SecProbe.io

January 31, 2011
 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,
June 30, 2010 and September 30, 2010 Form 8-K filed January 21, 2011 File No.: 001-06523

Dear Mr. Moynihan:
 We have reviewed your response letter da ted January 20, 2011 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 September 30, 2010

 Notes to Consolidated Financial Statements

 Note 6 – Outstanding Loans and Leases

 Impaired Loans and Troubled Debt Restructurings, page 30

 1. We note that you have a significant credit car d portfolio and that as of September 30,
2010 you had $10.4 billion of domestic and fore ign credit card loans that had been

 Mr. Brian T. Moynihan  Bank of America Corporation  January 31, 2011 Page 2

renegotiated, substantially all of which are c onsidered to be troubled debt restructurings
(TDRs).  Please tell us whether any of your credit card loan agreements have provisions
where the interest rate on the credit card loan is automatically increased due to non-
payment, late-payment, or similar events.  If  so, tell us how you determined the effective
interest rate of the loan existing at the origin ation or acquisition of the loan at the time of
the TDR for purposes of measuring the amount of the impairment.  For example, tell us
whether for purposes of this calculation you assumed the interest rate existing at the
origination was the original rate, prior to be ing increased for any events of default/late
payment, or the rate immediately in  effect prior to the modification.

Management’s Discussion and Analysis of Financ ial Condition and Results of Operations, page
92
 Representations and Warranties, page 139

 2. We note your responses to prior comments se ven and eight of our letter dated December
22, 2010 regarding the claims process with m onoline insurers, whole loan purchasers and
investors in private label securitiza tions.  Please respond to the following:

a. Your response indicates that approxima tely 12 percent and 68 percent of the
claims that you initially denied from  the monolines and whole loan sales
purchasers/private-label securitizations, respectively, have been resolved through
repurchase, make-whole payments or rescission.  Please disaggregate this
percentage separately for situations wh ere the claims are la ter resolved through
(a) repurchase or make-whole pa yments and (b) rescission.

b. Tell us how your original rejection impacts the timing and amount of the
repurchase reserve, such as  whether the reserve is im mediately reduced after your
original rejection, or whether the repurcha se reserve is adjusted only after final
resolution of the claim between you and the counterparty.  Please ensure your
response covers each of the counterpart ies individually given your disclosures on
page 40 about how the reserve is estab lished by counterparty and the differences
that may arise given those circumstances.

c. Your response indicates that certain m onolines have been unwilling to withdraw
repurchase requests, regardless of the evidence that you have provided.  Please
tell us whether you have other contractua l relationships with these monolines and
whether you have encountered other ci rcumstances where you or the monoline
have determined not to perform in light of  the open issues related to the mortgage
repurchase requests.

d. We note your disclosure on page 41 where you indicate the amount of unresolved
repurchase requests received from the m onolines that have been reviewed and

 Mr. Brian T. Moynihan  Bank of America Corporation  January 31, 2011 Page 3

where you believe a valid defect has not been  identified.  In light  of the fact that
in some situations after your  originally reject a claim, you later end up resolving
the matter through a make-whole payment or repurchase, please clarify this
disclosure to clearly indicate that sc enario as a potential outcome and add
disclosure addressing how that outcome is  factored into any reserve liability.
 Credit Risk Management, page 155

 Allowance for Credit Losses, page 189

 3. Please tell us whether the component of your  allowance for loan and lease losses that
covers performing consumer and commercial lo ans and leases which have incurred losses
that are not yet individually identifiable f actors in contractual interest payments not
expected to be collected on the loan.  If  so, tell us how your  model captures this
expectation and consider providing further di sclosure about this in your Form 10-K for
the fiscal year ended December 31, 2010.
 Form 8-K filed January 21, 2011

4. We note your disclosure on page 14 of your  earnings release that you recorded $4.1
billion of representations a nd warranties expense, which in cluded $3.0 billion related to
the GSE agreements, as well as adjustments to the representations and warranties liability for loans sold directly to the GSEs.  Please tell us why you had to recognize the entire
$3.0 billion settlement with th e GSEs as additional expense during the quarter given the
level of mortgage repurchase liability as of September 30, 2010 and the disclosures you
made indicating that you have an established history of working with the GSEs and thus
would have better been able to establish at l east some reserve related to future repurchase
requests.  As part of your re sponse, please clarify the amount of the repurchase reserve as
of December 31, 2010 by counterparty, and consid er including this information in your
Form 10-K for the year ended December 31, 2010.
              You may contact Angela Conne ll, Staff Accountant, at (202) 551-3426 or me at
(202) 551-3512 if you have any questions.
Sincerely,

Stephanie L. Hunsaker Senior Assistant Chief Accountant