SEC Company Response from BANK OF AMERICA (BAC) — Jun 27, 2018
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: June 27, 2018 · CIK: 0000070858 · Accession: 0001193125-18-205025
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-224523
Letter
BANK OF AMERICA CORPORATION
Bank of America Corporate Center
100 North Tryon Street
Charlotte, North Carolina 28255
June 27, 2018
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-010
Attention: Era Anagnosti, Legal Branch Chief, Office of Financial Services
Jessica Livingston, Staff Attorney
Re: Bank of America Corporation
Registration Statement on Form S-3 (File No. 333-224523)
Request for Acceleration of Effectiveness
Ladies and Gentleman:
In accordance with Rule 461 under the Securities Act of 1933, as amended, Bank of America Corporation, BAC Capital Trust XIII, BAC Capital Trust XIV, BAC Capital Trust XV and Merrill Lynch Capital Trust I (the “Registrants”), hereby request acceleration of the effective date of the Registration Statement on Form S-3 (No. 333-224523) (the “Registration Statement”) so that it will become effective at 9:00 a.m., New York City time, on June 29, 2019, or as soon thereafter as practicable. The members of the underwriting group for a “take down” from the Registration Statement have not been finally determined.
Please contact Richard W. Viola at (704) 343-2149 or Elizabeth G. Wren at (704) 343-2319, of McGuireWoods LLP, counsel to the Registrants, as soon as the Registration Statement has been declared effective, or if you have any other questions or concerns regarding this matter.
Very truly yours,
BANK OF AMERICA CORPORATION
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CORRESP
BANK OF AMERICA CORPORATION
Bank of America Corporate Center
100 North Tryon Street
Charlotte,
North Carolina 28255
June 27, 2018
VIA EDGAR
Securities and Exchange Commission
Division of Corporation
Finance
100 F Street, N.E.
Washington, D.C. 20549-010
Attention: Era Anagnosti, Legal Branch Chief, Office of
Financial Services
Jessica
Livingston, Staff Attorney
Re: Bank of America Corporation
Registration Statement on Form S-3 (File
No. 333-224523)
Request for Acceleration of Effectiveness
Ladies and Gentleman:
In accordance with
Rule 461 under the Securities Act of 1933, as amended, Bank of America Corporation, BAC Capital Trust XIII, BAC Capital Trust XIV, BAC Capital Trust XV and Merrill Lynch Capital Trust I (the “Registrants”), hereby request acceleration of
the effective date of the Registration Statement on Form S-3 (No. 333-224523) (the “Registration Statement”) so that it will become effective at 9:00 a.m., New
York City time, on June 29, 2019, or as soon thereafter as practicable. The members of the underwriting group for a “take down” from the Registration Statement have not been finally determined.
Please contact Richard W. Viola at (704) 343-2149 or Elizabeth G. Wren at (704) 343-2319, of McGuireWoods LLP, counsel to the Registrants, as soon as the Registration Statement has been declared effective, or if you have any other questions or concerns regarding this matter.
Very truly yours,
BANK OF AMERICA CORPORATION
By:
/s/ Vincent Lichtenberger
Name:
Vincent Lichtenberger
Title:
Associate General Counsel
Securities and Exchange Commission
June 27, 2018
Page
2
BAC CAPITAL TRUST XIII
BAC CAPITAL TRUST XIV
BAC CAPITAL TRUST XV
By:
/s/ Shannon Lilly
Name:
Shannon Lilly
Title:
Regular Trustee
By:
/s/ Julia Yoffee
Name:
Julia Yoffee
Title:
Regular Trustee
MERRILL LYNCH CAPITAL TRUST I
By:
/s/ Shannon Lilly
Name:
Shannon Lilly
Title:
Administrative Trustee
By:
/s/ Julia Yoffee
Name:
Julia Yoffee
Title:
Administrative Trustee