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SEC Company Response from BANK OF AMERICA (BAC) — Oct 30, 2008

BANK OF AMERICA CORP /DE/ (BAC, BAC-PB, BAC-PE, BAC-PK, BAC-PL, BAC-PM, BAC-PN, BAC-PO, BAC-PP, BAC-PQ, BAC-PS, BML-PG, BML-PL) (CIK 0000070858)
Date: Oct. 30, 2008 · CIK: 0000070858 · Accession: 0000898822-08-001060

Offering / Registration Process Regulatory Compliance Financial Reporting

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File numbers found in text: 333-153771

Date
October 30, 2008
Author
By: /s/ Teresa M. Brenner
Form
CORRESP
Company
BANK OF AMERICA CORP /DE/ (BAC, BAC-PB, BAC-PE, BAC-PK, BAC-PL, BAC-PM, BAC-PN, BAC-PO, BAC-PP, BAC-PQ, BAC-PS, BML-PG, BML-PL) (CIK 0000070858)

Letter

VIA EDGAR Securities and Exchange Commission Division of Corporation Finance Attention: Re: Bank of America Corporation Registration Statement on Form S-4/A, Filed October 29, 2008 File No. 333-153771

Dear Mr. Windsor:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Bank of America Corporation (the “Registrant”) hereby requests acceleration of effectiveness of its Registration Statement on Form S-4/A (File No. 333-153771) to 5:00pm EST on Thursday, October 30, 2008, or as soon as possible thereafter.

In connection with the foregoing request for acceleration of effectiveness, the Registrant hereby acknowledges the following:

Should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

The action of the Commission or staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

The Registrant may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Christian Windsor

October 30, 2008

Page 2

Please contact the undersigned at (704) 386-4238 with any questions you may have concerning this request. In addition, please contact the undersigned when this request for acceleration has been granted.

Very truly yours,
By: /s/ Teresa M. Brenner

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CORRESP
1
filename1.htm

   accelerationrequest.htm -- Converted by SEC Publisher, created by BCL Technologies Inc., for SEC Filing

     Bank of America Corporation

101 South Tryon Street

NC2-002-29-01

Charlotte NC 28255

October 30, 2008

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

     Attention:

     Christian Windsor

     Re:

     Bank of America Corporation

     Registration Statement on Form S-4/A, Filed October 29, 2008

     File No. 333-153771

Dear Mr. Windsor:

     Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Bank of America Corporation (the “Registrant”) hereby requests acceleration of effectiveness of its Registration Statement on Form S-4/A (File No. 333-153771) to 5:00pm EST on Thursday, October 30, 2008, or as soon as possible thereafter.

     In connection with the foregoing request for acceleration of effectiveness, the Registrant hereby acknowledges the following:

Should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

The action of the Commission or staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

The Registrant may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Christian Windsor

October 30, 2008

Page 2

     Please contact the undersigned at (704) 386-4238 with any questions you may have concerning this request. In addition, please contact the undersigned when this request for acceleration has been granted.

     Very truly yours,

     By: /s/ Teresa M. Brenner

     Teresa M. Brenner

     Associate General Counsel