BOARD OF GOVERNORS 

Of THE 

FEOERAL RESERVE SYSTEM 

...... 

Ms. Denise Sawyer 

Executive Vice President 

Bank of America Corporation 

NC1-021-06-22 

WASHINGTON, O. [. 20551 

401 North Tryon Street 

Charlotte, North Carolina 28255 

Dear Ms. Sawyer: 

ADDRESS OFFICIAL CORRESPONDENCE 

TO THE BOARD 

April 13, 2009 

This is in response to the request by Bank of America Corporation 

("BAC"), Charlotte, North Carolina, for temporary relief from, and other 

modifications related to, the Board's regulatory reporting requirements for 

bank holding companies ("BHCs") for first quarter 2009 and future 

reporting periods in connection with BAC's acquisition of 

Merrill Lynch & Co., Inc. ("Merrill Lynch"), New York, New York. 

On November 26, 2008, the Board approved the application by BAC 

to acquire Merrill Lynch, and the acquisition was consummated on 

January 1,2009.1 You have stated that BAC needs time to adjust its 

accounting processes, systems, and infrastructure to report information about 

Merrill Lynch to the Board. 

Based on all the facts of record, including the information provided in 

your request and other supervisory information, the Director of the Division 

of Banking Supervision and Regulation, with the concurrence of the General 

Counsel, acting under delegated authority, has granted in substantial part the 

temporary relief from the Board's regulatory reporting requirements for the 

March 31,2009, and future reporting dates that BAC has requested. The 

Board is aware of the magnitude and complexity of the work required in 

order for BAC to develop the reporting systems to incorporate the 

acquisition of Merrill Lynch and to comply with the Board's reporting 

requirements for BHCs. The attachment to this letter details each of your 

I Bank of America Corporation, 95 Federal Reserve Bulletin B13 (2008). 
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requests and the Board's response on a report-by-report basis. The Board 

has designed the temporary exemption to ensure that your organization will 

continue to devote the necessary resources to become fully compliant with 

the Board's regulatory reporting requirements for BHCs as soon as possible. 

The reporting relief provided herein relates only to incorporating Merrill 

Lynch into BAC's existing reporting systems and does not relieve BAC of 

any other regulatory reporting requirements. 

Please contact Lisa White of the Federal Reserve Bank of Richmond 

at (704) 358-2548 if you have any questions. 

Sincerely yours, 

Robert deV. Frierson 

Deputy Secretary of the Board 

cc: Lisa White, Assistant Vice President 

Federal Reserve Bank of Richmond 

Attachment 
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Attachment 

1. FR Y-9C (Consolidated Financial Statements for Bank Holding 

Companies) 

BAC has requested that it be allowed to submit its March 31, 2009, 

FR Y-9C report on a modified basis as follows: (1) Schedule HC-N would 

primarily incorporate data currently available at the bank level (excluding 

nonbank data) for Merrill Lynch; and (2) data for the remainder of the 

Merrill Lynch organization would include only instruments greater than 90 

days past due and would be reported on Schedule HC-N, column B, as still 

accruing until more detailed data can be obtained. In addition, BAC has 

requested that data for Schedule HC-S include only Merrill Lynch 

bank-level data for each detailed category and line item; additional data for 

Merrill Lynch required by schedule HC-S would include outstanding 

principal balances of assets sold and securitized plus any other required data 

from Merrill Lynch that may be available on a best-efforts basis. BAC 

expects to be in full compliance with the reporting requirements of 

Schedules HC-N and HC-S for the June 30, 2009, reporting date. 

Board Response on FR Y -9C 

BAC is granted permission to submit its March 31, 2009, FR Y -9C 

report on a modified basis as described in its request. BAC must disclose in 

footnotes to the FR Y -9C its basis for reporting on Schedules HC-Nand 

HC-S. Moreover, additional footnote disclosures should identify significant 

issues or deviations from the reporting requirements in the FR Y -9C report, 

as appropriate. 

2. FR Y-11 (Financial Statements of u.s. Nonbank Subsidiaries of 

U.S. Bank Holding Companies) and FR 2314 (Financial 

Statements of Foreign Subsidiaries of u.s. Bank Holding 

Companies) 

BAC has indicated that it plans to submit FR Y -11 and FR 2314 

reports for the six most significant Merrill Lynch subsidiaries (by asset size) 

for the first three quarters of2009. BAC has requested that it be given until 

December 31 , 2009, to submit the FR Y -11 and FR 2314 reports for all other 

Merrill Lynch subsidiaries. 
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Board Response on FR Y-ll and FR 2314 

BAC is granted an exemption from filing the FR Y -11 and FR 2314 

reports for all Merrill Lynch subsidiaries until the September 30,2009, 

reporting date except for the six most significant Merrill Lynch subsidiaries 

(by asset size). BAC must submit the FR Y -11 and FR 2314 reports for the 

six most significant Merrill Lynch subsidiaries beginning with the 

March 31,2009, reporting date. The Board believes that two reporting 

periods should provide adequate time for BAC to achieve full compliance 

with the reporting requirements of the FR Y -11 and FR 2314 reports. 

3. FFIEC 009 (Country Exposure Report/Country Exposure 

Information Report) 

BAC has requested that it be allowed to submit the FFIEC 009 report 

on a best-efforts basis for March 31, 2009, reporting date. 

Board Response on FFIEC 009 

BAC is permitted to submit its FFIEC 009 report on a best-efforts 

basis for the March 31, 2009, reporting date. BAC should be in full 

compliance with the reporting requirements of the FFIEC 009 report as of 

the June 30, 2009, reporting date.