global reporting initiative framework

Global Reporting Initiative Framework

2 | 2006 Sustainability Report

Contents

Introduction 04

Internal Organization Around Sustainability 14

Sustainability–Our Business & Related Policies 16

Implementation of Sustainability 26

Appendix 39


GRI G3 Sections/ Indicator

Message from Kenneth Lewis At Bank of America, we recognize that our decisions have impact far beyond the financial transactions that define our business. We know our leadership influences economic vitality, the well-being of our communities and even the way people live.

This understanding guides our commitment to environmental protection and mitigating human contributions to climate change. For example:

• We work to minimize the environmental impact of our operations, and to stay abreast of technological advances that can provide further environmental benefits.

• We encourage loans to and investments in environmentally-beneficial endeavors, including research and development of clean energy sources.

• We take a leadership role in working with public and private partners to create solutions that are beneficial to the environment as well as the economy.

I believe companies have a responsibility to share information with the public about the environmental impact of their business and steps they are taking to mitigate that impact. In accordance with modern standards of governance, these reports should be regular, metrics-based, transparent and forthright. This report continues and expands on our reporting commitments to date. Future reports will include even more data and informa-tion regarding our work with clients to create new business opportunities to address climate change.

Creating environmentally sustainable economic growth is an important part of the way we do business. This report is a demonstration of some of the work we’re doing to sustain a healthy, clean environment for ourselves and future generations.

Kenneth D. Lewis Chairman, Chief Executive Officer and President

1.1



Introduction

Business and Sustainability Impact on SustainabilityAt Bank of America, our environmental policies are shaped by our conviction that the health of our company is dependent on the health of communities and our society. Un-derstanding that every part of our business has a potential impact on our environment, we commit to integrating environmental policy into our company’s operations and to supporting the growth of environmentally sustainable business activity that addresses global climate change. Recognizing that sustainability is a journey, Bank of America is committed to good environmental behavior and began implementing a series of environ-mental efforts nearly two decades ago. In this effort, Bank of America continues to build on lending policies, corporate environmental initiatives and associate programs that are environmentally conscious.

Trends in Sustainability & Business OpportunitiesBank of America recognizes an opportunity to support our customer’s efforts to build an environmentally sustainable economy -- through innovative home and office construc-tion, new manufacturing technology, changes in transportation and new ways to sup-ply energy. There is a role for Bank of America to contribute, as financing is needed, to encourage the development of environmentally sustainable products and technology; accelerate the deployment of existing technology; and increase energy efficiency.

Commitment to Sustainability/Vision StatementBank of America uses its core values to guide our efforts to promote sustainability. These values are:

• Doing the right thing. Each of us has the freedom, authority and responsibility to do the right thing for our clients, customers, communities – and each other.

• Trusting and teamwork. We rely on each other and succeed together. We take collective responsibility for the quality of client and customer experiences.

• Inclusive meritocracy. We care about each other, focus on results and strive to help all associates develop their full potential. We respect and value each other’s differences.

• Winning. We have a passion for achieving results and winning – for our clients and customers, for our teammates and communities and for our shareholders.

• Leadership. We’re decisive leaders at every level – communicating our vision and taking action to help build a better future.

1.2

4.8



2.5, 3.6, 3.7, 3.9, 3.10, 3.11, 3.13

3.1, 3.2, 3.3, 3.4

Organization of ReportEvolution of Sustainability Reporting at Bank of AmericaBank of America recognizes that successful implementation of our environmental poli-cies relies upon transparency to all stakeholders, including regular public corporate reporting according to the Global Reporting Initiative (GRI) framework.This report cov-ers bank operations in the United States unless otherwise noted. The current report has evolved from the bank’s previous Environmental Reports, and, as such, focuses heavily on environmental indicators. The bank intends to widen reporting in future reports, both geographically and topically. The current report is intended to serve as a bridge between previous – year reports that followed an internally – developed reporting structure, to a report that more closely mirrors the Global Reporting Initiative (GRI) G3 reporting for-mat. Efforts have been made in the current report to reconcile the older internal report-ing format with current G3 guidelines by more explicitly referring to GRI sections and indicators, as well as adding new sections and indicators.

There are neither significant restatements of information from previous year reports, nor changes in scope, boundary or measurement methods. Wherever indicators involve quantitative methods, these are explained in context or as footnotes. All report prepara-tion was carried out by an external consultant, who collected data from a group of over 50 bank associates, encompassing all aspects of Bank activities. The consultant verified data with bank associates, checked calculations based upon relevant best practices, and confirmed that all sections and indicators used in this report conform to GRI G3 Guide-lines.

Reporting Year and Contact PointThis report covers the calendar year 2006. Unless otherwise noted, data are related to calendar year 2006. Bank of America reports on an annual basis, with the previous report covering calendar year 2005. Questions or comments on this report may be submitted to: [email protected]

or via mail at:

Environmental Initiatives Bank of America CT2-102-13-01 777 Main Street Hartford, CT 06115 U.S.A.



3.12Global Reporting InitiativeThe Global Reporting Initiative (GRI) is a common framework for sustainability report-ing. The GRI vision is that reporting on economic, environmental and social performance by all organizations becomes as routine and comparable as financial reporting. GRI accomplishes this vision by developing, continually improving and building capacity around the use of its Sustainability Reporting Framework. An international network of thousands from business, civil society, labor and professional institutions create the content of the Reporting Framework in a consensus-seeking process.

Bank of America began its sustainability reporting by initially reporting on environmen-tal indicators in 1992. Since that time, the bank has produced progress and then sustain-ability reports that held to a nearly annual schedule.

The following table shows the location of the sections and indicators of the GRI G3 Guidelines used in the report.

Section or Indicator from Global Reporting Initiative G3 GuidelinesPage

Number in Report

1.1 Statement from the most senior decision maker 3

1.2 Description of key impacts, risks and opportunities 4, 9

2.1 Name of the organization 10

2.2 Primary brands, products and/or services 11

2.3Operational structure of the organization, including main divisions, operating companies, subsidiaries and joint ventures

11

2.4 Location of organization’s headquarters 10

2.5Number of countries where the organization operates, and names of countries with either major operations or that are specifically relevant to the sustainability issues covered in the report

5

2.6 Nature of ownership and legal form 11

2.7 Markets served 10

2.8 Scale of the reporting organization 10

2.9 Significant changes during the reporting period 13

2.10 Awards received in the reporting period 13, 33

3.1 Reporting period for information provided 5

3.2 Date of most recent previous report 5

3.3 Reporting cycle 5

3.4 Contact point for questions regarding the report or its contents 5

3.6 Boundary of the report 5

3.7 State any specific limitations on the scope or boundary of the report 5

3.9 Data measurement techniques and the bases of calculations 5

3.10Explanation of the effect of any re-statements of information provided in earlier reports, and the reasons for such re-statement

5

3.11Significant changes from previous reporting periods in the scope, boundary, or measurement methods applied in the report

5

3.12 Table identifying the location of the Standard Disclosures in the report 6, 7

3.13 Policy and current practice with regard to seeking external assurance for the report 5



4.1 Governance structure of the organization 11

4.4Mechanisms for shareholders and employees to provide recommendations or direction to the highest governance body

13

4.8Internally developed statements of mission or values, codes of conduct and principles relevant to economic, environmental and social performance and the status of their implementation

4, 20, 21, 22, 26

4.12Externally developed economic, environmental, and social charters, principles, or other initiatives to which the organization subscribes or endorses

29

4.13 Memberships in associations 29

4.14 List of stakeholder groups engaged by the organization 29

4.15 Basis for identification and selection of stakeholders with whom to engage 29

4.16 Approaches to stakeholder engagement 32

4.17 Key topics and concerns that have been raised through stakeholder engagement 33

EN1 Materials used by weight or volume 34, 36

EN2 Percentage of materials used that are recycled input materials 34, 36

EN3 Direct energy consumption by primary energy source 37

EN4 Indirect energy consumption by primary source 37

EN5 Energy saved due to conservation and efficiency improvements 37

EN6Initiatives to provide energy-efficient or renewable energy based products and services, and reductions in energy requirements as a result of these initiatives

17, 37

EN7 Initiatives to reduce indirect energy consumption and reductions achieved 37

EN12Description of significant impacts of activities, products and services on biodiversity in protected areas and areas, of high biodiversity value outside protected areas

37

EN13 Habitats protected or restored 41

EN16 Total direct and indirect greenhouse gas emissions by weight 37

EN17 Other relevant indirect greenhouse gas emissions by weight 37

EN18 Initiatives to reduce greenhouse gas emissions and reductions achieved 16

EN19 Emissions of ozone-depleting substances by weight 37

EN20 NOx, SOx, and other significant air emissions by type and weight 37

EN21 Total water discharge by quality and destination 37

LA13Composition of governance bodies and breakdown of employees per category according to gender, age group, minority group membership and other indicators of diversity

23

SO5 Public policy positions and participation in public policy development and lobbying 23, 47

SO6Total value of financial and in-kind contributions to political parties, politicians and related institutions by country

23, 47

Section or Indicator from Global Reporting Initiative G3 GuidelinesPage

Number in Report



3.12

What’s New in the 2006 ReportThe following sections of the report are new for the 2006 Bank of America Sustainability Report:

• The GRI G3 Guidelines were followed for the first time when preparing this report.

• The number of sections and indicators explicitly mentioned in the report have increased significantly (32 sections and 17 indicators versus 20 sections and 15 indicators in the 2005 report).

• The report includes a comprehensive table showing the page number location of all GRI G3 sections and indicators.

• Data and methodology for reporting on indirect greenhouse gas emissions from the energy and utility portfolio.

• The awards section is more comprehensive, aiming to highlight more of the awards the bank receives relevant within the context of a Sustainability Report.

• Efforts have been made to include more links to online material wherever possible to ensure that the references are current.

• Larger blocks of text such as bank policies on various issues are described briefly in the body of the report and then included in their full form in the appendices and/ or as links to websites.

• Greater emphasis has been given to including “stories” and case studies that better illustrate the bank’s on-the-ground approach to sustainabililty issues.

• Multistakeholder partnerships with external organizations are summarized in a tabular form.

• Details are provided on greenhouse gas emissions, energy consumption, SOx , NOx , and ozone depleting substances (ODS).

• Consumption of material such as carpet and paper is discussed in greater detail.



1.2

1.2

Summary of Achievements The progress on goals stated in the 2005 Bank of America sustainability report is provided below in tabular format.

Goal from 2005 ReportContinue expanded reporting according to GRI standard including the financial services supplement.

Expand reporting on all operations worldwide by 2008.

Expanded training in 2005, implement a training program available to associates involved with credit decisions.

Direct emissions reduction: 9% by 2009 from 2004 benchmark.

Indirect emissions from energy and utility portfolio; goal to realize a 7% reduction by 2008 from 2004 benchmark.

Expanded analysis of goods consumption baseline planned for 2006.

Additional efficiency enhancements planned for 2006.

Phase in PrintSmart Program by 2006; augment toner recycling program.

Leadership in Energy and Environmental Design (LEED) certification of four retail stores by 2007 as part of a pilot program.

Progress by End of Calendar Year 2006GRI G3 Guidelines implemented with significant increases in sections and indicators; as financial services supplement indicators are being updated by GRI for the G3, these will be considered for our 2007 report.

Additional discussions and data collection processes expanded during the reporting cycle especially considering Western Europe in forthcoming reports.

All associates involved in credit decision making processes have access to environmental training programs.

The bank is on-track to meet this goal established with EPA Climate Leaders.

The bank is on track to reach this goal. In-depth discussion of "Utilities Portfolio Emissions Reduction Methodology" included in 2006 report.

Baseline analysis completed.

Details of efficiency measures provided in report.

PrintSmart program completed at existing bank facilities. Toner recycling focused on simplified return process.

Five retail store projects and 11 additional LEED projects registered in 2006. Additional projects registered include office and operations construction and renovations. No LEED certifications were awarded in 2006.

Summary of GoalsBank of America recognizes an opportunity to support our customer’s efforts to build an environmentally sustainable economy. In 2007 and beyond, we will look to match our strength as a financial services provider with the need for financial services and products that help our communities and our customers address global climate change. We will focus on these opportunities through lending, investing, philanthropy and the creation of new products and services. Bank of America set specific targets and goals on these opportunities during the course of 2007. We will also continue to minimize impacts associated with our own operations as our first targeted LEED projects are completed. We will set new, specific targets for operations in 2007 related to certified green building construction and overall operations efficiency.



2.1, 2.4

2.7, 2.8

Organizational ProfileName and LocationBank of America Corporation (NYSE: BAC) is a publicly-traded company headquartered in Charlotte, NC, that operates throughout the United States and 44 foreign countries. The principal executive offices of the Corporation are located in the Bank of America Corporate Center, Charlotte, North Carolina.

Markets ServedBank of America services the retail needs of customers throughout much of the United States and in selected international markets. A complete list of Bank of America’s offices throughout the world by region and the respective services provided can be found at the website,

http://corp.bankofamerica.com/public/public.portal?_pd_page_label=products/re-gions/index.

As of December 31, 2006, there were 203,425 full-time equivalent employees within Bank of America and our subsidiaries. Of these employees, 100,909 were employed within Global Consumer and Small Business Banking, 26,622 were employed within Global Corporate and Investment Banking and 13,728 were employed within Global Wealth and Investment Management . The remainder were employed elsewhere within our company including various staff and support functions.



2.2

2.6

2.3, 4.1

Products and ServicesBank of America is one of the world’s largest financial institutions, serving individual consumers, small and middle market businesses and large corporations with a full range of banking, investing, asset management and other financial and risk-management prod-ucts and services. The company provides unmatched convenience in the United States, serving more than 55 million consumer and small business relationships with more than 5,700 retail banking offices, nearly 17,000 ATMs and award-winning on-line banking with more than 21 million active users. Bank of America is the No. 1 overall Small Business Administration (SBA) lender in the United States and the No. 1 SBA lender to minority-owned small businesses. The company serves clients in 175 countries and has relationships with 98 percent of the U.S. Fortune 500 companies and 80 percent of the Global Fortune 500. Bank of America Corporation stock (NYSE: BAC) is listed on the New York Stock Exchange. Bank of America provides a diversified range of bank-ing and nonbanking financial services and products domestically and internationally through three business segments: Global Consumer & Small Business Banking, Global Corporate & Investment Banking and Global Wealth & Investment Management.

Nature of Ownership and Legal FormBank of America Corporation is a Delaware corporation, a bank holding company and a financial holding company under the Gramm-Leach-Bliley Act. The Corporation was in-corporated in 1998 as part of the merger of BankAmerica Corporation with NationsBank Corporation.

Operational Structure and Structure of Board Bank of America’s operational structure is composed of three principal business lines briefly described below:

Global Consumer & Small Business Banking serves approximately 53 million consumer households through checking, savings, credit and debit cards, home equity lending and mortgages, as well as mass-market small businesses with capital, credit, deposit and payment services.

Global Corporate & Investment Banking provides comprehensive financial solutions to clients ranging from companies with 2.5 million in revenues to large multinational corpo-rations, governments, institutional investors and hedge funds.

Global Wealth & Investment Management provides a wide offering of customized bank-ing and investment services for individual and institutional clients.

GovernanceBank of America is governed by a Board of Directors. The bank’s bylaws stipulate the Board have not less than five nor more than 30 directors. There are currently 17 directors. The Corporate Governance Committee is tasked with periodically reviewing the appropri-ate size of the board, with the objective of maintaining the necessary experience, exper-tise and independence without becoming too large to function efficiently.



Governance & EnvironmentEach major line of business has responsibility and ownership for environmental matters related to that line of business. The bank has also established an enterprise focus on the environment that requires support from across various lines of business and units within the bank. The bank’s Environmental Council was created to assist with the bank’s enterprise commitment. Supported by the bank’s public policy group, the Environmental Council helps ensure development of products, practices and policies aligned with the bank’s environmental commitment. The chair of the Environmental Council reports to the Chief Executive Officer on environmental matters.

The Chairman of the Board and the Chief Executive Officer may be filled by the same individual or by different individuals. The current list of the bank’s officers and directors is accessible at http://phx.corporate-ir.net/phoenix.zhtml?c=71595&p=irol-govboard.

The Board is composed of committees, and will have at all times Audit, Compensation and Corporate Governance Committees. The members of these committees will be “indepen-dent” as that term is defined from time to time by the listing standards of the New York Stock Exchange. The composition of the committees and the charters of the committees themselves can be viewed on the bank’s Corporate Governance website at http://phx.corporate-ir.net/phoenix.zhtml?c=71595&p=irol-govcommcomp. The board may establish additional committees as necessary or appropriate.



4.4

2.9, 2.10

Board of Director ResponsibilitiesThe basic responsibility of the Board of Directors is to oversee the company’s businesses and affairs, exercising reasonable business judgment on behalf of the company. In dis-charging that obligation, the board relies on the honesty, integrity, business acumen and experience of the company’s management, as well as its outside advisors and the com-pany’s independent, registered public accounting firm.

All directors are expected to attend the Annual Meeting of Stockholders, board meet-ings and meetings of the committees on which they serve. Further, they are expected to prepare for each meeting in advance and to dedicate sufficient time at each meeting as necessary to properly discharge their responsibilities to the Company and its sharehold-ers. Informational materials useful in preparing for meetings will be distributed to the board in advance of each meeting.

The non-management directors will meet in executive session at each regularly sched-uled board meeting.

The independent directors will meet in an executive session at least annually if there are non-management directors who are not independent. A Lead Director, who will be an independent director, will be elected by the independent directors annually. The Lead Director will chair the executive sessions of the non-management and independent direc-tors and will approve the agendas for the meetings of the Board of Directors.

More details on corporate governance can be found at http://phx.corporate-ir.net/phoenix.zhtml?c=71595&p=irol-govguidelines.

Employee and Shareholder Feedback to Upper Management on SustainabilityThere are various ways for associates to provide feedback on various sustainability issues. As an example with diversity, the bank has impletemented a Diversity Advisory Council that includes a mechanism for considering input from associates through a for-malized response process. On environmental matters, both internal and external associ-ates may respond through the bank’s email box on environment at www.bankofamerica.com/environment or to the physical address listed above for En-vironmental Initiatives. Shareholders can take advantage of shareholder mechanisms common to publicly held companies to voice their concerns and contribute to the sustain-ability discussion within the bank.

Significant Changes during Reporting YearThrough the acquisition of MBNA, Bank of America expanded its customer base and opportunity to deepen customer relationships across the full breadth of the corporation by delivering innovative deposit, lending and investment products and services to MBNA’s customer base. Additionally, the acquisition allows the corporation to signifi-cantly increase its affinity relationships through MBNA’s credit card operations and sell these credit cards through our delivery channels (including the retail branch network). More details on the MBNA acquisition can be found in Bank of America’s 2006 10-K report (p.117), available at http://investor.bankofamerica.com/phoenix.zhtml?c=71595&p=irol-sec#4420392



Internal Organization Around Sustainability

Each line of business has responsibility and ownership for environmental matters relat-ed to that line of business. The bank has established an enterprise focus on the environ-ment that has support from across various lines of business and units within the bank.

Environmental CouncilThe bank’s Environmental Council was created to assist with the bank’s enterprise com-mitment. The Environmental Council helps ensure development of products, practices and policies aligned with the bank’s environmental commitment. The Environmental Council is comprised of more than 20 associates that include executives and subject area experts that meet throughout the year to collaborate on new issues and to be sure that the bank is on-track for existing commitments. The chair of the Environmental Council reports to the Chief Executive Officer on environmental matters.

There are additional workteams organized around specific environmental issues. These workteams are typically cross-functional and assist to forward components of the bank’s environmental commitment which may extend beyond one divisional area or line of busi-ness. These teams include the Environmental Operations Team, Energy Team and Team Bank of America.

Environmental Operations TeamThis group includes cross-functional representation from Supply Chain Management (strategic sourcing and corporate services), the Electronification of Paper Group, Corpo-rate Workplace (corporate real estate) and Public Policy. The Environmental Operations team achieved its 2006 goals by participating in an in-depth analysis aimed at identifying the bank’s footprint relative to total consumption and disposal of goods and services.

Energy TeamThis team is led by Corporate Workplace and was established to reduce energy consump-tion, promote energy efficiency, implement the bank’s greenhouse gas emissions reduc-tion (for our own operations) and to explore alternative energy potential. Its vision is to establish Bank of America as the most energy efficient financial institution in the world while purchasing energy commodities at the most competitive rates. During 2006, the team was able to reduce energy by 4 percent across all facilities.



Team Bank of AmericaThis is a volunteer network of associates. The environmental projects that are completed through this group are centered around community involvement, volunteerism and promoting environmental issues at home and at work.



EN18

Sustainability – Our Business & Related Policies

Climate ChangeA summary of the bank’s position on global climate change is provided below. More de-tails can be found in the appendix and at http://www.bankofamerica.com/environment/index.cfm?template=env_clichangepos.

Scientists have concluded that human activities, primarily from the burning of fossil fuels, have an effect on earth’s climate due to the resultant “greenhouse effect” from the emissions of carbon dioxide, methane and nitrous oxide. If not checked, climate change and atmospheric pollution could alter the natural, social and economic systems that sup-port a growing global economy and sustain the quality of life for all of us on earth.

Bank of America will: • Assess, set goals and reduce Bank of America’s direct effect on greenhouse gases.

• Assess climate change risk on our business and take action to limit risk and invest in change where appropriate.

• Maximize investment return through energy and resource efficiency.

• Share our position and build partnerships to work on solutions with customers, government and other stakeholders.

• Utilize Bank of America’s position as a community and industry leader to serve as an agent of change.

• Take advantage of market-based environmentally beneficial business opportunities.

• Inform our associates and provide information for how they can take action at work and in their personal lives.

• Report on goals, actions and progress, and continue to monitor the issue and as needed make adjustments to our position and actions.

Bank Operations - Direct and Indirect EmissionsThe company has set aggressive, voluntary goals to reduce greenhouse gas emission across the company nine percent by 2009 through the reduction of its energy consump-tion. The bank is on target to achieve this goal and the related methodologies and prog-ress are outlined in the Energy, Greenhouse Gases and Ozone Depleting Substances Section on pg. 37.



EN6

Lending PortfolioAs a corporation, Bank of America has a responsibility to address climate change and the service sector has a role in promoting and implementing reductions of greenhouse gas emissions that extends beyond its own operations, including relationships with custom-ers and suppliers.

The bank set a target goal to reduce GHG emissions seven percent in its energy and utility customers’ operations. The goal is to achieve this reduction by 2008 from a 2004 benchmark. We are on track for meeting that goal and are doing so in two ways:

• First, we are changing the mix of the portfolio and have added customers using renewable energy sources.

• Second, we have applied business practices to good environmental behavior and are routinely asking our energy and utility partners about their emissions.

The methodology and progress towards our utilities portfolio goal is outlined below:

Utilities Portfolio Emissions Reduction MethodologyCarbon dioxide (CO2) emissions from the U.S. electric power sector represent ap-proximately one-third of all U.S. greenhouse gas emissions and 40 percent of all U.S. energy-related CO2 emissions. Since 1990 these emissions have grown by more than 30 percent. Increases in the efficiency of electric power plants and shifts in fuel used from coal to natural gas or zero-emitting fuels such as nuclear and wind power have the potential to reverse this trend and lower emissions from the utility sector.

In 2004, Bank of America began considering the emissions profile of the utilities to which it extends credit. The bank committed to reducing the emissions rate of the companies in its utility portfolio 7 percent by 2008. To date, Bank of America has made significant progress in lowering the collective emissions rate for companies in its utility portfolio. This progress is attributable to two primary factors: 1) a shift in lending away from some of the highest emitting companies in the portfolio and the addition of lower emitting companies; and 2) a reduction in the emission rate of the other companies remaining in the portfolio.

7% Reduction Target

Emissions Rate of Bank of America Utility Portfolio

Portfolio Year

Tons

CO 2

Per M

Wh

0.733

0.658

2004

0.78

0.74

0.7

0.66

0.62

0.58

2005 2006 2007

0.638 0.634



About the Data Set Bank of America’s methodology for estimating emission rates focuses on the largest electricity genera-tors in its portfolio. These firms are the most likely to report electric generation and CO2 emissions publicly. Use of these data ensure transparency and minimize tracking costs, ensuring consistency in application of methods.

Together, these largest generators represent 75 percent of the total estimated generation from the bank’s utility portfolio. Because the largest generators will be providing base-load (24 hour provision of electricity), they are often coal-fired (a lower cost form of generation). Smaller generators often use higher cost natural gas and renewables such as wind, photovoltaics and biomass. Thus, it is likely that the largest generators have emission rates above those of the smaller generators.

The bank tests this hypothesis by performing spot checks on companies outside the large generator data set and has found their emission rates equal to or lower than the collective emission rate of the largest generators.

MethodologyThe following describes the methodology used by Bank of America to calculate our emissions reduction commitment in the utilities portfolio:

• Bank of America defines the utility portfolio as all electric generators with whom the bank has significant lending/credit relationships.

• Obtain electric generation data (expressed as Megawatt hours (MWh)) for firms representing at least 75 percent of total generation in the portfolio.

• Obtain CO2 emissions data for the same firms that represent 75 percent of total electric generation.

• Add the generation from each of the firms together to estimate total MWh for the portfolio.

• Add the emissions from each of the firms together to estimate total CO2 for the portfolio.

• Divide total CO2 for the portfolio by total MWh to estimate CO2 emitted per MWh generated.

The most recent sources of data are used for the calculations. Data are derived from various sources including U.S. Environmental Protection Agency, Emissions and Resource Generation Integrated Database (eGRID).

http://www.epa.gov/cleanenergy/egrid/index.htm

U.S. Energy Information Administration, Form 906 database http://www.eia.doe.gov cneaf/electricity/page/eia906_920.html

Company annual and environmental reports; Ceres utility industry emissions reporting http://www.ceres.org



Why Target a Decline in Emission Rates?Greenhouse gas emissions performance is typically measured on an ab-solute basis, focusing on the change in aggregate emission levels or on an intensity basis, represented by a rate of emissions per unit of output such as Megawatt hours (MWh).

Emission rates (an intensity measurement) are the most accurate repre-sentation of the emissions performance of a utility portfolio. These rates minimize the impact of circumstances unrelated to a utility’s environmen-tal decisions such as:

Weather Variation – Warmer than normal summers or cooler than normal winters can increase demand for electricity and overall emissions;

Demand Growth – Increases in population and economic activity increase electric demand that must be met by the local utility through generation or power purchases;

Mergers and Divestitures – When a company acquires additional gener-ating capacity, the apparent absolute emissions of the company grow, while the decrease in emissions from the company selling the generating units remains unaccounted for; and

Outages for Maintenance – When a company reduces electric generation to perform maintenance, they still need to meet electric demand, so they purchase electricity from another generator. This lowers their apparent emissions which have been shifted to another company now providing the electricity.

In contrast to absolute emission estimates, emission rates will mute the impacts of these external factors on environmental performance.

Absolute Emissions of Bank of America Utility Portfolio

Portfolio Year

Mill

ion

Tons

CO 2

0.733

690

781

2004

800

760

720

680

640

2005 2006 2007

715

765



4.8Forests

Bank of America promotes sustainable practices for both the bank and its clients by man-aging the environmental, social and reputation impact of our financing activities. Ad-ditional considerations are made for our own purchase of forest products for our opera-tions (discussed further in section on paper use, pg 34). Forests are important resources for communities and globally. Forests provide a wide range of goods and benefits, such as timber, wildlife habitat, food and medicine, water and air quality, and spiritual and aesthetic solace. Forest-dependent communities, including indigenous forest dwellers, rely on the continued vitality of the forests for their livelihoods and, in some cases, their cultural survival. Forests are also an important element of the global carbon cycle. The bank has a detailed set of practices for lending involving forests that attempt to encom-pass these multiple roles of forests. These Forest Practices can be found at http://www.bankofamerica.com/environment/index.cfm?template=env_workrel



4.8

4.8

Environmental Risk ManagementBank of America’s lending is impacted by environmental issues. The Bank’s Environmen-tal Credit Policies for each of its divisions aim to manage the environmental risk associ-ated with bank loans. These policies are summarized below and a longer explanation can be found in the appendix.

Commercial and Small Business Environmental Policy • Appropriate levels of Environmental Due Diligence (EDD) mitigate risks from borrowers becoming subject to liabilities arising from regulatory actions, litigation and property contamination.

• The level of EDD required in a transaction is based on the use of the property (past or present), the loan amount and the presence of existing due diligence.

GCIB Environmental Policies • The bank considers environmental sensitivity an important component of its credit, investment, underwriting and payments decision-making.

Equator PrinciplesBank of America has endorsed the Equator Principles on project finance and continues to support these principles as an industry best standard for project finance. The bank’s business model does not generally reflect the types of transactions subject to the Equa-tor Principles. However, in 2006 there was one transaction that was included within the definition of Equator Principle applicability.

In concert with reporting standards, this transaction is summarized below:

Equator Principles Reporting 2006Number of Projects – 1

Category – A

Sector – Oil and Gas

Project Capital Cost – U.S. $ 2 billion

Exceptions to risk policies – None



4.8Developing Country and Indebted Poor Country (HIPC) LendingIn developing country and HIPC lending, the bank considers not only a client’s capacity and willingness to repay as agreed but also the following factors (a more detailed exposi-tion is found in the appendix.

• The bank favors the stability and prosperity that arise from political and economic democracy and political and economic systems in which participation is widespread, rather than limited to a privileged few.

• Associates are directed to ensure that lending is to enterprises for producing and improving products and offering services that enable communities to prosper.

• Associates are to be alert to and carefully analyze the risks posed in some countries by inefficiency or corruption, or both.

• The bank also considers the impact on the local population –the environment, the structure of culture and society, political systems, public health, economics and standards of living, and the government’s human rights record and policies.

• In the special case of HIPC, the bank considers total external debt, political and economic Reforms, impact on the local population (as above), the sovereignty of the government and sensitivity to outside interference

When forming an opinion on local economies or social conditions, associates routinely gather information from observers on the ground, including local businesspeople, bank-ers and economists, the U.S. Embassy, the host country’s central bank and credible, reliable non-governmental organizations.



LA 13

SO5, SO6

Hiring PoliciesThe following table presents the breakdown of female (includes minority females) and minority associates in various job categories. This table is also available at http://careers.bankofamerica.com/learnmore/workforce.asp.

With respect to disabled individuals, the bank is frequently heralded for its efforts to hire disabled individuals including recognition by the Center for Independence in Albany, NY. Internally, disabled employees and all associates have access to the Disability Affinity Group (DAG), which increased its membership 300 percent in 2006. As detailed in the awards sectionon page 33, the bank is the recipient of numerous awards for the promo-tion of diversity within its workforce.

Public PolicyBank of America maintains a Political Action Committee PAC Program to allow the company and its associates to be fully engaged in the political and legislative process. Although, under federal law, Bank of America is allowed to pay the costs of administering the PAC Program, it is prohibited from directly contributing to the PACs. So, associates support those efforts through their voluntary personal contributions.

The nonpartisan Bank of America PACs allow eligible associates to combine their contri-butions for maximum impact in backing candidates who share the company’s views on key issues. Government Relations professionals and other appropriate Bank of America associates designate to whom political contributions are made.

The bank’s 2006 PAC Campaign supported candidates and legislators engaged on a wide range of critical issues, including OCC preemption, class action reform, anti-money laun-dering and anti-terrorist financing, identity theft, general regulatory relief and pension reform. These issues have a direct impact on our ability to serve our customers, grow our business and generate strong, consistent returns for our shareholders.

2006 Workforce BreakdownJob Category Percent Female Percent Minority

Officials and Managers 50.25 24.26

Professionals 46.83 26.96

Technicians 43.14 40.89

Sales Workers 34.75 23.85

Office and Clerical 77.02 53.68

Operatives 37.52 68.97

Service Workers 9.76 51.22

Total 66.22 44.08



In 2007, the PAC worked closely with state and federal legislators in regard to credit card and mortgage practices, patent reform, retirement savings issues, tax issues, industrial loan companies and a host of other issues that could impact Bank business.

For more information regarding the Bank of America Political Action Committee see the appendix.

Anti-Money Laundering & Anti-Terrorism FinancingThe bank holds itself to a stringent Anti-Money Laundering and Anti-Terrorism Financ-ing Policy Statement, intended to guard against Bank of America’s unintentional involve-ment in criminal activity, and to reinforce Bank of America’s policy of cooperation with law enforcement and regulatory agencies. It can be found at http://www.bankofamerica.com/investor/index.cfm?section=laundering



Ethics - Laws and RegulationsThe actions of all associates are guided by a strong commitment to a Code of Ethics that defines how we work. This commitment is outlined by our CEO in the message below. The detailed Code of Ethics can be found at:

http://investor.bankofamerica.com/phoenix.zhtml?c=71595&p=irol-govconduct

Bank of America Corporation Code of Ethics“The Bank of America Code of Ethics for all of our associates and directors puts into writ-ing the highest standards of ethical conduct to which we hold ourselves, and one another, accountable. This year, we revised the code to make it clearer and easier to understand, while maintaining our commitment to those standards.

For example, we greatly simplified the language and redesigned the format to highlight key information. Our top executives contributed insights at the beginning of each sec-tion, investing their personal leadership in the document. And, we again listed our core values at the front of the code, making it clear that every rule and guideline flows from the principles that define our culture.

Our code provides direction on how we can achieve our business goals while preserving and building on the trust of our customers, shareholders, communities and one another. It is this trust upon which our company is built, and the responsibility for creating and sustaining trust in Bank of America rests squarely on each of us and the personal integ-rity we bring to our work.

The code, in effect, explains what we mean when we say one of our core values is “doing the right thing.” Each of us is required to acknowledge our responsibility for reading, understanding and complying with the guidelines in this document. If you have any ques-tions, talk with your manager.

We all recognize that results are important. Our Code of Ethics underscores our individ-ual and collective recognition that how we achieve those results is just as important. To preserve the trust others place in us—and our trust in each other—I am counting on you to uphold the highest professional and ethical standards in all that you do. In living up to this commitment, I look forward to all we will accomplish together.”

Kenneth D. Lewis

Chairman, Chief Executive Officer and President



4.8

Implementation of Sustainability

The following section presents case studies and specific examples of how Bank of America implements our commitment to Sustainability:

Case StudiesHybrid Vehicle Reimbursement ProgramBank of America initiated a Hybrid Vehicle Reimbursement Program for its associates living within 90 minutes of Boston, Charlotte and Los Angeles. Under this program, the bank reimbursed associates $3,000 towards the cost of hybrid vehicles. Within the three cities where it was piloted, hybrid vehicle purchases by associates have more than quadrupled. The program continues to expand our commitment to the environment and offers our associates a way to participate in making a difference while cutting down on their commuting costs. In 2007, the program will become available to all U.S.–based as-sociates. The company will continue to evaluate the program and assess how it could be rolled out to associates beyond the pilot program and outside of the U.S. A total of 315 associates participated in the pilot program; their average fuel economy increased 91 percent from 23 to 44 miles per gallon, resulting in a reduction of approximately 520 metric tons of CO2.



EN 6Green Communities™Bank of America has provided significant thought leadership on a number of community development issues, including gentrification, Smart Growth and “green” development. The bank is a partner in Green Communities, a five-year initiative to build more than 8,500 environmentally friendly affordable homes across the country. During 2006, the bank financed the “green” construction or rehabilitation of multifamily buildings in Cali-fornia, Maryland, Massachussets and New Jersey to a total of about $97 million. Led by The Enterprise Foundation, The Enterprise Social Investment Corporation and the Natural Resources Defense Council, the Green Communities partners include a blue-chip roster of corporate, financial and philanthropic organizations. All partners are aim-ing for nothing less than a transformation in the way communities think about, design and build affordable houses.

Brownfield LendingThe bank’s Environmental Services Department tracks the number of sites that it as-sists the bank in evaluating and ensuring that business can be conducted while man-aging risk. Bank of America is a leader in supporting the redevelopment of Brownfield properties. Due to the real or perceived additional credit risk posed by the presence of toxic or hazardous materials or wastes on a property that could affect value or the use of the property, safe and sound lending practices encourage lenders to shy away from Brownfield lending. Bank of America’s Environmental Services Department has a eightteen-year history of assessing environmental conditions of real estate, includ-ing Brownfield and evaluating the financial and credit risks of taking such properties as collateral. This experience allows Bank of America to differentiate between real and perceived risks, as well as more definitively quantify and underwrite environmental risks. The net result is that our environmental risk management expertise has been an advantage that has created opportunities by enabling our participation in the financing of redevelopment of, as well as the ongoing business activities at, environmentally impacted properties. In 2006, the Environmental Services Department assisted lending units with evaluation of over 70 such properties representing an aggregate loan amount of over $1.87 billion where significant environmental issues were initially evident but ultimately resolved by ensuring cleanup was or will be completed and property use or reuse enhanced as a result of Bank of America’s participation. Bank of America also par-ticipated directly in the redevelopment of Brownfield properties through the Community

Development Banking equity participation transactions.

U.S. Environmental Protection Agency (EPA) / Small Business Administration (SBA) SmartWay LoansBank of America is one of the lending institutions that provides loans for SmartWay Up-grade Kits to small trucking companies. The loan program is part of the EPA’s SmartWay Transport Partnership

http://www.epa.gov/smartway/financing.htm for more details about the program.



The loans help these companies purchase equipment that helps reduce fuel consump-tion and emissions. The SmartWay Upgrade Kits include idle-reduction devices, low rolling resistance tires, aerodynamic equipment and exhaust after treatment devices. The equipment could boost fuel efficiency by 15 percent and save over $8,000 in fuel costs annually while reducing emissions, according to the EPA. SmartWay Upgrade Kits that include an idling reduction device, exhaust aftertreatment device, tractor and/or trailer aerodynamics and low rolling resistance duals or single wide tires, may improve fuel economy up to 20 percent, reduce oxides of nitrogen (NOx) up to 20%, and reduce particu-late matter (PM) up to 90 percent. Upgrade Kits purchased by trucking companies can be customized to the specific needs of the company.

Bank of America provided quick approval and affordable monthly payments for borrow-ing from $5,000 to $25,000 with no collateral. The SmartWay program serves as an edu-cational outreach to demonstrate that you can save money, fuel and reduce air pollution. The small trucking companies demonstrated this via the incentive program provided by Bank of America in collaboration with EPA and the SBA.

Save A Tree, Conserve a ForestIn March of 2006, Bank of America announced that it would donate $1 per account to The Nature Conservancy’s “Save A Tree, Conserve a Forest” program when customers elect to stop receiving paper versions of checking or savings account statements and decide to view them online instead. A total donation of up to $500,000 was committed and within just five months, the bank reached that goal.

This program provided customers with two ways to help the environment: Customers save paper when they use online statements, and they helped donate $500,000 to pro-mote forest conservation programs with The Nature Conservancy. Since 2004 Bank of America Online Banking customers have saved 5,714 tons of paper by using Online Statements, online bill pay and ebills.

Minority Market PenetrationAn element of the bank’s products and services that merits noting is its commitment to the minority market. For the second consecutive year, Bank of America has earned the Best in Minority Market Penetration Award from the Mortgage Lending Industry Diver-sity Conference, Inc. The award recognizes the financial lender with the greatest propor-tion of minority applications as compared to the national minority population, according to the 2000 census.

Identity CrimeAn aspect of great concern to many consumers is Identity Theft. The Bank has an-nounced a three-year partnership with the International Association of Chiefs of Police (IACP) to help consumers and law enforcement officials understand and respond to identity crime. One important element of this partnership is the website www.IDSafety.org. The bank’s identity theft initiatives have been recognized by Javelin Strategy & Research’s Identity Fraud Safety Scorecard (ranked 1 in 2004, 2005 and 2006).



4.12, 4.13, 4.14, 4.15

StakeholdersThere are several stakeholders that the bank works with on environmental issues. These partnerships are important to us as a financial institution and our use of energy and natural resources as well as other issues including climate change and biodiversity. All initiatives are multi-stakeholder. Our local market presidents and their staff develop many of these relationships and dialogue directly with customers, associates and groups in the local communities that the bank serves. Beyond this network, several within the bank have expanded relationships with investors and non-governmental organizations. There are several formal partnerships that the bank has developed to help maintain strong collaboration with our stakeholders, these are summarized below:

Formal Alliances/Partnerships and Description from Alliance

Date of Adoption

Countries/Operations where applied

Binding/NonBinding

Relevance

United Nations Environment Program Finance Initiative - UNEP FI works closely with over 160 financial institutions who are signatories to the UNEP FI Statements, and a range of partners organizations to develop and promote linkages between the environment, sustainability and financial performance. Through regional activities, a comprehensive work programme, training programmes and research, UNEP FI carries out its mission to identify, promote and realise the adoption of best environmental and sustainability practice at all levels of financial institution operations.

(http://www.unepfi.org/about/index.html).

July, 2001 International binding statement of principles

Has informed sustainability practices in international markets and on finance and environmental related issues

1996 International binding statement of principles

Has informed the banks sustainability reporting practices and environmental best practices

Coalition for Environmentally Responsible Economies - CERES is a national network of investors, environmental organizations and other public interest groups working with companies and investors to address sustainability challenges such as global climate change

(http://www.ceres.org/ceres/).


Date of Adoption


Binding/NonBinding

Relevance

Equator Principles - The Equator Principles Financial Institutions (EPFIs) have consequently adopted these Principles in order to ensure that the projects financed are developed in a manner that is socially responsible and reflect sound environmental management practices. The EPFIs believe that by doing so, negative impacts on project-affected ecosystems and communities should be avoided where possible, and if these impacts are unavoidable, they should be reduced, mitigated and/or compensated for appropriately. The EPFIs believe that adoption of and adherence to these Principles offers significant benefits to ourselves, our borrowers and local stakeholders through our borrowers’ engagement with locally affected communities. The EPFIs therefore recognise that our role as financiers affords us opportunities to promote responsible environmental stewardship and socially responsible development

(http://www.equator-principles.com/principles.shtml).

April, 2004 International binding Has informed the bank’s lending policies


U.S. EPA Climate Leaders - EPA’s Climate Leaders is an industry-government partnership that works with companies to develop long-term comprehensive climate change strategies. Partners set a corporate-wide greenhouse gas (GHG) reduction goal and inventory their emissions to measure progress. By reporting inventory data to EPA, Partners create a lasting record of their accomplishments. Partners also identify themselves as corporate environmental leaders and strategically position themselves as climate change policy continues to unfold

(http://www.epa.gov/stateply/aboutus.html).

May, 2003 U.S. voluntary, non-binding commitment

Bank formalized commitment to reduce GHG emissions from operations

U.S. EPA Energy Star - ENERGY STAR is a joint program of the U.S. Environmental Protection Agency and the U.S. Department of Energy helping us all save money and protect the environment through energy efficient products and practices

(http://www.energystar.gov/index.cfm?c=about.ab_index).

N/A U.S. non-binding Influences choice of products purchased

Metafore Paper Working Group - The Paper Working Group (PWG) is a collaboration between 11 leading companies and Metafore to make environmentally preferable paper products more widely available and affordable

(http://www.metafore.org/index.php?p=Paper_Working_Group&s=263).

July, 2004 U.S. non-binding EPAT tool developed by PWG will enable bank to better evaluate the environmental characteristics of paper it sources.

The Nature Conservancy International Leadership Council - The International Leadership Council (ILC) of The Nature Conservancy–is one of the world's leading corporate forums focusing on the challenges confronting biodiversity preservation, habitat conservation and natural resource management. These issues lie at the heart of a growing number of corporate responsibility programs. The ILC brings together companies from many industries—finance, manufacturing, forestry, consumer products, information technology, etc.—to seek solutions to conservation challenges through cooperative partnerships between the business community and The Nature Conservancy

(http://www.nature.org/joinanddonate/corporatepartnerships/leadership/).

1998 International non-binding Land conservation and related finance


Environmental Bankers Association - Environmental Bankers Association (EBA) is a non-profit trade association that represents the financial services industry, including bank and non-bank financial institutions, insurers, asset management firms and those who provide services to them. Its members include lending institutions, property & casualty and life insurers, the environmental consulting and appraisal community, and attorneys. The EBA was established in 1994 in response to heightened sensitivity to environmental risk issues, and the need for environmental risk management and due diligence policies and procedures in financial institutions (http://www.envirobank.org/about.php).

1994 U.S. non-binding Promoting environmental responsibility and sustainabililty as a core component in managing environmental risk.

Pew Center on Global Climate Change Business Environmental Leadership Council (BELC) - The Pew Center's Business Environmental Leadership Council (BELC) was created at the Center’s inception under the belief that business engagement is critical for developing efficient, effective solutions to the climate problem. BELC also believes that companies taking early action on climate strategies and policy will gain sustained competitive advantage over their peers. The BELC is now the largest U.S.-based association of corporations focused on addressing the challenges of climate change, with 44 members representing $2.8 trillion in market capitalization and over 3.8 million employees. Many different sectors are represented, from high technology to diversified manufacturing; from oil and gas to transportation; from utilities to chemicals (http://www.pewclimate.org/companies_leading_the_way_belc).

October 2006 U.S. non-binding Integration of business principles and developing climate change policy


Date of Adoption


Binding/NonBinding

Relevance



4.16Approaches to Stakeholder EngagementSupplier DiversityThe bank’s approach to stakeholder engagement is exemplified by its efforts to increase supplier diversity. In 1990 Bank of America established the Minority Business Develop-ment (MBD) initiative to include diverse suppliers into the overall corporate purchasing strategy. Supplier diversity spending goals were established at 10 percent and MBD sponsored activities targeted the expansion of opportunities for diverse suppliers. For-mal corporate purchasing policies have been implemented mandating that all contracts with domestic Bank of America suppliers above $500,000 must include supplier diversity & development language and expectations. Contracts less than or equal to $500,000 must include documentation to show diverse supplier participation in the RFP and/or bid process.

This commitment is also realized through the dedication of our team of Supplier Rela-tionship Development Managers (SRDMs) who work with Minority Business Enterprises (MBEs), supporting their development, and positioning them as Bank of America suppli-ers and leaders in their industry. SRDMs also work with suppliers to create and enhance their supplier diversity programs and help them uncover opportunities to work with diverse companies in 2nd tier relationships.

The Bank of America Supplier Development Program incorporates Six Sigma training for diverse suppliers, sponsorship of conferences and networking events and access to capital. Offering continued education through the Dorothy B. Brothers Executive Schol-arship and maintaining our relationships with organizations such as the National Minor-ity Supplier Development Council (NMSDC) has helped us keep supplier diversity at the forefront of our procurement activities.

After surpassing its initial 1990 goal of spending 10 percent of overall sourceable spend with diverse suppliers, Bank of America increased the commitment to 15 percent by 2007.1 Despite vendor consolidations, productivity saving initiatives and contract bun-dling, SRDM development activities led to a supplier diverse spend of $4.4 billion from 2002 to 2006. This total more than triples the total of $1.4 billion achieved from 1990 to 2002. In 2006 alone, Bank of America spent over $1.3 billion dollars, or 14 percent of overall sourceable spend with diverse companies.

For more information on our relationship with suppliers, including the Supplier Relation-ship Development Initiative and the Dorothy B. Brothers Executive Management Schol-arship fund, visit http://www.bankofamerica.com/suppliers.

1 Sourceable is defined as the amount of estimated baseline spend which is actually able to be influenced by strategic sourcing activities. The cost of goods and/or services procured by Bank of America through various channels that are subject to competitive bidding, contract ne gotiation and/or procurement related activities that are provided by Supply Chain Management. Such goods and/or services are routinely consumed as an ongoing part of conducting Bank business and are provided by suppliers in a competitive marketplace.



4.17

2.10

Topics Raised through Stakeholder EngagementBank of America creates and maintains many channels of dialog with its stakeholders, which help to foster communication that allows the bank to learn more about its markets, its clients’ social and economic needs, and ways to have a positive impact in their commu-nities. Many of these same channels allow the bank to become a thought leader in address-ing community needs and in applying its resources – financial and human – to help solve the priority problems faced by the communities it serves.

The bank’s relationships with its stakeholders help the bank identify ways its products and services could help commercial clients create and use new products, services and tech-nologies that would be environmentally friendly and sustainable. Areas of focus include financing for real estate projects with LEED certification, energy efficiency and promotion of smart growth. Among other new projects, the bank will launch the capability to trade car-bon emissions credits to help clients achieve carbon emission neutrality through existing and emerging market mechanisms.

Awards Received in Reporting YearBank of America is often the recipient of awards and other recognitions from organiza-tions and stakeholders which address environmental and social issues about which the company takes an active interest. The company develops and implements strategies to improve our operations and meet our commitments to improving the health of our com-munities and our society. These programs and strategies are often judged exemplary within our industry and among the business community in general, and are recognized for their innovation, success and effectiveness. One such program is the Neighborhood Excellence Initiative, the bank’s signature philanthropic program, which focuses on de-veloping relationships with and investing in strong nonprofits/charitable organizations with great leaders. Details can be found at http://www.bankofamerica.com/foundation/pdf/NEIBuilders.pdf.

In October, 2006, Bank of America was honored for its commitment to designing and constructing environmentally responsible buildings. Global Green USA presented Bank of America its Green Building Design award at its seventh annual “Designing a Sustainable and Secure World” awards ceremony. The award was in recognition of the Bank of America Tower at One Bryant Park, the bank’s future headquarters for New York operations. Currently being constructed in midtown Manhattan, the tower will be one of the most environmentally responsible high-rise office buildings in the world. The project focuses on conserving energy, saving water and recycling materials.

In 2006, DiversityInc Magazine recognized Bank of America as No. 1 in the Top 10 Com-panies for Executive Women and No. 8 for recruitment and retention. The bank was also recognized as the No. 5 company for Hispanics and Gay, Lesbian, Bisexual and Trans-gender employees and No. 8 for Asian Americans. The bank placed No. 6 on the Supplier Diversity list.

In 2006, Black Enterprise Magazine recognized Bank of America as one of the “40 Best Companies for Diversity” and as one of the 10 Best Companies for supplier diversity.



EN1, EN2

Daily OperationsPaper Use Bank of America has implemented a number of programs to reduce paper use. The “Electronification of Paper” (EOP) initiative saved 5,946 tons of forms and copy paper from internal use relative to a baseline year 2000. In addition, the bank further encour-ages our own associates to reduce paper use by opting to receive a variety of regular statements and other material electronically, including their pay, 401(k) and Pension Plan, Health Care and Dependent Care Reimbursement Accounts, and retirement fund information and disclosures. The chart on page 35 shows the percent reduction of paper consumption per associate from a base year of 2000.

As our business continues to grow, the total volume of paper that we send externally to customers continues to grow. Since the year 2000, the bank has acquired institutions with large consumer accounts including both FleetBoston Financial and MBNA. These acquisitions have resulted in increase of total paper volume sent externally.

As we continue to look towards ways that allow us to reduce paper sent externally yet service the needs of customers – we are relying more on electronic means of serving cus-tomer needs. Technology enhancements have allowed the bank to reduce the volume of certain items sent to customers, through the use of electronic bills, payments and state-ments. This technology helped avoid the consumption of 2,699 tons of paper during the year 2006. Going forward, the bank will be augmenting programs focused on converting customers to electronic means of banking which reduce paper consumption. Our 2007 report will include additional discussion on tracking external distribution of paper and actions the bank is taking to reduce that volume of paper.

Latina Style Magazine recognized the bank as one of the top companies for recruiting, retention and advancement opportunities for Latinas.

Women’s Business Enterprise national Council (WBENC) named Bank of America one of America’s Top Corporations for Women’s Business Enterprises. This is the only national award honoring corporations for world class supplier diversity programs.

Working Mother Magazine for 18 years has consistently recognized Bank of America as one of the top companies for working mothers. In 2006, Bank of America was one of the first companies inducted into the magazine’s Hall of Fame.

Human Rights Campaign 2006 Corporate Equality Index gave Bank of America 100 percent for its support of Gay, Lesbian, Bisexual and Transgender associates.

Bank of America has received the 2006 Celebration Independence Employer of the Year/Accessible Business Award from the Center for Independence in Albany, NY. The award recognizes area companies that demonstrate a commitment to hire, train, accommodate, retain and promote employees with disabilities - and provide a greater level of accessibility to their customers with disabilities.



In addition to reducing paper supply, Bank of America has developed a comprehensive paper procurement policy because we recognize that paper is a key material used in providing financial services, that the majority of the paper we purchase is derived from forests, and that maintaining the ecological health of forests aligns with our commitment to environmental stewardship. Forests help regulate climate, support biodiversity and provide other vital services that help sustain the cultures, local communities and econo-mies relying on this resource.

The bank’s paper procurement policy seeks to maintain the ecological health of forests through:

• Source Reduction and Recycling. The bank will build on its long-standing commitment to minimize consumption of paper products containing virgin wood fiber, in order to reduce demand on forests;

• Sustainable Forest Practices. When procuring paper products containing virgin wood fiber, the bank will require its suppliers to ensure that the source forests from which fiber is procured are managed using environmentally preferable practices;

• Protection of Endangered Forests. The bank will require its suppliers of paper products to identify and appropriately manage forests threatened by human or commercial activity.

The complete paper procurement policy is available at this link:

http://www.bankofamerica.com/environment/index.cfm?template=env_paperproc

2001 2002 2003 2004 2005 2006

-50

-45

-40

-35

-30

-25

-20

-15

-10

-5

Bank of America Internal Paper Use Per Associate Relative to Base Year 2000

Year

Percentage Change in Tons of Paper / Associate

Perc

ent c

hang

e in

vol

ume

of p

aper

con

sum

ed p

er a

ssoc

iate



EN1, EN2

EN1, EN2

EN1, EN2

EN1, EN2

Delivery of Office SuppliesBank of America requires its suppliers to supply recycled paper goods, whenever pos-sible and compatible with quality requirements, and to implement and adhere to other environmentally-beneficial policies and practices.

PrintersThe Bank of America Print Smart strategy integrates copier, fax and desktop printers and related consumables. PrintSmart has generated approximately $25 million in cost savings from all related program activities since its inception in 2002 through December 2006. Additionally, significant environmental benefits will be achieved through reduction in toner (savings in paper and energy use are captured in their respective sections).

Suppliers of printers have been chosen for their ability to provide a set of products de-signed to meet the requirements of business units while contributing to reduced energy consumption and gains in mechanical efficiencies with environmental friendly compo-nents ( i.e. Toner, Toner Cartridges, Fusers). Printing itself has been reduced through the transformation of paper-based business processes & information into digital formats, electronic faxing, and reducing paper intensive core processes.

TonerToner use is addressed in several ways. Primarily, the PrintSmart strategy minimizes unnecessary printers with associated reduction in toner use. A second component in reducing toner use is the strategy for using remanufactured toner cartridges. Up to three quarts of oil are consumed in the production of a single new toner cartridge. Bank of America buys remanufactured toner cartridges for its owned equipment—which have been used at least once and then disassembled, cleaned, repaired and refilled—at reduced prices. The remanufactured cartridges offer the same level of performance at significant savings and have far less impact on the environment. Finally, the bank encourages returning toner cartridges via collection bins in copy rooms or near printers and fax machines; or via mail using the prepaid label included in the toner box.

Bank of America leases the majority of its printers, copiers and computers, and, when upgrading, returns equipment to its vendors. Thus, the bank does not directly dispose of such equipment. For the small minority of equipment that has reached the end of its use-ful life, the bank sells them to liquidators. Cell phones are returned to suppliers as part of the contract requirements.

CarpetThe bank purchased 2,637,932 square yards of carpet tile and broadloom in 2006; Ap-proxamately 130,370 square yards of carpet was tile with an overall recycled content of 34 percent, 9.5 percent of which was post-consumer, and the remainder post-industrial. The recycled content of this 130,370 square yards represented 400 tons of material not sourced from or disposed to the environment.

Bank of America recyled 115,501 square yards (or 898,150 lbs.) of carpet that had reached the end of its useful life avoiding 1,020 cubic yards of landfill.



EN7, EN12, EN21

EN3, EN4, EN5, EN6, EN7, EN16, EN17, EN18, EN19, EN20

Non-Tracked ImpactsThe bank uses water in its office buildings for personal use, irrigation of surrounding landscape, and Heating, Ventilation and Air Conditioning (HVAC). While bank activities could potentially affect biodiversity, via third-party projects financed by the bank, the bank does not currently track biodiversity effects of its lending in a systematic manner. However, the bank’s “Environmental Credit Policies,” “Forests Practices” and “Develop-ing Countries Lending Criteria,” all contain significant environmental screens designed to minimize negative environmental consequences of bank activities, and minimize financial risk to the bank itself. These policies are included in the appendix.

Energy, Greenhouse Gases and Ozone– Depleting SubstancesBank of America has voluntarily declared that it will reduce its U.S. greenhouse gas emis-sions by 9 percent from 2004 to 2009 via participation in the U.S. EPA’s Climate Leaders program. In 2006, the bank emitted a total (direct and indirect) of 1,380,000 metric tons of carbon dioxide equivalent (MMTCO2E), 14,790 less than in 2005.2 The vast majority of these emissions (92 percent) are indirect emissions from electricity consumption, which is to be expected for a large services provider, while 8 percent are from direct emissions. The breakdown of these emissions, in native units by primary energy source, is provided in the following table.

Associated with the emissions of greenhouse gases are SOx (6,473 metric tons) and NOx (2,505 metric tons). Improvements in energy conservation and efficiency improvements led to 62,000 MWh or 50,000 MMBtu of decreases in energy use, which translates into cost savings of $8,200,000. Solar energy projects amounted to 60KW. The conservation and efficiency improvements included:

Source QuantityDirect

Fuel Oil and Diesel 602,997 gallons

Natural Gas 1,650,000 MMBtu

Propane 102,069 gallons

Other Fuel 1,289,722 gallons

Indirect

Electricity 2,358,000 MWh

Steam 110,379,000 lbs.

2 Direct emissions refer to emissions from sources owned and operated by the reporting entity. Indirect emis-sions are those that are emitted by consumption of electricity, steam, hot water, and chilled water. The emis-sions occur where the electricity, steam, hot and chilled water, are produced. Other indirect emissions cover a wide variety of emissions up and downstream that are associated with the entity’s economic activity. In the case of a service sector company, other indirects would include product use, employee business travel, and contractor owned vehicles. Within the terminology of the GHG Protocol (WBCSD/WRI), direct emissions are scope 1, indirect emissions are scope 2, and other indirect emissions are scope 3.


GRI G3 Sections/ Indicator • Energy Black Belt

• Vacant Space Green Belt

• 100 Days to Save

• Capital Projects

• Retro-Commissioning

• Computer Sleep Controls

• After Hours Audits

• Energy Answers Email

• Energy Conservation Practices Checklist

• Energy Score Analysis

Other indirect emissions include business travel and emissions from armored car com-panies working for the bank. Scope 3 emissions from business air travel were calculated using the GHG Protocol (WRI/WBSCD) Business Travel spreadsheet.3 Bank of America determined a total of 86,584 metric tons of CO2 for global business travel by air. The bank estimated emissions of 1,895 metric tons of CO2 based upon fuel consumption and the fraction attributable to the bank based upon the armored car firms’ records. Finally, 13,875 metric tons of ozone-depleting substances were emitted .

3 Business travel miles were estimated using total miles traveled per country and the number of segments involved. Calculations were done per country of origin using average miles per segment. Emissions were then determined based upon the average miles per segment differentiating according to whether the average miles per segment represented a short, mid, or long



Appendix

Bank of America Climate Change PositionAt Bank of America, our environmental policies are shaped by our conviction that the health of our company is dependent on the health of communities and our society. Under-standing that every part of our business has a potential impact on our environment, we commit to integrating environmental policy into our company’s operations at every level.

“Bank of America’s goal is to be the leading financial services company in this country, and to be recognized as one of the world’s great companies. We know that these goals come with a responsi-bility to serve as a leader on issues of great importance.”

—Ken Lewis, Chairman and CEO Bank of America

Scientists have concluded that human activities, primarily from the burning of fossil fuels, has an effect on earth’s climate due to the resultant “greenhouse effect” from the emissions of carbon dioxide, methane and nitrous oxide. If not checked, climate change and atmospheric pollution could alter the natural, social and economic systems that sup-port a growing global economy and sustain the quality of life for all of us on earth.

As a corporation, Bank of America has the responsibility to address climate change and the service sector has a role in promoting and implementing reductions of greenhouse gas emissions that extends beyond its own operations, including relationships with cus-tomers and suppliers.

“We, at Bank of America, recognize that climate change and atmospheric pollution represent a risk to the ultimate stability and sustainability of our way of life. Bank of America is committed to addressing climate change issues even more so today, when we believe we can set real and achievable targets for greenhouse gas reductions in both our operations as well as investment opportunities.”

- Anne Finucane, Chief Marketing Officer Bank of America Environmental Council



Bank of America will take the following actions, recognizing that climate change and atmospheric pollution represent a major risk to the ultimate stability and sustainability of our way of life:

• Assess, set goals and reduce Bank of America’s direct effect on greenhouse gases; including benchmarking and reporting on direct emissions of greenhouse gas (GHG) from its operations. Bank of America was the first financial institution to become a partner in the EPA Climate Leaders program and has set a target to reduce our GHG emissions 9 percent by 2009.

• Assess climate change risk on our business and take necessary action to limit risk and invest in change, where appropriate; beginning this process with an assessment and reporting on GHG emissions from the energy and utilities portfolio. The goal is to realize a 7 percent reduction in indirect emissions in accordance with the Intergovernmental Panel on Climate Change targets within our energy and utility portfolio. Also, Bank of America will commission an independent research paper, through one of our environmental alliances, using industry expertise to evaluate the level of financial sector risk through the financing of GHG emission intensive industries. Through this research and independent efforts, the bank will continue to evaluate methods of reducing GHG emissions in Bank of America’s chain of activities, including investment in renewable energy and energy efficiency.

• Maximize investment return through energy and resource efficiency.

• Share our position and build partnerships to work on solutions with customers, government and other stakeholders.

• Utilize Bank of America’s position as a community and industry leader to serve as an agent of change in elevating the public and private sector’s commitment and approach to addressing climate change.

• Take advantage of market-based environmentally beneficial business opportunities.

• Inform our associates and provide information for how they can take action at work and in their personal lives.

Report on goals, actions and progress, and continue to monitor the issues and make adjustments to our position and actions.



Forest PracticesBank of America promotes sustainable practices for both the bank and its clients by man-aging the environmental, social and reputation impact of our financing activities. Forests are important resources for communities and globally. Forests provide a wide range of goods and benefits, such as timber, wildlife habitat, food, medicine, water and air quality, and spiritual and aesthetic solace. Forest-dependent communities, including indigenous forest dwellers, rely on the continued vitality of the forests for their livelihood and, in some cases, their cultural survival. Forests are also an important element of the global carbon cycle. The importance of sustaining the ecological health of forests is a key factor in sustaining the cultures, local communities1 and economies relying on this resource.

Bank of America will apply the following policies to all extensions of credit. In addition, this policy will apply to bond underwriting where proceeds are project specific. The fol-lowing policy applies to new business as of May 15, 2004 and for existing contracts at the time of renewal:

A. Bank of America will use due diligence measures to assure that lending proceeds are not used to finance commercial projects or operations that result in resource extraction2 from, or the clearing of:

I. Primary tropical moist forests;3

II. Additionally, lending proceeds will not go to logging operations in intact forests as defined by World Resource Institute (WRI) mapping as it is developed. Bank of America will assist in funding the development of WRI mapping;

III. Primary forests4 in temperate or boreal forest regions that are not managed using sustainable forestry practices as verified by an independent third party audit; and

IV. High conservation value forests,5 unless under approved conservation plans verified by an independent, third party audit with necessary permits granted by applicable governmental/regulatory authorities.

In all cases, the borrower must remain in compliance with applicable laws and regula-tions governing timber harvesting.

B. Within the next year, the bank will partner with existing environmental alliances to evaluate the value of various forestry certification programs as a means to both reduce risk and further encourage recognized best practices in sustainable forestry.

C. Given the benefits associated with reforestation of cleared and degraded land, Bank of America will finance tree plantations on previously cleared forest land if the clearing and/or degradation of the land was conducted in accordance with applicable laws and regulations. Exceptions are allowed only after five years have passed and only if no direct link to the original deforestation can be demonstrated.

D. Bank of America will not finance companies or projects that collude with, or knowingly purchase timber from, illegal logging 6 operations. Due diligence will include company representation as to its practices and monitoring for illegal logging.

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E. Bank of America respects the rights of indigenous communities whose livelihoods or cultural integrity could be adversely impacted. Due diligence procedures for projects in primary temperate/boreal or high conservation value forests will weigh the impact of credit decisions on the indigenous peoples that could be affected. The bank will not finance the operations unless it is determined that indigenous peoples impacted by proj-ects in these sensitive areas, whether directly or by induced impact, have the opportunity and, if needed, culturally appropriate representation, and have access to the information to engage in informed participation. Additionally, Bank of America will not finance opera-tions in areas where indigenous land claims are not settled.

F. Bank of America will not finance companies that do not have an explicit policy against the uncontrolled and/or illegal use of fire in their forestry or plantation operations. Due diligence will include company representation as to its policy and monitoring.

G. Bank of America will not finance companies or projects that contravene any relevant binding international environmental agreement to which the member country concerned is a party to or that violate local, state or national environmental, labor or social laws.7 Due diligence will include company representation as to its policy and monitoring.

H. False declarations of compliance or failure to adhere to conditions are considered events of default and appropriate actions will be taken.

I. All other environmental issues pertaining to forestry practices will be guided through Bank of America’s other environmental guidelines and policies.

Bank of America will follow corporate-approved due diligence procedures when financing companies involved in the forestry industry. However, we recognize that in some circum-stances, decisions will be taken based on the best information available at the time and based on the good faith that information presented to us was accurate. As such, we will not be held liable if information after the fact demonstrates that a breach of policy occurred. 1. Local communities — describes the broad group of people living in or near a forest or plantation, with some significant level of dependence on it. The term includes forest dwellers, indigenous forest-adjacent populations and recent immigrants.

2. Resource extraction - includes oil and gas exploration, mining and logging, including any activity (such as road building and pipelines) associated with extraction.

3. Tropical moist forests is in areas that receive not less than 100mm of rain in any month for two out of three years and have an annual mean temperatures of 24° C or higher. Also included in this category, however, are some forests (especially in Africa) where dry periods are longer, but high cloud cover causes reduced evapotranspiration.

4. Primary forests are relatively intact natural forest that have been essentially unmodified by commercial scale human activity for the previous 60-80 years.

5. High conservation value forests — are those that possess one or more of the following attributes: Forest areas containing globally, regionally or nationally significant concentrations of biodiversity values (e.g. endemism, endangered species, refugia); and/or large landscape-level forest, contained within, or containing, the management unit, where viable populations of most, if not all, naturally occurring species exist in natural patterns of distribution and abundance.

- Forest areas that are in or contain rare, threatened or endangered ecosystems.

- Forest areas that provide basic services of nature in critical situations (e.g. watershed protection).

- Forest areas fundamental to meeting basic needs of local communities (e.g. subsistence, health) and/or critical to local communities’ traditional cultural identity (areas of cultural, ecological, economic or religious significance identified in cooperation with such local communities).

6. Illegal logging-takes place where timber is harvested in violation of local and national laws intended to stop illegal logging. Illegal logging includes: a) using corrupt means to gain access to forests; b) extraction without permission or from a legally unauthorized area, c) the cutting of protected species or the extraction of timber in excess of legal limits or in violation of legally -approved forest management plans. Illegal logging has not yet been written into international law, although issues relating to illegal logging have been addressed in some fashion by international treaties such as the Convention on Biological Diversity.

7. International agreements - examples include CITES, ILO Conventions and the Convention on Biological Diversity.



Environmental Credit PoliciesCommercial and Small Business Environmental PolicyRisk can be increased by environmental conditions because borrowers can become sub-ject to liabilities arising from regulatory actions, litigation and property contamination. Thus, the bank is concerned with the possibility of a customer experiencing unforeseen financial distress and also with the possibility of being unable to foreclose on collateral that is contaminated. Appropriate levels of Environmental Due Diligence (EDD) mitigate these risks. Appropriate due diligence for an extension of credit must include a review of a client’s environmental policies, procedures and/or practices, an inquiry into the envi-ronmental status of a client’s properties and an assessment of a client’s environmental liabilities.

The level of EDD required in a transaction is based on the use of the property (past or present), the loan amount and the presence of existing due diligence. The due diligence conducted ranges from a simple environmental questionnaire on the lower risk and lower loan amounts to an ASTM Phase I and/or Phase II asbestos survey or lead-based paint survey, depending on the usage and dollar amount of the loan.

Global Corporate Investment Banking Environmental PoliciesBank of America is committed to playing a leadership role in helping to make economic development and environmental protection compatible, and considers environmental sensitivity an important component of its credit, investment, underwriting and payments decision-making. Because GCIB’s business is broader in scope, the environmental credit policies are written to reflect that scope. General guidance and credit considerations are written into policy. In addition, when lending in developing countries, the bank has more specific guidance that includes social considerations as well as environmental considerations.

General GuidanceThe bank will make special efforts to find ways to finance projects and companies that benefit the environment, and refrain from financing projects and companies if their environmental practices fall short of acceptable standards. The bank considers environ-mental practices acceptable if they:

• Meet industry standards, conform to World Bank guidelines and Comply with applicable law.

This consideration is in addition to measures the bank should take to ensure: • A client’s creditworthiness is not impaired by liability for costly environmental cleanups, the bank does not incur liability for environmental matters and doing business with a particular project or client does not negatively impact the bank’s image and global brand.



General Credit ConsiderationsPrudent due diligence, underwriting, documentation and servicing of credit extensions include an inquiry into, an understanding of, and an appropriate response to environ-mental issues which may affect the properties and business operations of a particular client or that otherwise arise in a particular transaction.

Appropriate due diligence for an extension of credit includes a review of a client’s envi-ronmental policies and procedures, an inquiry into the environmental status of a client’s properties and an assessment of a client’s environmental liabilities. The appropriate level of environmental due diligence may be determined in consultation with the bank’s Environmental Services Department and, when appropriate, legal counsel.

Developing Countries Lending CriteriaWhen extending new loans and other credit commitments to and in developing countries, the bank considers not only a client’s capacity and willingness to repay, as agreed, but also:

• Social policy

• The purpose of the transaction

• The impact on the local population

Taking Social Policy into AccountThe bank takes social policy into account when making lending decisions. To do so is responsible behavior, and responsible behavior on the bank’s part, as well as that of its clients, promotes stability and prosperity. Thus, over time, social responsibility and credit considerations tend to converge.

The bank favors the stability and prosperity that arise from political and economic democracy, and political and economic systems, in which participation is widespread, rather than limited to a privileged few. Nonetheless, in a world of diverse circumstances and cultures, many countries follow political and economic models that differ from those to which the United States adheres.

Lending for Productive PurposesWhen lending to clients in developing countries, associates are directed to adhere to the bank’s principle (as set out below) regarding the purpose of the underlying transaction, and be alert to and carefully analyze the risks posed in some countries by inefficiency or corruption, or both.

Principle Regarding Purpose of the TransactionOne of the most important activities the bank undertakes is lending to enterprises for producing and improving products and offering services that enable communities to prosper. To that end, the bank encourages providing credit facilities to creditworthy cli-ents for these productive purposes. Credits are generally discouraged if they do not help the bank’s clients create value but, instead, merely facilitate transferring assets from one entity to another or allow a client to engage in speculation.

The bank recognizes that this is a broad principle rather than a specific rule with clear



boundaries. Moreover, the bank’s willingness to enter into individual transactions varies from time to time depending on the availability of resources and its global strategy. That being said, this broad principle always applies.

Considering the Impact on the Local PopulationWhen deciding whether to make loans or extend credit to clients in developing countries, associates are directed to carefully weigh the impact of the credit decision on the resi-dents of the country. Factors considered include the transaction’s effect on:

• The environmen the structure of culture and society, political systems (with special regard for the development of democracy or other systems which foster civil liberties and widespread participation in the political process);

• Public health;

• Economics and standards of living (including the development of economic democracy); and

• The government’s human rights record and policies.

• These considerations are not just social policy concerns, they are also credit concerns. If a transaction would adversely impact any of the items listed above, that negative impact would be considered a serious negative consideration against approval. Other normal factors are also taken into account, including both credit and policy considerations.

Negotiating with Heavily-Indebted Poor CountriesThe bank recognizes that economic development necessarily entails social as well as monetary costs, and acknowledges that the governments involved are properly the prime decisionmakers in such processes. By its actions, the bank has already joined and intends to continue to join with other lenders, both public and private, to negotiate with heavily indebted poor countries (HIPCs) in an effort to achieve the best possible outcome of economic, political and social stability.

In those negotiations, the following criteria are given significant weight: • Total External Debt. In cases where total external debt is at such a level that debt service cannot be sustained without placing an undue burden on the country’s residents, additional considerations apply. Generally, economic concessions should be agreed to as part of an overall economic program involving all creditors including multilateral agencies (e.g. the IMF, World Bank and regional development banks), individual governments, and private creditors, (such as banks) aimed at making a substantial and positive economic impact. Such concessions are typically arrived at by negotiation, rather than repudiation or imposition of terms by the debtor or unilateral forgiveness by the creditor.

• Political and Economic Reforms. The HIPC should have implemented and evidenced an intention to continue a program of sound political and economic



reforms to ensure that the benefits of any concessions its creditors make will not be lost to local inefficiency or corruption. Such reforms should not unduly burden the country’s poorest segment.

• Impact on the Local Population. Action by an HIPC to make strides in the six areas listed above, under Considering the Impact on the Local Population, weighs as a significant positive factor. Conversely, shortfalls in those areas weigh as a significant negative factor.

• Role of the Government. In making these decisions, associates are directed to also be conscious of the primary role to be played by the recognized governments of the countries concerned, and the legitimate sensitivity of the governments and people of those countries, with interference in their domestic affairs by other countries’ governments and financial institutions. Each case is evaluated individually.

The criteria outlined above are not absolute and inflexible rules; instead, they are an indication of the spirit in which the bank’s management intends these decisions to be made. These decisions must balance a variety of factors to advance the interests of all our constituencies’ shareholders, associates, customers and the communities the bank serves.

Information on which to Base JudgmentsWhen forming an opinion on local economies or social conditions, associates routinely gather information from observers on the ground, including local businesspeople, bank-ers and economists, as well as the U.S. Embassy and the host country’s central bank.

Non-Governmental OrganizationsWhen gathering data to assess the risk inherent in doing business in a particular location, or with a particular client or project, associates are directed to also take into account information developed by reputable non-governmental organizations (NGOs). There are literally thousands of NGOs, many of which are dedicated to observing and reporting on a wide range of issues, such as environmental standards, democratic prac-tices, principles of sustainable development, decent working conditions and the like. The views of credible, reliable NGOs can provide another perspective on the local economy and may be useful when assessing the likelihood of local opposition to a particular un-dertaking. Whether an NGO’s opinion should influence individual credit decisions is a matter of judgment.



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Political Action Committee Report 22006 Bank of America PAC Campaign Annual Report

Why We Contribute: Our Role in Shaping the Competitive Landscape We have a clear opportunity to participate in shaping the political and regulatory environment in which we do business. By contributing to the annual Bank of America PAC Campaign, associates speak up for the interests of our customers and clients, and work together to strengthen the financial services industry.

Thanks to the contributions of our eligible associates, our 2006 PAC Campaign supported candidates and legislators engaged on a wide range of critical issues, including OCC preemption, class action reform, anti-money laundering and anti-terrorist financing, identity theft, general regulatory relief and pension reform (which affects all of us directly). These issues have a direct impact on our ability to serve our customers, grow our business and generate strong, consistent returns for our shareholders.

The issues we face in 2007 are also significant. In addition to our continued attention to the issues above, we are working closely with state and federal legislators in regard to credit card and mortgage practices, patent reform, retirement savings issues, tax issues, industrial loan companies, and a host of other issues that could impact our business.

Included in the following report is a detailed look at the results of our 2006 PAC Campaign efforts. This report illustrates what can be accomplished when associates work together to achieve a shared goal.

I would like to thank everyone who participated in last year’s successful campaign. I hope you will continue to join me in taking the opportunity to participate in the legislative process on behalf of our customers, shareholders and associates.

Best regards,

Kenneth D. LewisChairman and Chief Executive Officer


32006 Bank of America PAC Campaign Annual Report

Mission StatementThe mission of the Bank of America Political Action Committees, or PACs, is to promote good government, and a strong and favorable business environment by supporting candidates at all levels of government who generally support positions favorable to our business models and to our philanthropic endeavors. Achieving a legal and regulatory environment conducive to the growth of our business requires a strong base of support from legislators and other elected officials and is fostered by their understanding of the issues important to us and their awareness of the value and opportunity that Bank of America provides to the communities we serve. The PACs help achieve that objective. The Bank of America PACs are non-partisan.

Legal Structure and EligibilityAs authorized by law, Bank of America maintains a PAC program to enable associates to support the political and legislative processes. In furtherance of that, Bank of America sponsors both a Federal Political Action Committee, which is authorized to contribute to all federal candidates, and a State Political Action Committee, which is authorized to contribute to statewide candidates. Although, under federal law, Bank of America is allowed to pay the costs of administering the PAC program, it is prohibited from directly contributing to the PACs. Bank of America PACs are funded solely by contributions from associates.

The Bank of America PACs allow eligible associates to combine their contributions to support candidates who share the company’s views on key issues. Government Relations professionals and PAC committees, composed of Bank of America associates, designate to whom political contributions are made.

Participation is not available to all Bank of America associates. Federal law limits participation to executive and administrative personnel, to shareholders of the corporation, its parent, subsidiary, branch, division or affiliate and to the families of those associates and shareholders. As a result, we may solicit only the company’s executive and administrative personnel who are paid on a salaried, not hourly, basis. Overseas associates and foreign nationals are also excluded. Associates in broker/dealer subsidiaries may only contribute to PACs that solely contribute to federal campaigns, like the Bank of America Corporation Federal-only PAC.

PAC Compliance and Enhanced Risk ManagementIn keeping with our commitment to the highest ethical and legal standards, we continue to examine the administration and operation of our PAC programs to ensure that we are operating consistently with all applicable laws and

regulations and that we are fulfilling our obligations to associates, shareholders and customers to do so. In furtherance of that, we maintain policies and procedures to tightly regulate the collection and disbursement of PAC funds, and ensure that the funds are expended consistent with our mission, on a non-partisan basis and with integrity.

The Bank of America PAC program is governed by PAC bylaws, policies and procedures, and is monitored through the Government Relations Risk Management program. In 2006, the managing structure of the PAC Boards and Steering Committees was re-organized to strengthen oversight, increase consistency and further reduce compliance risk.

Political Participation Leads to ResultsAssociate contributions make a substantial difference and clearly have an impact. These contributions help the voice of Bank of America to be heard and they help bring and keep legislators in office who support a healthy environment in which our business can prosper.

In 2006, we successfully managed many important issues in the federal and state legislative sessions. A few examples include:

1. Pension Reform – The Pension Protection Act enables Bank of America to continue its pension plan and provide investment advice to plan participants, create tax credits for retirees, protect cash-balance retirement plans, and stabilize 401(k) and IRA contribution limits.

2. Postal Reform – The Postal Reform bill was signed into law on December 20, 2006 and was the first significant overhaul of the postal system since 1970. This bill will limit increases in postal rates over the next ten years. As a result, Bank of America will save millions of dollars in operational expenses.

3. Regulatory Relief – Provides Bank of America with increased flexibility in a number of key areas.

4. State Security Breach Legislation – Ensured legislation included appropriate levels of law enforcement criminal investigations for victims of identity theft.

5. Corporate Taxation – Minimized various state tax legislation proposals that could have adversely impacted the Bank’s operational and retail facilities.

There will be many more issues in the coming months, including increased scrutiny of our credit card practices, legislation that could affect our growing mortgage business, and a number of significant tax issues. To successfully address these issues we need to have a strong base of support from our legislators, fostered by their understanding of the issues and awareness of the value and opportunity that Bank of America provides to the community.


42006 Bank of America PAC Campaign Annual Report

Bank of America PAC PerformanceBank of America’s PAC is successful, both with contributions into the PAC and with contributions to candidates who share common philosophies about our business environment. That happens in large part because of the vital participation of our associates. We believe the trend reflected in the chart below demonstrates the keen understanding our associates have of the importance of participation, and the significant role their contributions—when combined with those of fellow associates—play in our ability to achieve and maintain an environment conducive to growth.

2006 Results and Financial Report The 2006 PAC fundraising accomplishments include over 13,000 associates contributing $1,995,247 in support of our PAC Program. Nationally, PAC participation was slightly over 15% of eligible associates, with 218 new associates generously joining in. The following is a breakdown of 2006 PAC activity.

2006 PAC Revenue Allocation

Total amount allocated for state/local purposes: $1,697,288 (70%)

Total amount allocated for federal purposes: $713,580 (30%)

2006 PAC Disbursement ReportThe following is a breakdown of the $2,060,368 disbursed from the Bank of America State and Federal PAC program and the $350,500 disbursed to federal candidates from the Federal-only PAC. Bank of America’s PACs disbursed a combined total of $2,410,868 in 2006.

2006 State and Federal PAC Disbursement Allocation

46% to candidates at state level ($1,114,319) 2% to candidates at local level ($44,864)

10% to state and local party committees ($253,075)

12% to other state and local political organizations ($285,030)

17% to federal candidates ($405,850)

4% to federal party committees ($93,000)

9% to other federal political organizations ($215,000)

Government Relations Contacts For questions or suggestions, please contact your State Government Relations manager. To obtain a listing, please refer to the Federal and State Government Relations Managers’ rosters at: http://pac.bankofamerica.com/grcontacts.doc.

70%

30%

10%

46%

9%4%

17%

2%

12%

$0

$200,000

$400,000

$600,000

$800,000

$1,000,000

$1,200,000

$1,400,000

$1,600,000

$1,800,000

$2,000,000

2002 2003 2004 2005 2006

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