Bank of America Goldman Sachs U.S. Financial Services Conference Brian Moynihan, Chairman and CEO December 06, 2016 At Bank of America, we live our values, deliver our purpose and drive responsible growth through our eight lines of business Our values Our purpose Responsible growth Eight lines of business • Deliver together To help make financial lives • We must grow and win in the Serving the core financial needs of • Act responsibly better, through the power of • Realize the power of our people • Trust the team every connection market – no excuses people, companies and • We must grow with our customer-focused strategy institutional investors through eight lines of business • We must grow within our risk framework • We must grow in a sustainable manner We’re better when we’re connected® 2 We must grow and win in the market – no excuses 3 Transformed and Simplified the Company Reorganized to Focus on Customers’ Core Needs $74B Fees • Sold/divested $74B in non-core assets 1 including: – Equity interests in other financial institutions – Non-core credit card portfolios – Ancillary mortgage businesses – International wealth management – Correspondent / wholesale lending – Proprietary trading • Eliminated add-on products and reduced punitive fees • Prioritized resources within Global Banking and Global Markets towards developing long-term relationships with our key clients Simplified Consumer Product Set Checking Credit Card Home Loans Business Loans Auto Loans 22 products 18 products 44 products 136 products 9 products 10 products 3 6 11 39 5 3 Significantly Improved Cost Structure ($B) 2 Less Complex Number of legal entities $77.1 5.6 71.5 2011 Savings 3Q16 2011 $72.1 4.2 $69.2 6.1 $75.7 16.4 $57.7 $55.8 1.2 1.3 67.9 63.1 59.3 56.5 54.5 2012 2013 2014 2015 LTM 3 Noninterest expense excluding litigation Litigation expense ____________________ 1 Since 2010. 2 Noninterest expense excludes goodwill impairment of $3.2B in 2011, which represents a non-GAAP financial measure. Reported noninterest expense in 2011 was $80.3B. 3 LTM defined as last twelve months as of September 30, 2016. 4 Strengthened Balance Sheet Strengthened Capital Built Strong Liquidity Enhanced Funding Structure TCE Ratio and Tangible Book Value per Share 1, 2 GLS ($B) 3 and TTF (months) Deposits and Long-term Debt ($B) 1 9% 8.2% $20 $17.14 $15 $600 $522 $500 6% 5.0% $10 $11.31 $5 0% $0 4Q09 38 $214 $200 3% 3Q16 Tangible common equity (TCE) ratio Tangible book value per share Improved Portfolio Mix Loans and Leases ($B) 1 $100 $1,233 $992 40 $400 $300 50 30 $523 $225 20 25 $0 10 4Q09 3Q16 4Q09 Global Liquidity Sources (GLS) Time to Required Funding (TTF) Reduced Illiquid Assets Level 3 Assets ($B) Deposits $905 $104 33% Long-term debt Lowered Average Trading-related Assets ($B) and Average VaR ($MM) 4 $600 $1,003 3Q16 $400 $300 $494 $256 $415 $200 50% $200 67% $100 $16 50% $40 $0 4Q09 Consumer 3Q16 Commercial 4Q09 3Q16 4Q09 $0 3Q16 Avg. trading-related assets Avg. VaR ____________________ 1 4Q09 reflects 12/31/09 information adjusted to include the 1/1/10 adoption of FAS 166/167 as reported in the company’s SEC filings, which represents a non-GAAP financial measure. 2 Represents a non-GAAP financial measure. Common equity ratio was 8.7% and 11.2% at 4Q09 and 3Q16. Book value per share was $21.48 and $24.19 at 4Q09 and 3Q16. 3 Prior to the third quarter of 2016, GLS were referred to as “Global Excess Liquidity Sources.” 4 VaR model uses historical simulation approach based on three years of historical data and an expected shortfall methodology equivalent to a 99% confidence level. 5 Growing Loans as Legacy Run-off Reduced Average Total Loans & Leases ($B) $914 $907 $894 $880 1Q14 2Q14 3Q14 4Q14 $867 1Q15 $876 $877 2Q15 3Q15 $886 $893 $900 $901 4Q15 1Q16 2Q16 3Q16 $135 10 24 $126 10 22 $118 10 21 $112 10 20 $105 9 19 117 101 93 87 82 77 2Q15 3Q15 4Q15 1Q16 2Q16 3Q16 Average Loans & Leases in All Other ($B) $212 $205 12 31 12 30 163 1Q14 158 2Q14 $194 12 28 149 3Q14 Residential mortgage $179 11 27 137 4Q14 $165 10 26 127 1Q15 Home equity $153 10 25 Non-U.S. credit card Other ____________________ Note: Amounts may not total due to rounding. 6 We must grow with our customer-focused strategy 7 Integrated Business Model with Full Suite of Products and Services Consumer Banking Optimize Efficiency Retail Global Wealth & Investment Management Global Markets Global Banking Drive growth through additions of advisors and other client-facing professionals, growth in target clients, depth of relationships, and expanded market coverage Preferred & Small Business • 47MM Consumer and Small Business relationships • 31MM Retail customers – <$50K household income • 11MM Preferred customers – >$75K HHI / >$100K in assets • 3MM Small Business customers • 21.3MM mobile customers • 33.7MM active online users Merrill Lynch U.S. Trust • Nearly 1MM high net worth households – >$250K in assets (ML) – >$3MM in assets (UST) • Nearly $2.5T client assets – $145B loans and leases – $253B deposits • ~21K client-facing professionals, including 17K financial advisors 1 Business Banking Commercial Banking • ~39K clients • $5MM– $50MM in revenue • Primary focus on small and mid-sized U.S. domiciled clients • ~20K clients • $50MM–$2B in revenue • Primary focus on U.S. domiciled middle market clients and int’l subs. Global Corporate & Investment Banking • ~5K clients • >$2B in revenue • Largest global corporates, FI’s, gov’t. Capture Market Share Potential Global Markets • ~9K clients • 29 countries with sales & trading locations • Nearly 700 research analysts ____________________ 1 Includes Financial Advisors in the Consumer Banking segment of 2,179. 8 Industry-Leading Positions Across our Businesses People • No. 1 retail deposit share 1 Companies • Top 3 Global Investment Bank by Fees 6 • Best Bank for Cash Management (Global), Transaction Banking Awards (The Banker ‘16) • No. 1 home equity lender 2 • No. 3 U.S. credit card balances 3 • No.1 online banking functionality 4 • No. 1 mobile banking functionality 5 • • No. 1 wealth management position across assets, loans and deposits 3 Best Bank in North America for Small to Medium Sized Companies (Euromoney, ’16) • World’s Best Bank for Financing and Diversity (Euromoney ‘16) • No. 1 in Barron’s U.S. High net worth client assets (2016) • Relationships with 80% of the Global Fortune 500 and 96% of the U.S. Fortune 1,000 (2016) ____________________ 1 Source: June 2016 FDIC data, adjusted to remove commercial deposit balances. 2 Source: Inside Mortgage Finance 1H16. 3 Source: Competitor 3Q16 earnings releases and call reports. 4 Source: Keynote, 2Q16 Online Banker Scorecard. Institutions • Primary dealer in 19 countries with access to 100+ exchanges, trading more than 200 currency pairs • No. 1 Global Research firm – 5 straight years 7 • Nearly 700 analysts covering 3,100+ companies, 1,100+ corporate bond issuers across 56 economies and 28 industries • 2016 U.S. Fixed Income Quality Leader in Credit and Emerging Markets 8 • No. 1 U.S. Investors Equity Trading Share Leader 8 5 Source: Forrester, 2016 U.S. Mobile Banking Functionality Benchmark. Rankings per Dealogic as of November 30, 2016 YTD; excludes self-led deals. 7 Source: Institutional Investor (2011-2015). 8 Source: Greenwich Associates 2016. 6 9 Solid Growth in Business Segments Average Loans & Leases in Business Segments ($B) 1 Average Total Deposits ($B) YoY $742 66 $760 $775 69 69 319 309 137 134 329 139 $788 70 $795 69 +7% +4% $1,186 $1,198 $1,213 $1,227 +6% 63 63 63 61 -2% 308 297 299 306 296 251 260 255 254 +4% 244 556 564 578 596 606 +9% 3Q15 4Q15 1Q16 2Q16 3Q16 $1,159 63 334 141 334 143 233 235 238 243 249 3Q15 4Q15 1Q16 2Q16 3Q16 Consumer Banking Global Banking YoY GWIM Global Markets +8% +3% +7% +7% Consumer Banking Global Banking GWIM Other (GM and All Other) ____________________ Note: Amounts may not total due to rounding. 1 Includes loans and leases within Consumer Banking, Global Wealth & Investment Management, Global Banking and Global Markets. 10 Relationship Deepening – Consumer Example Average Consumer Banking Deposits ($B) $800 Preferred Rewards (Launched June 2014) 3% 2.61% $600 $421 $415 $447 $520 $489 $606 $553 1.59% 2% $400 1% $200 Preferred Rewards is a hassle-free program that offers real banking benefits and rewards clients actually use - and as their balances grow, so do their benefits Eligibility Requirements: • 3 months average balances (banking + investment) • Eligible personal checking account PLATINUM $20k - $50k $50k - $100k 25% 50% 75% 5% Interest rate booster 10% Interest rate booster 20% Interest rate booster No-fee transactions at non-BofA ATMs (U.S.) None Up to 12 per year One per statement cycle Unlimited Merrill Edge® online investing – $0 online equity and ETF trades None Up to 30 per month Up to 100 per month Mortgage purchase or refinance relationship credit $200 $400 $600 Home Equity Loan / Line of Credit interest rate discount 0.125% 0.250% 0.375% Auto Loan interest rate discount 0.25% 0.35% 0.50% Bank of America credit card rewards bonus $0 0% 2010 2011 2012 2013 2014 Average Deposits 2015 3Q16 Cost of Deposits `12 - `16 Change +9 +5 +1 76 75 74 Rewards Money Market Savings rate booster 1 1 Client Satisfaction at All-Time High (ASCI Satisfaction Index) 75 71 66 PLATINUM HONORS GOLD $100k+ Up to 4 checking and 4 savings accounts with no monthly fee BAC WFC 2012 JPM 2016 No fees on select banking services – Check orders, inbound wires, etc. Priority client service ____________________ 1 Cost of deposits calculated as annualized noninterest expense as a percentage of total average deposits within the Deposits subsegment. 11 We must grow within our risk framework 12 Risk Framework Overview Seven Key Risks Compliance Liquidity Operational Credit Strategic Market Reputational Risk culture of personal integrity and accountability where risks are promptly identified, escalated and debated 13 Asset Quality – Consumer Portfolio Consumer Net Charge-Offs ($B) U.S. Consumer Credit Card Net Charge-Offs ($B) $13.0 11.04% $29.4 $7.3 6.90% $4.6 $3.4 4.88% 3.74% 4.51% $18.5 2010 2011 2012 2013 Net charge-offs $13.6 $2.6 $2.3 $1.7 2.96% 2.62% 2.60% 2014 2015 2016 YTD 1 Net charge-off ratio 2.94% Average Booked FICO on New Originations 2.36% $7.2 1.34% 800 $4.1 $3.9 0.80% 0.84% 794 793 $2.5 0.76% 782 774 775 771 2010 2011 2012 2013 2014 2015 771 2016 YTD 1 766 761 Net charge-offs Net charge-off ratio 750 3Q15 4Q15 U.S. Consumer Credit Card Residential Mortgage 1Q16 2Q16 3Q16 Consumer Vehicle Lending Home Equity ____________________ 1 As of 9/30/16. 14 Asset Quality – Commercial Portfolio Commercial Net Charge-Offs ($B) Commercial Nonperforming Loans and Leases ($B) $9.8 $5.0 $6.3 Increase driven primarily by Energy and Metals and Mining $3.2 1.64% 2010 2011 2012 $1.3 $1.1 $1.2 2013 2014 2015 $2.0 3Q16 $2.3 Commercial Portfolio Mix (%) 2 0.77% $1.3 0.43% 100% $0.7 $0.3 0.18% 2010 2011 2012 2013 15% 24% 29% 85% 76% 71% JPM WFC 80% 0.08% 2014 $0.4 $0.4 60% 0.10% 0.12% 40% 2015 2016 YTD 1 20% 0% Net charge-offs Net charge-off ratio BAC C&I and other Real estate & construction ____________________ 1 As of 9/30/16. 2 Based on FRY-9C data. 15 Asset Quality – Reduced Risk Under Severely Adverse Conditions BAC Credit Losses Under FRB Stress Test ($B) 1 Stressed Portfolio Loss Rates BAC Worst 9-Qtr Losses Portfolio Total Consumer 2016 CCAR FRB Results 1 4Q08-4Q10 Actual Losses BAC 9-Qtr Losses Annualized Loss Rate 10.7% 6.8% 3.0% $104 150% Down $50B or 48% $54 Credit Card 23.4% 11.5% 5.1% Total Commercial 4.6% 4.5% 2.0% Total Loans and Leases 8.7% 5.6% 2.5% 33% SCAP 2009 Stress Credit Losses CCAR 2016 % of Tangible Common Equity 2 ____________________ 1 CCAR defined as Comprehensive Capital Analysis and Review. SCAP defined as Supervisory Capital Assessment Program. 2 Calculated as stressed credit losses as a percentage of tangible common equity as of 3/31/09 for SCAP 2009 and 12/31/15 for CCAR 2016. Tangible common equity was $69.6B and $162.1B as of 3/31/09 and 12/31/2015 and common equity was $166.3B and $233.9B as of 3/31/09 and 12/31/2015. 16 Market Risk Optimization 2016 YTD Sales & Trading Revenue per $ of Average VaR ($MM) 2 BAC Trading Portfolio VaR ($MM) 1 $350 $300 $500 Reduction of ~85% from historical peak to September 2016 2016 DFAST Trading and Counterparty Losses as a % of CET1 3 30% $460 26.2% 25% $400 23.4% $358 $250 18.8% 20% $200 $300 $244 $150 $200 15% 13.0% 11.4% $173 10% $100 $100 5% $50 $0 2011 2012 2013 2014 2015 2016 0% $0 BAC JPM MS GS GS MS JPM BAC C ____________________ 1 VaR model uses historical simulation approach based on three years of historical data and an expected shortfall methodology equivalent to a 99% confidence level. 2 Represents YTD reported sales and trading revenue as of 9/30/16 divided by average VaR of the trading portfolio using a 95% confidence level. C not shown as only discloses average VaR using a 99% confidence level. Using a 99% confidence level BAC’s 2016 YTD sales & trading revenue per $ of average VaR was $248MM compared to C’s $175MM. 3 CET1 defined as Common Equity Tier 1 capital. Represents the trading and counterparty losses from the severely adverse scenario of the 2016 Dodd-Frank Act Stress Test results, published on 6/23/16, divided by CET1 on a fully phased-in basis as of 12/31/15 as disclosed in SEC filings. 17 We must grow in a sustainable manner 18 Recent Results Reflect Reduced Volatility 2010-2014 Diluted EPS 1, 2 2015-2016 Diluted EPS $0.56 $0.28 $0.32 $0.27 $0.41 $0.27 $0.28 $0.29 $0.28 $0.19 $0.17 $0.41 $0.38 $0.38 $0.27 $0.20 $0.10 $0.15 $0.20 $0.03 $0.03 $0.00 ($0.03) ($0.16) ($0.04) ($0.77) ($0.90) Q1 Q2 Q3 2010 Q4 Q1 Q2 Q3 Q4 2011 $83B $28B Net Charge-offs ____________________ Rep & Warranty Q1 Q2 Q3 Q4 2012 Q1 Q2 Q3 Q4 Q1 2013 $36B Q2 Q3 2014 Q4 Q1 Q2 Q3 2015 Q4 Q1 Q2 Q3 2016 $44B Litigation Expense Legacy Mortgage Servicing 1 Periods shown after 4Q14 reflect the change in accounting method for the amortization of premium and accretion of discount related to certain debt securities carried at fair value and held-to-maturity. For additional information regarding this change in accounting, please see the 8-K filed on 10/4/16. 2 Litigation expense includes the $1.1B provision for the Independent Foreclosure review acceleration agreement in 2012. Legacy mortgage servicing expenses excludes litigation expense. 19 Solid Progress Towards Long-term Financial Targets BAC Long-Term Financial Targets 1% ROA 12% ROTCE 3Q16 Results • ROA of 0.9% • ROTCE of 10.3% (above cost of capital) Common Dividends and Share Repurchases ($B) $5.6 $6 $4.5 $3.6 $4 • Efficiency ratio of 62% • Distributed $5.6B in capital through common stock repurchases and dividends 2016 YTD 1 vs. $3.1B 2015 YTD Increase capital return to shareholders ~60% Efficiency ratio $2.9 3.2 $2 $0 $0.4 0.4 $0.4 0.4 $0.4 0.4 0.4 2010 2011 2012 2013 Dividends 2.4 3.8 1.7 1.3 2014 2.1 1.8 2015 2016 YTD Gross repurchases ____________________ Note: Amounts may not total due to rounding. 1 As of 9/30/2016. 20 Investing in the Franchise Consumer • Investing in new digital capabilities ‒ Real-time P2P payments ‒ Free FICO scores ‒ Launched Spanish mobile app ‒ Introduced artificial intelligence • functionality (“Erica”) 6,000 cardless-enabled ATMs (launched in 1Q16) • Deployed 3,500+ digital ambassadors in financial centers Banking and Markets Wealth Management • Multi-year investment in Merrill Lynch One (fee-based advisory platform) • Launching Merrill Edge Guided Investing – online investing + professional portfolio management • Investment in Practice Management & Development (PMD) program (new advisor training) • Increased wealth advisors by nearly 700 since 2014 • Enhanced IVR capabilities to improve client experience • Targeted banking center entry (e.g. • Invested $1.1B in GTS over last 4 years to enhance functionality and strengthen our core treasury business • Improved local coverage in Global Commercial Banking and Business Banking ‒ Increased percentage of clients served by a local market coverage officer from 59% to 90% • Established a centralized Wholesale Credit function to drive efficiencies • Migrating to new trading platform with enhanced functionality • Electronic trading enhancements Denver, Minneapolis) Continued franchise investment included in firm-wide 2018 expense target of $53B ― Focused on expense discipline including technology/digital efficiencies as well as lower mortgage servicing costs Have invested ~$3B annually on technology initiatives Made significant investments in cybersecurity, compliance and regulatory functions while replacing many enterprise platforms Added >1,000 primary sales associates year-over-year across Consumer Banking, GWIM, and Global Banking 21 Strong Focus on ESG Aids Sustainability Environmental Social Governance • $125B environmental business initiative to accelerate the transition to a lowcarbon economy • No. 1 underwriter of green bonds • Commitment for our own operations to be Carbon Neutral by 2020 and use 100% renewable electricity • • • • • • 52% of global workforce is female 44% of U.S.-based workforce is from a racially or ethnically diverse background Driving competitive pay practices across all levels of associates Expanded parental leave to 16 weeks Offer transparent, responsible products and services Invested more than $185MM in philanthropy in local communities in 2016 • Strengthened ESG Committee • Introduced an Environmental and Social Risk Policy Framework that outlines our business practices in key areas of ESG interest 22 Summary • Our company today is stronger, simpler and better prepared • We are driving responsible growth • Recent quarterly results more representative of power of franchise • We are benefitting from strong client activity and strong risk management • Focused on controllable elements of balance growth and expense management • Our businesses are operating well with returns above the cost of capital 23 Forward-Looking Statements Bank of America 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 Bank of America's current expectations, plans or forecasts of its future results, revenues, expenses, efficiency ratio, capital measures, 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 Bank of America'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 elsewhere in this report, including under Item 1A. Risk Factors of the Corporation's 2015 Annual Report on Form 10-K and in any of the Corporation's subsequent Securities and Exchange Commission filings: the Corporation's ability to resolve representations and warranties repurchase and related claims, including claims brought by investors or trustees seeking to distinguish certain aspects of the New York Court of Appeals' ACE Securities Corp v. DB Structured Products, Inc. (ACE) decision or to assert other claims seeking to avoid the impact of the ACE decision; the possibility that the Corporation could face increased servicing, securities, fraud, indemnity, contribution or other claims from one or more counterparties, including trustees, purchasers of loans, underwriters, issuers, other parties involved in securitizations, monolines or private-label and other investors; the possibility that future representations and warranties losses may occur in excess of the Corporation's recorded liability and estimated range of possible loss for its representations and warranties exposures; potential claims, damages, penalties, fines and reputational damage resulting from pending or future litigation and regulatory proceedings, including the possibility that amounts may be in excess of the Corporation's recorded liability and estimated range of possible loss for litigation exposures; the possible outcome of LIBOR, other reference rate, financial instrument and foreign exchange inquiries, investigations and litigation; 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 (including negative or continued low interest rates), currency exchange rates and economic conditions; the possibility that future credit losses may be higher than currently expected due to changes in economic assumptions, customer behavior and other uncertainties; the impact on the Corporation's business, financial condition and results of operations of a potential higher interest rate environment; the impact on the Corporation's business, financial condition and results of operations from a protracted period of lower oil prices or ongoing volatility with respect to oil prices; our ability to achieve our expense targets; adverse changes to the Corporation's credit ratings from the major credit rating agencies; estimates of the fair value of certain of the Corporation's assets and liabilities; uncertainty regarding the content, timing and impact of regulatory capital and liquidity requirements, including the potential adoption of total loss-absorbing capacity requirements; the potential for payment protection insurance exposure to increase as a result of Financial Conduct Authority actions; the impact of Federal Reserve actions on the Corporation's capital plans; the possible impact of the Corporation's failure to remediate deficiencies and shortcomings identified by banking regulators in the Corporation's Recovery and Resolution plans; 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, FDIC assessments, the Volcker Rule, fiduciary standards and derivatives regulations; a failure in or breach of the Corporation's operational or security systems or infrastructure, or those of third parties, including as a result of cyber attacks; the impact on the Corporation's business, financial condition and results of operations from the potential exit of the United Kingdom from the European Union; and other similar matters. Forward-looking statements speak only as of the date they are made, and Bank of America 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. 24 Important Presentation Information • The information contained herein speaks only as of the particular date or dates included in the accompanying slides. Bank of America does not undertake an obligation to, and disclaims any duty to, update any of the information provided. • • Certain prior period amounts have been reclassified to conform to current period presentation. • The Company’s fully phased-in Basel 3 estimates and the supplementary leverage ratio are based on the Standardized and Advanced approaches under Basel 3 and supplementary leverage ratio final rules. Under the Basel 3 Advanced approaches, risk-weighted assets are determined primarily for market risk and credit risk, similar to the Standardized approach, but also incorporate operational risk and a credit valuation adjustment component. Market risk capital measurements are consistent with the Standardized approach, except for securitization exposures, where the Supervisory Formula Approach is also permitted. Credit risk exposures are measured using internal ratings-based models to determine the applicable risk weight by estimating the probability of default, loss given default and, in certain instances, exposure at default. The internal analytical models primarily rely on internal historical default and loss experience. The calculations under Basel 3 require management to make estimates, assumptions and interpretations, including the probability of future events based on historical experience. Actual results could differ from those estimates and assumptions. Bank of America received approval to begin using the Advanced approaches capital framework to determine risk-based capital requirements beginning in the fourth quarter of 2015. As previously disclosed, with the approval to exit parallel, U.S. banking regulators requested modifications to certain internal analytical models including the wholesale (e.g., commercial) credit models, which increased our risk-weighted assets under the Advanced approaches beginning in the fourth quarter of 2015. These Basel 3 fully phased-in Advanced approaches estimates assume approval by U.S. banking regulators of our internal analytical models, including approval of the internal models methodology (IMM). As of September 30, 2016, BAC did not have regulatory approval for the IMM model. Our estimates under the Basel 3 Advanced approaches may be refined over time as a result of further rulemaking or clarification by U.S. banking regulators. • The Company allocates capital to its business segments using a methodology that considers the effect of regulatory capital requirements in addition to internal risk-based capital models. The Company's internal risk-based capital models use a risk-adjusted methodology incorporating each segment's credit, market, interest rate, business and operational risk components. Allocated capital is reviewed periodically and refinements are made based on multiple considerations that include, but are not limited to, riskweighted assets measured under Basel 3 Standardized and Advanced approaches, business segment exposures and risk profile and strategic plans. As a result of this process, in the first quarter 2016, the Company adjusted the amount of capital being allocated to its business segments. The Corporation may present certain key performance indicators and ratios excluding certain items which result in non-GAAP financial measures. The Corporation believes the use of these non-GAAP financial measures provides additional clarity in understanding its results of operations and trends. The Company views net interest income and related ratios and analyses on a fully taxable-equivalent (FTE) basis, which when presented on a consolidated basis, are non-GAAP financial measures. The Company believes managing the business with net interest income on an FTE basis provides investors with a more accurate picture of the interest margin for comparative purposes. For more information about the non-GAAP financial measures contained herein, please see the presentation of the most directly comparable financial measures calculated in accordance with GAAP and accompanying reconciliations in the earnings press release for the relevant period and other earnings-related information available through the Bank of America Investor Relations web site at: http://investor.bankofamerica.com. 25
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