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- 10-K Annual report
- 3 Amended and Restated Certificate of Incorporation
- 4 Amended and Restated Agency Agreement Dated August 21, 2006
- 4 Issuing and Paying Agreement Dated May 23, 2006
- 4 Tenth Supplemental Indenture Dated March 28, 2006
- 4 Eleventh Supplemental Indenture Dated May 23, 2006
- 4 Twelth Supplemental Indenture Dated August 2, 2006
- 4 Third Supplemental Indenture Dated As of December 21, 2005
- 4 Agency Agreement Dated August 27, 2003
- 4 Agency Agreement Dated September 15, 2004
- 4 Australian MTN Deed Poll
- 4 Agreement and Appointment of Acceptance Dated As of December 29, 2006
- 10 Bank of America Director Deferral Plan
- 12 Ratio of Earnings to Fixed Charges
- 21 List of Subsidiaries
- 23 Consent of Pricewaterhousecoopers LLP
- 24 Power of Attorney
- 24 Corporate Resolution
- 31 Certification of CEO Pursuant to Section 302
- 31 Certification of CFO Pursuant to Section 302
- 32 Certification of CEO Pursuant to 18 U.s.c Section 1350
- 32 Certification of CFO Pursuant to 18 U.s.c Section 1350
- CORRESP Corresp
February 28, 2007
VIA EDGAR
Securities and Exchange Commission
Washington, D.C. 20549
Re: | Bank of America Corporation: Annual Report on Form 10-K for the Fiscal Year Ended December 31, 2006 (Commission File Number 1-6523) |
Ladies and Gentlemen:
On behalf of Bank of America Corporation, I am transmitting via EDGAR the Corporation’s Annual Report on Form 10-K for the fiscal year ended December 31, 2006 (the “Form 10-K”). The financial statements incorporated in the Form 10-K reflect the impact of the adoption of Statement of Financial Accounting Standards (SFAS) No.123 (revised 2004), “Share-based Payment” on January 1, 2006; the election to early adopt SFAS No. 156, “Accounting for Servicing of Financial Assets, an amendment of FASB Statement No.140” for consumer-related mortgage services rights on January 1, 2006; and the adoption of SFAS No.158, “Employers’ Accounting for Defined Benefit Pension and Other Postretirement Plans, an amendment of FASB statements No. 87, 88, 106, and 123(R)” on December 31, 2006. The financial statements do not reflect a change from the preceding year in any other accounting principles or practices, or in the method of applying any such principles or practices.
Should you have any questions on this filing, please do not hesitate to call the undersigned at 704.386.1624.
Very truly yours,
/s/ Ellen A. Perrin
Ellen A. Perrin
Assistant General Counsel