IBORInterbank Offered Rates
IRLCInterest rate lock commitment
ISDAInternational Swaps and Derivatives Association, Inc.
LCRLiquidity Coverage Ratio
LGDLoss given default
LHFSLoans held-for-sale
LIBORLondon Interbank 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
NOLMWMMerrill Wealth Management
NOLNet operating loss
NSFRNet Stable Funding Ratio
OCC
OCCOffice of the Comptroller of the Currency
OCI
OCIOther comprehensive income
OREOOther real estate owned
OTCOver-the-counter
OTTIOther-than-temporary impairment
PCAPrompt Corrective Action
RMBS
PPPPaycheck Protection Program
RMBSResidential mortgage-backed securities
RSURestricted stock unit
SBLCRWARisk-weighted assets
SBASmall Business Administration
SBLCStandby letter of credit
SCCLSingle-counterparty credit limits
SBSDsSCBSecurity-based swap dealersStress capital buffer
SEC
SECSecurities and Exchange Commission
SLRSupplementary leverage ratio
SOFR
SOFRSecured Overnight Financing Rate
TDRTroubled debt restructurings
TLACTotal loss-absorbing capacity
VA
UDAAPUnfair, deceptive, or abusive acts or practices
VAU.S. Department of Veterans Affairs
VaRValue-at-Risk
VIEVariable interest entity


163Bank of America170







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.
Report of Management on Internal Control Over Financial Reporting
The Report of Management on Internal Control over Financial Reporting is set forth on page 8687 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 pages 8788 and 8889 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, 2019,2021, that materially affected, or are reasonably likely to materially affect, our internal control over financial reporting.
Item 9B. Other Information
NoneAmendment to the Bylaws of Bank of America Corporation
On February 22, 2022, the Board approved and adopted an amendment to the Bylaws of Bank of America Corporation, as amended and restated by the Board on September 23, 2020 (Bylaws). The amendment to the Bylaws was effective as of the date approved by the Board.
As part of the amendment, the Board adopted a new Article IX, Section 6 designating the Delaware Court of Chancery as the exclusive forum for certain legal actions (Delaware exclusive forum provision). The Delaware exclusive forum provision provides that, unless the Corporation consents in writing to the selection of an alternative forum, the following actions shall be solely and exclusively brought in the Court of Chancery of the State of Delaware (or, if the Delaware Court of Chancery in the State of Delaware determines that it lacks jurisdiction over any such action or proceeding, another state or federal court located within the State of Delaware): (i) any derivative action or proceeding brought on behalf of the Corporation, (ii) any action asserting a claim of breach of a fiduciary duty owed by any current or former director, officer, or other employee or agent or stockholder of the Corporation to the Corporation or the Corporation’s stockholders, including a claim alleging the aiding and abetting of such a breach of fiduciary duty, (iii) any action asserting a claim against the Corporation or any current or former director, officer or other employee or agent of the Corporation arising pursuant to any provision of the Delaware
General Corporation Law (DGCL) or the Corporation’s Certificate of Incorporation or Bylaws, or as to which the DGCL confers jurisdiction on the Court of Chancery of the State of Delaware; (iv) any action asserting a claim governed by the internal affairs doctrine of the State of Delaware; or (v) any action asserting an “internal corporate claim” as that term is defined in Section 115 of the DGCL.
Although the Delaware exclusive forum provision took effect immediately upon adoption by the Board, the Board determined, including based on input from our shareholders during our engagement process, that it would be beneficial in this instance, to submit it to shareholders for voluntary ratification at the Corporation’s 2022 annual meeting of shareholders with the understanding that, if shareholders fail to ratify the Delaware exclusive forum provision, the Board will amend the Bylaws to remove it.
The Bylaws amendment also related to other governance practices, including the following:
Adoption of gender-neutral language throughout the Bylaws, including using the title “Chair” in place of “Chairman”
Clarification that the notice to stockholder requirements apply except as otherwise provided within the bylaws or as permitted by law (Article III. Stockholders, Section 4. Notice to Stockholders)
Clarification that exemption from the majority voting standard refers to the chair of a stockholders’ meeting and that the election of directors and of the chair of a stockholders’ meeting are excluded from the Voting of Shares provision because they are covered elsewhere within the Bylaws (Article III. Stockholders, Section 9. Voting of Shares)
Clarification to specify the delivery method of notice for nominations or other business to be properly brought before an annual meeting (Article III. Stockholders, Section 12. Notice of Stockholder Business and Nominations)
Clarification that Board committees may exercise the authority of the Board to the extent and as provided by the Board (Article IV. Board of Directors, Section 6. Committees)
Revision to specify the method of delivery for the notice of director nomination and to clarify that any notification by a stockholder to correct any inaccuracy or omission in their submission does not cure any defect or limit the Corporation’s rights to omit a stockholder nominee from its proxy materials (Article IV. Board of Directors, Section 9. Inclusion of Director Nominations by Stockholders in the Corporation’s Proxy Materials)
Clarification that if a quorum is not present, a directors’ meeting may be adjourned by a majority of directors present (Article V. Meetings of Directors, Section 5. Quorum)
Clarification that duly authorized Board committees may elect officers (Article VI. Officers, Section 2. Appointment and Term)
Clarification that officers may specify by electronic transmission the effective date of resignation and that duly authorized Board committees may remove officers. (Article VI. Officers, Section 4. Resignation and Removal of Officers)
The amendment also includes certain other technical and conforming revisions and clarifications. The foregoing summary is qualified in its entirety by reference to the Bylaws of Bank of America Corporation, as Amended and Restated by the Board of Directors on February 22, 2022, a copy of which (marked to show changes from the prior version) is attached hereto as Exhibit 3.2 and is incorporated in this Item 9B by reference.

171 Bank of America


Disclosure Pursuant to Section 13(r) of the Securities Exchange Act of 1934
Pursuant to Section 13(r) of the Securities Exchange Act of 1934, as amended (Exchange Act), an issuer is required to disclose in its annual or quarterly reports, as applicable, whether it or any of its affiliates knowingly engaged in certain activities, transactions or dealings relating to Iran or with individuals or entities designated pursuant to certain Executive Orders. Disclosure may be required even where the activities, transactions or dealings were conducted in compliance with applicable law. Except as set forth below, as of the date of this Annual Report on Form 10-K, the Corporation is not aware of any other activity, transaction or dealing by any of its affiliates during the quarter ended December 31, 2021 that requires disclosure under Section 13(r) of the Exchange Act.
Pursuant to a specific license from the U.S. Treasury Department’s Office of Foreign Assets Control issued on May 28, 2021, during the fourth quarter of 2021, Bank of America, National Association (BANA), a U.S. subsidiary of Bank of America Corporation, processed one authorized wire deposit totaling $327,257 on behalf of a U.S. client into its account at BANA. The wire deposit settled invoices owed to the U.S. client and consisted of unblocked funds belonging to Jammal Trust Bank, which at the time of the deposit was designated pursuant to Executive Order 13224. There was no measurable gross revenue or net profit to the Corporation relating to this transaction. The Corporation may in the future engage in similar transactions for its clients to the extent permitted by U.S. law.
Item 9C. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections
Not applicable.
Part III
Bank of America Corporation and Subsidiaries
Item 10. Directors, Executive Officers and Corporate Governance
Information about our Executive Officers
The name, age, position and office, and business experience during the last five years of our current executive officers are:
Dean C. Athanasia (53)(55) President, Regional Banking since October 2021; President, Retail and Preferred & Small Business Banking sincefrom January 2019 to October 2021; Co-Head -- Consumer Banking from September 2014 to January 2019; and
Preferred and Small Business Banking Executive from April 2011 to September 2014.
Catherine P. Bessant (59) Aditya Bhasin (48)Chief Operations and Technology & Information Officer since July 2015; GlobalOctober 2021; Chief Information Officer and Head of Technology for Consumer, Small Business, Wealth Management and Employee Technology from October 2017 to October 2021; CIO, Retail, Preferred & Wealth Management Technology, and Wealth Management Operations from June 2015 to October 2017.
Darrin Steve Boland (53) Chief Administrative Officersince October 2021; President, Retail from February 2020 to October 2021; Head of Consumer Lending from May 2017 to February 2020; Consumer Lending Executive from March 2010May 2015 to July 2015.May 2017.
Alastair M. Borthwick (53) Chief Financial Officersince November 2021; President of Global Commercial Banking from October 2012 to October 2021.
Sheri Bronstein (51)(53) 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.
James P. DeMare (52) President, Global Marketssince September 2020; Global Co-Head of FICC Trading and Commercial Real Estate Banking from February 2015 to September 2020.
Paul M. Donofrio (59)(61) Vice Chair since November 2021; Chief Financial Officer sincefrom August 2015;2015 to November 2021; Strategic Finance Executive from April 2015 to August 2015; and Head of Global Corporate Credit and Transaction Banking from January 2012 to April 2015.
Geoffrey S. Greener (55)(57) Chief Risk Officer since April 2014; Head of Enterprise Capital Management from April 2011 to April 2014.
Matthew M. Koder (50) President, Global Corporate & Investment Bankingsince December 2018; President of APAC from March 2012 to December 2018.
Kathleen A. Knox (56)(58) President, The Private Bank since November 2017; Head of Business Banking from October 2014 to November 2017; and Retail Banking & Distribution Executive from June 2011 to October 2014.
David G. LeitchBernard A. Mensah (53) President, International,CEO of Merrill Lynch International (MLI), BANA London Branch Head since August 2020. President of UK and Central and Eastern Europe, the Middle East, Africa, CEO of MLI, BANA London Branch and Co-Head of Global Fixed Income Currency and Commodities (FICC) Trading from September 2019 to August 2020; Co-Head of Global FICC Trading from March 2015 to September 2019.
Lauren A. Mogensen (59) Global General Counselsince January 2016; General Counsel of Ford Motor Company from April 2005 to December 2015.
Thomas K. Montag (63) Chief Operating Officer since September 2014; Co-Chief Operating OfficerNovember 2021; Head of Global Compliance & Operational Risk, and Reputational Risk fromSeptember2011 December 2013 to September 2014.October 2021.
Brian T. Moynihan (60) Chairman(62) Chair of the Board since October 2014, and President, and Chief Executive Officer, and member of the Board of Directors since January 2010.
Thong M. Nguyen (61)(63)Vice Chair, Head of Global Strategy & Enterprise Platforms since October 2021; Vice Chairman Bank of America Corporation sincefrom January 2019;2019 to October 2021; Co-Head -- Consumer Banking from September 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.
Thomas M. Scrivener (50)Chief Operations Executive since October 2021; Head of Consumer, Small Business & Wealth Management Operations from October 2019 to October 2021; Global Real Estate and Enterprise Initiatives Executive from September 2018 to October 2019; Enterprise Scenario Planning and Execution Executive from May 2016 to September 2018; Enterprise Stress Testing, Recovery & Resolution Planning Executive from June 2014 to March 2016.
Andrew M. Sieg (52)(54) 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 (52) Chief Administrative OfficerBruce R. Thompson (57) Vice Chair, Head of Enterprise Credit since August 2015; GlobalOctober 2021; Vice Chairman, Head of Human ResourcesInstitutional Credit Exposure Management (from December 2020) and Wholesale Credit Underwriting and Monitoring (from May 2021) to October 2021; Vice Chairman, President of the EU & Switzerland and CEO of Bank of America Europe DAC from January 2010May 2018 to August
Bank of America 172


December 2020; Vice Chairman of Bank of America Corporation from March 2016 to May 2018; Managing Director from July 2015 to March 2016; Chief Financial Officer from July 2011 to July 2015.
Information included under the following captions in the Corporation’s proxy statement relating to its 20202022 annual meeting of stockholdersshareholders (the 20202022 Proxy Statement) is incorporated herein by reference:
“Proposal 1: Electing Directors – Our Director Nominees;”
“Corporate Governance – Additional Corporate Governance Information;” and
“Corporate Governance – Board Meetings, Committee Membership, and Attendance.”
“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 20202022 Proxy Statement is incorporated herein by reference:
“Compensation Discussion and Analysis;”
“Compensation and Human Capital 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.”

Bank of America 164


Item 12. Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters
Information included under the following caption in the 20202022 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, 2019:2021:
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 shareholders188,687,164 — 254,845,261 
Plans not approved by shareholders— — — 
Total188,687,164 — 254,845,261 
(1)This table does not include 593,890 vested restricted stock units and stock option gain deferrals at December 31, 2021 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 3,671,576 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 Equity Plan.
      
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 shareholders158,954,915
 
 304,904,984
Plans not approved by shareholders
 
 
Total158,954,915
 
 304,904,984
(1)
This table does not include 783,282 vested restricted stock units and stock option gain deferrals at December 31, 2019 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 1,115,166 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.
Item 13. Certain Relationships and Related Transactions, and Director Independence
Information included under the following captions in the 20202022 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 20202022 Proxy Statement is incorporated herein by reference:
    “Proposal 3: Ratifying the appointment of our independent registered public accounting firm for 2022.”

“Proposal 3: Ratifying the Appointment of our Independent Registered Public Accounting Firm for 2020.”


165173 Bank of America







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 (PCAOB ID 238)
Consolidated Statement of Income for the years ended December 31, 2019, 20182021, 2020 and 20172019
Consolidated Statement of Comprehensive Income for the years ended December 31, 2019, 20182021, 2020 and 20172019
Consolidated Balance Sheet at December 31, 20192021 and 20182020
Consolidated Statement of Changes in Shareholders’ Equity for the years ended December 31, 2019, 20182021, 2020 and 20172019
Consolidated Statement of Cash Flows for the years ended December 31, 2019, 20182021, 2020 and 20172019
Notes to Consolidated Financial Statements
(2) Schedules:
None
(3) Index to Exhibits
With the exception of the information expressly incorporated herein by reference, the 20202022 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    
3.2 10-Q3(b)10/28/191-6523
4.1 S-34.12/1/9533-57533
4.2 8-K4.311/18/981-6523
4.3 8-K4.46/14/011-6523
4.4 8-K4.28/27/041-6523
4.5 S-34.65/5/06333-133852
4.6 8-K4.112/5/081-6523
4.7 10-K4(ee)2/25/111-6523
4.8 8-K4.11/13/171-6523
4.9 10-K4(a)2/23/171-6523
4.10 S-34.26/28/96333-07229
4.11 10-K4(aaa)2/28/071-6523
4.12 S-34.125/1/15333-202354
4.13 S-34.135/1/15333-202354
4.14 S-34.145/1/15333-202354
4.15 8-K4.21/13/171-6523
4.16 8-K4.31/13/171-6523
4.17 S-34.52/1/9533-57533
4.18 8-K4.811/18/981-6523

Incorporated by Reference
Exhibit No.DescriptionNotesFormExhibitFiling DateFile No.
3.11
3.21
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
Bank of America 166174


   Incorporated by Reference
Exhibit No.DescriptionNotesFormExhibitFiling DateFile No.
4.19 S-44.33/16/07333-141361
4.20 10-K4(ff)2/25/111-6523
4.21 10-K4(i)2/23/171-6523
4.22

 S-34.36/27/18333-224523
4.23 S-34.46/27/18333-224523
4.24 S-34.56/27/18333-224523
4.25 S-34.66/27/18333-224523
4.26 S-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
10.41,2    
10.51,2    
10.6

1,2    
10.7

1,2    
10.8NationsBank Corporation Benefit Security Trust dated as of June 27, 1990210-K10(t)3/27/911-6523
10.9
First 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
10.141,2    
10.15210-K10(g)3/3/031-6523
10.16210-K10(d)2/28/131-6523
10.17210-K10(g)2/28/071-6523
10.18210-K10(f)2/26/191-6523
10.1928-K10.212/14/051-6523
10.20210-K10(h)3/1/051-6523
10.21210-Q10(a)8/4/111-6523
10.2228-K10.25/3/101-6523
10.23210-Q10(a)5/1/141-6523
10.2428-K10.25/7/151-6523

167Bank of America






   Incorporated by Reference
Exhibit No.DescriptionNotesFormExhibitFiling DateFile No.
10.25210-Q10(a)5/2/161-6523
10.26210-Q10(c)5/2/161-6523
10.27

210-Q10(a)5/2/171-6523
10.28

210-Q10(b)5/2/171-6523
10.29210-Q104/30/181-6523
10.30210-K10(h)2/26/191-6523
10.31

210-Q10(a)4/26/191-6523
10.32210-Q10(b)4/26/191-6523
10.33210-Q10(c)4/26/191-6523
10.34210-K10(v)3/1/041-6523
10.35210-K10(r)3/1/051-6523
10.36210-K10(u)3/1/051-6523
10.37210-K10(v)3/1/051-6523
10.38210-K10(p)2/26/101-6523
10.39210-K10(c)2/25/111-6523
10.40210-K10(l)2/28/131-6523
10.41210-K10(x)3/1/051-6523
10.42210-K10(y)3/1/051-6523
10.43210-K10(z)3/1/051-6523
10.44210-K10(aa)3/1/051-6523
10.45210-K10(cc)3/1/051-6523
10.46210-K10(hh)3/1/051-6523
10.47210-K10(ii)3/1/051-6523
10.48210-K10(jj)3/1/051-6523
10.49210-K10(ll)3/1/051-6523
10.50210-K10(oo)3/1/051-6523
10.512S-410(d)12/4/03333-110924
10.5228-K10.110/26/051-6523
10.5328-K10.210/26/051-6523
10.54210-K10(zz)2/26/101-6523
10.55210-K10(aaa)2/26/101-6523
10.56210-K10(bbb)2/26/101-6523
10.57 8-K1.18/25/111-6523
10.58 10-K10(rr)2/23/171-6523
10.59210-Q107/30/181-6523
10.60210-Q10(b)6/30/191-6523

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-34.48/2/21333-257399
4.26S-34.58/2/21333-257399
4.27S-34.66/27/18333-224523
4.28S-34.76/27/18333-224523
4.29S-34.78/2/21333-257399
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
4.301
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
10.15210-K10.152/24/211-6523
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
175 Bank of America


Incorporated by Reference
Exhibit No.DescriptionNotesFormExhibitFiling DateFile No.
10.2328-K10.14/22/211-6523
10.24210-Q10(a)5/2/161-6523
10.25210-K10(h)2/26/191-6523
10.26

210-Q10(a)4/26/191-6523
10.27210-Q10(b)4/26/191-6523
10.28210-Q10.15/1/201-6523
10.29210-Q10.25/1/201-6523
10.30210-Q10.14/29/211-6523
10.31210-Q10.24/29/211-6523
10.321, 2
10.331, 2
10.341, 2
10.351, 2
10.36210-Q10(c)4/26/191-6523
10.37210-K10(v)3/1/041-6523
10.38210-K10(r)3/1/051-6523
10.39210-K10(u)3/1/051-6523
10.40210-K10(v)3/1/051-6523
10.41210-K10(p)2/26/101-6523
10.42210-K10(I)2/28/131-6523
10.43210-K10(c)2/25/111-6523
10.44210-K10(x)3/1/051-6523
10.45210-K10(y)3/1/051-6523
10.46210-K10(z)3/1/051-6523
10.47210-K10(aa)3/1/051-6523
10.48210-K10(cc)3/1/051-6523
10.49210-K10(hh)3/1/051-6523
10.50210-K10(ii)3/1/051-6523
10.51210-K10(jj)3/1/051-6523
10.52210-K10(ll)3/1/051-6523
10.53210-K10(oo)3/1/051-6523
10.542S-410(d)12/4/03333-110924
10.5528-K10.110/26/051-6523
10.5628-K10.210/26/051-6523
10.57210-K10(bbb)2/26/101-6523
Bank of America 168176


 Incorporated by ReferenceIncorporated by Reference
Exhibit No.DescriptionNotesFormExhibitFiling DateFile No.Exhibit No.DescriptionNotesFormExhibitFiling DateFile No.
10.61210-K10(mm)2/26/191-6523
10.6228-K10.14/24/191-6523
10.5810.588-K1.18/25/111-6523
10.5910.59210-Q107/30/181-6523
10.6010.60210-Q10(b)6/30/191-6523
21

1 21

1
222210-Q2210/29/211-6523
231 231
241 241
31.11 31.11
31.21 31.21
32.11 32.11
32.21 32.21
101.INSInline XBRL Instance Document3 101.INSInline XBRL Instance Document3
101.SCHInline XBRL Taxonomy Extension Schema Document1 101.SCHInline XBRL Taxonomy Extension Schema Document1
101.CALInline XBRL Taxonomy Extension Calculation Linkbase Document1 101.CALInline XBRL Taxonomy Extension Calculation Linkbase Document1
101.LABInline XBRL Taxonomy Extension Label Linkbase Document1 101.LABInline XBRL Taxonomy Extension Label Linkbase Document1
101.PREInline XBRL Taxonomy Extension Presentation Linkbase Document1 101.PREInline XBRL Taxonomy Extension Presentation Linkbase Document1
101.DEFInline XBRL Taxonomy Extension Definitions Linkbase Document1 101.DEFInline XBRL Taxonomy Extension Definitions Linkbase Document1
104Cover Page Interactive Data File (formatted as Inline XBRL and contained in Exhibit 101) 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.
(3) The instance document does not appear in the interactive data file because its XBRL tags are embedded within the inline XBRL document.



169Bank of America







Item 16. Form 10-K Summary
Not applicable.
177 Bank of America


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 19, 2020
22, 2022
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
SignatureTitleDate
/s/ Brian T. Moynihan
Chief Executive Officer, ChairmanPresident, Chair and Director

(Principal Executive Officer)
February 19, 202022, 2022
Brian T. Moynihan
*/s/ PaulAlastair M. DonofrioBorthwick
Chief Financial Officer

(Principal Financial Officer)
February 19, 202022, 2022
PaulAlastair M. DonofrioBorthwick
*/s/ Rudolf A. Bless
Chief Accounting Officer

(Principal Accounting Officer)
February 19, 202022, 2022
Rudolf A. Bless
*/s/ Sharon L. AllenDirectorFebruary 19, 202022, 2022
Sharon L. Allen
*/s/ Susan S. BiesDirectorFebruary 19, 202022, 2022
Susan S. Bies
*/s/ Jack O. Bovender, Jr.DirectorFebruary 19, 2020
Jack O. Bovender, Jr.
*/s/ Frank P. Bramble, Sr.
DirectorFebruary 19, 202022, 2022
Frank P. Bramble, Sr.
*/s/ Pierre J. P. de WeckDirectorFebruary 19, 202022, 2022
Pierre J. P. de Weck
*/s/ Arnold W. DonaldDirectorFebruary 19, 202022, 2022
Arnold W. Donald
*/s/ Linda P. Hudson
DirectorFebruary 19, 202022, 2022
Linda P. Hudson
*/s/ Monica C. LozanoDirectorFebruary 19, 2020
Monica C. Lozano

Bank of America 170


Signature*/s/ Monica C. LozanoTitleDirectorDateFebruary 22, 2022
Monica C. Lozano
*/s/ Thomas J. MayDirectorFebruary 19, 202022, 2022
Thomas J. May
*/s/ Lionel L. Nowell, IIIDirectorFebruary 19, 202022, 2022
Lionel L. Nowell, III
Bank of America 178


SignatureTitleDate
*/s/ Denise L. RamosDirectorFebruary 19, 202022, 2022
Denise L. Ramos
*/s/ Clayton S. RoseDirectorFebruary 19, 202022, 2022
Clayton S. Rose
*/s/ Michael D. WhiteDirectorFebruary 19, 202022, 2022
Michael D. White
*/s/ Thomas D. WoodsDirectorFebruary 19, 202022, 2022
Thomas D. Woods
*/s/ R. David YostDirectorFebruary 19, 202022, 2022
R. David Yost
*/s/ Maria T. Zuber
DirectorFebruary 19, 202022, 2022
Maria T. Zuber
*By/s/ Ross E. Jeffries, Jr.
Ross E. Jeffries, Jr.

Attorney-in-Fact



171179 Bank of America