SecProbe.io

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            November 28, 2005

Mail Stop 4561

By U.S. Mail and facsimile to (704) 386-4579

Mr. Alvaro G. de Molina
Chief Financial Officer
Bank of America Corporation
100 N. Tryon Street
Charlotte, NC  28255

Re:	Bank of America Corporation
	Form 10-K filed March 1, 2005
	File No. 1-06523

Dear Mr. de Molina:

	We have reviewed your filings and have the following
comments.
Where indicated, we think you should revise future filings in
response to these comments.  If you disagree, we will consider
your
explanation as to why our comment is inapplicable or a future
revision is unnecessary.  Please be as detailed as necessary in
your
explanation.  In some of our comments, we may ask you to provide
us
with supplemental information so we may better understand your
disclosure.  After reviewing this information, we may raise
additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

*    *    *    *    *    *    *

Form 10-K for the year ended December 31, 2005

Management`s Discussion and Analysis of Financial Condition and
Results of Operations

Financial Highlights, page 11

1. We note your disclosure on page 12 that during 2004, the return
of
securitized loans to your balance sheet resulted in an increase to
your provision for credit losses in your consumer credit card
portfolio.  We also note your disclosure on page 57 that you
anticipate the return of approximately $4.5 billion of securitized
loans to the balance sheet in 2005.  For each period presented in
your filing, please:

* tell us what caused the return of previously securitized loans
to
the balance sheet;

* quantify the amount of securitized loans returned to the balance
sheet by loan type; and

* quantify the impact that the return of these loans had upon your
provision for credit losses by loan type.

Consolidated Financial Statements

Note 1 - Summary of Significant Accounting Principles, page 90

2. We note your disclosure on page 94 that you net cash collateral
against the applicable derivative mark-to-market exposures based
upon
provisions contained in legal netting agreements.  It appears that
similar disclosure was not provided in your 12/31/03 Form 10-K.
Please tell us whether this represents an accounting policy change
to
your method of handling cash collateral.  If your policy has
changed,
please tell us when this change was made and whether all periods
are
presented on the same basis.  If applicable, please tell us
whether
you received a preferability letter from your independent
accountants
regarding this change.

3. Please tell us and revise future filings to clarify your
accounting policies regarding unrealized gains or losses on
derivative contracts held for trading purposes.  Refer to EITF 02-
3.
Please provide us with the following information:

* describe your accounting policy for recognition of unrealized
gains
and losses at the inception of the contracts;

* describe your accounting policy for recognition of previously
unrecognized gains and losses subsequent to inception.  Tell us
whether these gains and losses are ever recognized and if so,
describe the conditions for recognition;

* separately quantify unrecognized gains and losses at the
inception
of the contracts and recognized gains and losses subsequent to
inception during each period presented; and

* if you have deferred losses, please tell us the authoritative
literature you rely upon to support this position.

Note 2 - Merger and Restructuring Activity, page 102

4. It appears that your disclosures regarding the FleetBoston
merger
do not include the matters described in paragraphs 51(b), 51(f)f,
51(h), and 52(c)(1) of SFAS 141.  Please tell us why you believed
these disclosure requirements were not applicable to this
transaction.

Note 11 - Short-term Borrowings and Long-term Debt, page 120

5. Please revise future filings to disclose the significant terms
of
your advances from each of the Federal Home Loan Banks.  The terms
to
be disclosed should include interest rates, maturity dates,
conversion features and call dates associated with the advances,
where applicable.  Refer to paragraph 14(h) of SOP 01-6.

Note 12 - Commitments and Contingencies

6. We note your March 3, 2005 Form 8-K in which you announced an
agreement to settle class action litigation with WorldCom
securities
holders for $460.5 million.  Your press release states that the
expense of the settlement was provided for in prior periods but
your
Form 10-K disclosures in Note 12 to the consolidated financial
statements do not include a range of possible loss for this matter
as
required by paragraph 10 of SFAS 5.

In future filings beginning with your Form 10-K for the year ended
December 31, 2005, please revise your disclosures for each
litigation
matter to clearly describe whether estimated losses from
litigation
contingencies are both probable and estimable, estimable but not
probable, or neither.  To the extent that estimated losses related
to
litigation contingencies are both probable and estimable, please
revise future filings to disclose an estimate of the possible loss
or
a range of loss.  Refer to paragraphs 8-10 of SFAS 5.

*    *    *    *    *    *    *

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
cover letter that keys your responses to our comments and provides
any requested supplemental information.  Detailed cover letters
greatly facilitate our review.  Please understand that we may have
additional comments after reviewing your responses to our
comments.

        We urge all persons who are responsible for the accuracy
and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require.
Since the company and its management are in possession of all
facts
relating to a company`s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.

        In connection with responding to our comments, please
provide, in writing, a statement from the company acknowledging
that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff do not foreclose the
Commission from taking any action with respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

 	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

	You may contact Lisa Haynes, Staff Accountant at (202) 551-
3424
or me at (202) 551-3490 if you have questions.

								Sincerely,

	                        	Donald A. Walker
				Senior Assistant Chief Accountant

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Mr. Alvaro G. de Molina
Bank of America Corporation
November 28, 2005
Page 5

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