SecProbe.io

October 22, 2010
 Brian T. Moynihan  Chief Executive Officer, President and Director  Bank of America Corporation Bank of America Corporate Center 100 N. Tryon Street Charlotte, NC  28255
RE: Bank of America Corporation
Form 10-K for the Fiscal Year Ended December 31, 2009 Forms 10-Q for the Quarterly Periods Ended March 31, 2010
and June 30, 2010 File No.: 001-06523

Dear Mr. Moynihan:

We have reviewed your response letter da ted August 25, 2010 and have the following
comments.  In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
 Please respond to this letter within te n business days by providing the requested
information, including a draft of your proposed disclosures to be made in future filings, or by
advising us when you will provide the requested  response.  If you do not believe our comments
apply to your facts and circumstances or do not believe future revisions are appropriate, please tell us why in your response.
 After reviewing the information you provide in response to these comments, including
the draft of your proposed disclosures, we may have additional comments.
            Form 10-Q for Quarterly Period Ended June 30, 2010

Financial Statements

Notes to Consolidated Financial Statements

Note 6 – Outstanding Loans and Leases, page 30

1. We note your response to prior comment te n of our letter dated May 3, 2010.  In your
response, you clarified that your renegotiated loans are classified as TDRs.  However, it is not clear from your disclosure on pages 31 – 32 that your rene gotiated portfolio is

 Mr. Brian T. Moynihan
Bank of America Corporation  October 22, 2010 Page 2

classified similarly.  For example, on page 31 you quantify the amount of performing and nonperforming TDRs; however it does not app ear that your $14.1 b illion renegotiated
portfolio is included in these amounts.  Please revise your future filings to clarify whether
the loans in your renegotiated po rtfolio are classified as TDRs.  To provide greater clarity
around your TDR portfolio, please also consid er disclosing your TDRs in a tabular
format by loan type and accrual status.
 Note 8 – Securitizations and Other Va riable Interest Entities, page 34

 2. We note your responses to comments two th rough five of our letter dated July 30, 2010
and the related disclosures on pages 40 – 41 related to your representations and
warranties obligations.  In an effort to provide greater transparency surrounding your
representations and warranties exposure, please  revise your future fi lings to disclose the
following:
• Provide a tabular rollforward  of your representations and warranties obligation for
each period presented, with clear disclosure  about the types of claimants that are
excluded from your accrual (e.g., certain  monoline insurers, private label
investors, and any other significant thir d parties not alrea dy disaggregated.);
• Provide a sensitivity analysis that i llustrates how changes in significant
assumptions would impact the amount of  your recognized repurchase obligation;
• We note that you disclose the unpaid principal balance of loans for which the monolines requested loans files for revi ew but for which no repurchase request
has been received.  If available, provid e similar disclosure for GSEs and other
purchasers; and
• With respect to your unresolved repurc hase requests from monoline insurers,
separately disclose the amount of unresolved repurchase requests for those monolines for which a liability  has not been established.
 3. As a related matter, in your response to co mment five you state that monoline repurchase
claims are generally made on loans that have  or will have a loss and where the monolines
have advanced funds to the securitization trus ts.  Please tell us a nd revise your future
filings to disclose what happens in the event a monoline insurer ceases funding advances to a securitization trus t and how this information is taken into account when estimating
your repurchase obligation.
 Note 11 – Commitments and Contingencies, page 53

 Litigation and Regulatory Matters, page 57

 4. We note that you disclose an aggregate po ssible range of loss in excess of amounts
accrued for certain litigation matters for wh ich you are able to estimate a range of
possible loss.  In the interest of transparency, please revise your future filings to clearly

 Mr. Brian T. Moynihan  Bank of America Corporation  October 22, 2010 Page 3

disclose that this range of possible loss does not represent your maximum loss exposure
as you were not able to estimate a range of  loss for all of your litigation matters.
               You may contact Angela Conne ll, Staff Accountant, at (202) 551-3426 or me at
(202) 551-3872 if you have any questions.
Sincerely,

Hugh West Accounting Branch Chief