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  Title	BANK OF AMERICA CORPORATION Bank of America : Pillar 3 Regulatory Capital Disclosures (December 31, 2024)
  ID	7329015
  External ID	7587026102
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  Published Date	Feb. 27, 2025, 4:21 p.m.
  Summary	February 27, 2025 at 05:15 pm EST Pillar 3 Regulatory Capital Disclosure Advanced Approaches For the quarter ended December 31, 2024 DISCLOSURE MAP SCOPE OF APPLICATION Corporate Overview
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  Content	February 27, 2025 at 05:15 pm EST Pillar 3 Regulatory Capital Disclosure Advanced Approaches For the quarter ended December 31, 2024 DISCLOSURE MAP SCOPE OF APPLICATION Corporate Overview Bank of America Corporation is a Delaware corporation, a bank holding company (BHC) and a financial holding company. When used in this report, "Bank of America", "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. 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. 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 (GAAP) requires management to make estimates and assumptions that affect reported amounts and disclosures. Actual results could materially differ from those estimates and assumptions. For additional information, refer to Note 1 - Summary of Significant Accounting Principles in the December 31, 2024 Form 10-K. These disclosures are required by regulatory capital rules set out by the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (Federal Reserve) and the Federal Deposit Insurance Corporation (FDIC) (collectively, U.S. banking regulators) in alignment with the Basel 3 regulatory capital framework. These disclosures provide qualitative and quantitative information about regulatory capital and risk-weighted assets (RWA) for the Advanced approaches, and should be read in conjunction with our Form 10-K for the year ended December 31, 2024, and the Consolidated Financial Statements for Bank Holding Companies - FR Y-9C, the Market Risk Regulatory Report for Institutions Subject to the Market Risk Capital Rule - FFIEC 102 and the Regulatory Capital Reporting for Institutions Subject to the Advanced Capital Adequacy Framework FFIEC 101 for the period ended December 31, 2024. The Corporation's Pillar 3 disclosures may include some financial information that has not been prepared under GAAP. Certain information contained in the Pillar 3 disclosures is prepared pursuant to instructions in the U.S. Basel 3 Final Rule (Basel 3). U.S. banking regulators permit certain Pillar 3 disclosure requirements to be addressed by their inclusion in the Consolidated Financial Statements of the Corporation. In such instances, incorporation into this report is made by reference to the relevant section(s) of the most recent Form 10-K filed with the United States Securities and Exchange Commission (SEC). This Pillar 3 report should be read in conjunction with the aforementioned reports as information regarding regulatory capital and risk management is largely contained in those filings. The table on the previous page indicates the location of such disclosures. Basel 3 Regulatory Capital Standards and Disclosures As a BHC, the Corporation is subject to regulatory capital rules, including Basel 3, issued by U.S. banking regulators. Basel 3 is a regulatory capital framework composed of three parts, or pillars. Pillar 1 addresses capital adequacy and provides minimum capital requirements. Pillar 2 requires supervisory review of capital adequacy assessments and strategies. Pillar 3 promotes market discipline through prescribed regulatory public disclosures on capital structure, capital adequacy and RWA. The Corporation's depository institution subsidiaries are also subject to the Prompt Corrective Action (PCA) framework. The PCA framework establishes categories of capitalization including well capitalized, based on the Basel 3 regulatory capital 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. The Corporation and its primary banking subsidiaries, Bank of America, National Association (BANA) and Bank of America California, National Association (BACANA), are Advanced approaches institutions under Basel 3 and are required to report regulatory risk-based capital ratios and risk-weighted assets (RWA) under both the Standardized and Advanced approaches. The lower of the capital ratios under the Standardized or Advanced approaches compared to their respective regulatory capital ratio requirements is used to assess capital adequacy, including under the PCA framework. As of December 31, 2024, the common equity tier 1 (CET1) capital, Tier 1 capital and Total capital ratios under the Standardized approach were the binding ratios. In order to avoid restrictions on capital distributions and discretionary bonus payments to executive officers, the Corporation must meet risk-based capital ratio requirements that include a capital conservation buffer (under the Advanced approaches only), a stress capital buffer (SCB) (under the Standardized approach only), plus any applicable countercyclical capital buffer and a global systemically important bank (G-SIB) surcharge. The buffers and surcharge must be comprised solely of CET1 capital. For the period from January 1, 2024 through September 30, 2024, the Corporation's minimum CET1 capital ratio requirements were 10.0 percent under both the Standardized approach and the Advanced approaches. Effective October 1, 2024, the Corporation's minimum CET1 requirements were 10.7 percent under the Standardized approach and 10.0 percent under the 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 3.5 percent from 3.0 percent on January 1, 2027, unless the surcharge calculated as of December 31, 2025 is lower than 3.5 percent. At December 31, 2024, the Corporation's CET1 capital ratio of 11.9 percent under the Standardized approach exceeded its CET1 capital ratio requirement. 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 to executive officers. At December 31, 2024, our insured depository institution subsidiaries exceeded their requirement 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 the simple average of certain off- balance sheet exposures, as of the end of each month in a quarter. The Corporation is subject to the Federal Reserve's final rule requiring G-SIBs to maintain minimum levels of total loss- absorbing capacity (TLAC) and long-term debt. TLAC consists of the Corporation's Tier 1 capital and eligible long-term debt issued directly by the Corporation. Eligible long-term debt for TLAC ratios is comprised of unsecured debt that has a remaining maturity of at least one year and satisfies additional requirements as prescribed in the TLAC final rule. As with the risk-based capital ratios and SLR, the Corporation is required to maintain TLAC ratios in excess of minimum requirements plus applicable buffers to avoid restrictions on capital distributions and discretionary bonus payments to executive officers. For additional information on Basel 3 and management of the Corporation's regulatory capital and pending or proposed capital changes, refer to the Capital Management section within the Management's Discussion and Analysis of Financial Condition and Results of Operations (MD&A) and Note 16 - Regulatory Requirements and Restrictions in the December 31, 2024 Form 10-K. Information contained in this report is presented in accordance with the Basel 3 rules for RWA and capital measurement under the Advanced approaches, and follows the Pillar 3 disclosure requirements for the quantitative and qualitative presentation of data. Information presented herein may differ from similar information presented in the Consolidated Financial Statements and other publicly available disclosures. Unless specified otherwise, all amounts and information are presented in conformity with the definitions, rules and requirements of Basel 3. CAPITAL STRUCTURE Under Basel 3, Total capital consists of two tiers of capital, Tier 1 and Tier 2. Tier 1 capital is further composed of CET1 capital and additional Tier 1 capital. CET1 capital primarily includes common stock, retained earnings and Accumulated Other Comprehensive Income (AOCI). Goodwill, disallowed intangible assets and certain deferred tax assets are excluded from CET1 capital. Additional Tier 1 capital primarily includes qualifying non-cumulative preferred stock. Tier 2 capital primarily consists of qualifying subordinated debt and a limited portion of eligible credit reserves. The Corporation's Total capital is the sum of Tier 1 capital and Tier 2 capital. The following table presents the capital composition as of December 31, 2024. Results below reflect the impact of transition provisions related to the Corporation's adoption of the current expected credit losses (CECL) accounting standard, as well as information reflecting the full impact of CECL adoption. December 31, 2024 (Dollars in millions) and preferred stock, refer to Note 13 - Shareholders' Equity in the December 31, 2024 Form 10-K. For additional information on Tier 2 capital instruments, refer to Note 11 - Long-term Debt in the December 31, 2024 Form 10-K. Total common shareholders' equity CECL transitional amount Goodwill, net of related deferred tax liabilities Deferred tax assets arising from net operating loss and tax credit carryforwards Intangibles, other than mortgage servicing rights and goodwill, net of related deferred tax liabilities Defined benefit pension plan net assets Cumulative unrealized net (gain) loss related to changes in fair value of financial liabilities attributable to own creditworthiness, net-of-tax 1 December 31, 2024 includes 25 percent of the CECL transition provision's impact as of December 31, 2021. 2 Includes amounts in AOCI related to the hedging of items that are not recognized at fair value on the Consolidated Balance Sheet. 3 Basel 3 CECL Transitional includes the impact of transition provisions related to the CECL accounting standard. For additional information on the components of common shareholders' equity, refer to Schedule A " Advanced Approaches Regulatory Capital " in Bank of America's December 31, 2024 Regulatory Capital Reporting for Institutions Subject to the Advanced Capital Adequacy Framework ― FFIEC 101 Report. For the related breakdown of AOCI, refer to Note 14 - Accumulated Other Comprehensive Income (Loss) in the December 31, 2024 Form 10-K. For additional information on goodwill and intangibles, refer to Note 7 - Goodwill and Intangible Assets in the December 31, 2024 Form 10-K. For terms and conditions of common stock CAPITAL ADEQUACY 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. For more information, see Capital Management in the MD&A of the Corporation's 2024 Annual Report on Form 10-K. 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 of Directors (the Board) or its committees. The Federal Reserve requires BHCs to submit a capital plan and planned capital actions on an annual basis, consistent with the rules governing capital planning and the SCB requirement, which include supervisory stress testing by the Federal Reserve. Based on 2024 Comprehensive Capital Analysis and Review (CCAR) stress test results, our SCB is 3.2 percent effective from October 1, 2024 through September 30, 2025. On July 24, 2024, the Board authorized a $25 billion common stock repurchase program, effective August 1, 2024, which replaced the Corporation's previous program that was initially authorized by the Board in 2021, modified in 2023 and expired on August 1, 2024. Pursuant to Board authorizations, during 2024, we repurchased $13.1 billion of common stock. For more information, see Part II. Item 5. Market for Registrant's Common Equity, Related Stockholder Matters and Issuer Purchases of Equity Securities in the Corporation's 2024 Annual Report on Form 10-K. The timing and amount of common stock repurchases 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. Regulatory Capital Ratios December 31, 2024 Key Capital Metrics - Bank of America Corporation 1 As of December 31, 2024, the CET1 capital ratio for the Corporation was lower under the Standardized approach. The following tables present capital ratios and related information as well as the regulatory minimum and well capitalized ratio requirements under Basel 3 Advanced and Basel 3 Standardized for the Corporation and its major national bank subsidiaries: BANA and BACANA as of December 31, 2024. For the Corporation and BANA, the results below include information that reflects the impact of transition provisions related to the adoption of the CECL accounting standard, as well as information reflecting the full impact of CECL adoption. BACANA did not elect to apply the transition provisions. Capital Ratios Common equity tier 1 capital Tier 1 capital Total capital Tier 1 leverage Supplementary leverage ratio 1 As of December 31, 2024, 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 on January 1, 2020. 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. 4 The CET1 capital regulatory minimum is the sum of the CET1 capital ratio minimum of 4.5 percent, our G-SIB surcharge of 3.0 percent and our capital conservation buffer of 2.5 percent (under the Advanced approaches) or the SCB (under the Standardized approach) of 3.2 percent at December 31, 2024. The countercyclical capital buffer was zero. The SLR regulatory minimum includes a leverage buffer of 2.0 percent. 5 Risk-based capital regulatory minimums at December 31, 2024 are the minimum ratios under Basel 3 including a capital conservation buffer of 2.5 percent. The regulatory minimums for leverage ratios as of December 31, 2024 are the percent required to be considered well capitalized under the PCA framework. As of December 31, 2024 Bank of America Corporation and its regulated banking subsidiaries were in excess of their respective minimum Total capital requirements and our regulated principal broker-dealer subsidiaries were in compliance with their net capital requirements. The Corporation's capital conservation buffer of 7.06 percent under the Standardized Approach, 8.43 percent under the Advanced Approaches and leverage buffer of 2.84 percent are above the capital conservation buffer (including the G-SIB surcharge) requirement of 6.2 percent (Standardized), 5.5 percent (Advanced) and the leverage buffer requirement of 2.0 percent, respectively. Total Loss-Absorbing Capacity The following table presents the Corporation's TLAC and long-term debt ratios and related information as of December 31, 2024. Results below reflect the election of CECL transition. 1 As of December 31, 2024, TLAC ratios are calculated using the regulatory capital rule that allows a five-year transition period related to the adoption of CECL accounting standard on January 1, 2020. 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 this period. 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 3.0 percent requirement based on the Corporation's Method 2 G-SIB surcharge. The long-term debt leverage exposure regulatory minimum is 4.5 percent. Effective January 1, 2024, the Corporation's G-SIB surcharge, which is higher under Method 2, increased 50 bps, resulting in an increase in our long-term debt RWA regulatory minimum requirement to 9.0 percent from 8.5 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, 2024. Bank of America is not subject to payout ratio limitations, including limitations on capital distributions and discretionary bonus payments to executive officers, under Basel 3 requirements. For additional information on regulatory capital, capital ratios, capital conservation, stress capital and countercyclical capital buffers for the Corporation, refer to Part I. Item 1A. Risk Factors - Regulatory, Compliance and Legal and Capital Management within the MD&A section in the December 31, 2024 Form 10-K, Schedule A "Advanced Approaches Regulatory Capital" in Bank of America's December 31, 2024 Regulatory Capital Reporting for Institutions Subject to the Advanced Capital Adequacy Framework ― FFIEC 101 and Schedule HC-R "Regulatory Capital" in Bank of America's December 31, 2024 Consolidated Financial Statements for Bank Holding Companies - FR Y-9C. For information on eligible retained income, refer to Schedule HC-R "Regulatory Capital" in Bank of America's December 31, 2024 Consolidated Financial Statements for Bank Holding Companies - FR Y-9C. Bank Subsidiary Distributions 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. For additional information, refer to Note 16 - Regulatory Requirements and Restrictions in the December 31, 2024 Form 10-K. Risk-Weighted Assets Basel 3 Advanced approaches include measures of credit risk, market risk, operational risk and risks related to the credit valuation adjustment (CVA) for over-the-counter (OTC) derivative exposures. The Advanced approaches rely on internal analytical models to measure risk weights for credit risk exposures and allow the use of models to estimate the exposure at default (EAD) for certain exposure types. Market risk applies to covered positions which include trading assets and liabilities, foreign exchange exposures and commodity exposures. Market risk capital is modeled for general market risk as well as specific risk for products where specific risk regulatory approval has been granted; in the absence of specific risk model approval, standard specific risk charges apply. For securitization exposures, institutions are permitted to use the Supervisory Formula Approach (SFA) and would use the Simplified Supervisory Formula Approach (SSFA) if the SFA is unavailable for a particular exposure. Credit risk exposures are measured using internal ratings- based models to determine the applicable risk weight by estimating the probability of default (PD), loss-given default (LGD) and, in certain instances, EAD. The internal analytical models primarily rely on internal historical default and loss experience. Operational risk is measured using internal analytical models which rely on both internal and external operational loss experience and data. The calculations require management to make estimates, assumptions and interpretations, including with respect to the probability of future events based on historical experience. Actual results could differ from those estimates and assumptions. Under the Federal Reserve's reservation of authority, they may require us to hold an amount of capital greater than otherwise required under the capital rules if they determine that our risk-based capital requirement using our internal analytical models is not commensurate with our credit, market, operational or other risks. Attachments Original document Permalink Disclaimer Bank of America Corporation published this content on February 27, 2025 , and is solely responsible for the information contained therein. Distributed by Public, unedited and unaltered, on February 27, 2025 at
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