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BACBank of America

Financials · Banks · NYSE, OTC
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The 10-K against last year's

468 changes: 42 added, 41 removed, 383 reworded, 2 quiet changes

10-K Feb 25, 2026 vs Feb 25, 2025
Risk FactorsRedline ↓
20.1%
of the text changed · 16,535 words now
15.6%
of the text changed · 38,305 words now
Legal ProceedingsRedline ↓
23.5%
of the text changed · 3,384 words now
Accounting PoliciesRedline ↓
13.4%
of the text changed · 8,875 words now

10-K 0000070858-26-000157 (2026-02-25) vs 10-K 0000070858-25-000139 (2025-02-25)

The redline

The paragraph that changed most in each section

Marked against last year's 10-K: cut words struck through, new words highlighted and underlined.

Accounting Policies 237 words changed in this paragraph; it is 32% similar to last year's version.
Debt securities are reported on the Consolidated Balance Sheet at their trade date. Their classification is dependent on the purpose for which the securities were acquired. Debt securities purchased for use in the Corporation’s trading activities are reported in trading account assets at fair value with unrealized gains and losses included in market making and similar activities. Substantially all other debt securities purchased are used in the Corporation’s asset and liability management (ALM) activities and are reported on the Consolidated Balance Sheet as either debt securities carried at fair value or as held-to-maturity Held-to-maturity (HTM) debt securities. Debt securities carried at fair value are either available-for-sale (AFS) securities with unrealized gains and losses net-of-tax included in accumulated OCI or carried at fair value with unrealized gains and losses reported in market making and similar activities. HTM debt securities are debt securities that management has the intent and ability to hold to maturity and are recognized at their trade date and reported at amortized cost. If Interest is recognized in the same manner as debt securities carried at fair value. For certain U.S. Agency mortgage-backed-securities, if more than 85 percent of the principal has been collected on level-payment mortgage-backed HTM debt securities since their acquisition, the HTM debt securities, if disposed, are treated as matured for classification purposes. The Corporation separately evaluates its HTM debt securities for any credit losses, of which substantially all qualify for the zero-loss credit assumption. For the remaining securities, the Corporation performs a discounted cash flow analysis to estimate any credit losses, which are then recognized as either credit loss expense or a reversal of credit loss expense in other income for the amount necessary to adjust the debt securities valuation allowance to its current estimate of expected credit losses.

Source: Item 8, Note 1 – Summary of Significant Accounting Principles, 10-K 0000070858-26-000157 vs Item 8, Note 1 – Summary of Significant Accounting Principles, 10-K 0000070858-25-000139

MD&A 185 words changed in this paragraph; it is 73% similar to last year's version.
You should not place undue reliance on any forward-looking statement and should consider the following uncertainties and risks, as well as the risks and uncertainties more fully discussed under Item 1A. Risk Factors of this Annual Report on Form 10-K: and in any of the Corporation’s subsequent U.S. Securities and Exchange Commission (SEC) filings: the Corporation’s potential judgments, orders, settlements, penalties, fines and reputational damage, which are inherently difficult to predict, resulting from pending, threatened or future litigation and regulatory inquiries, demands, requests, investigations, proceedings and enforcement actions, which the Corporation is subject to in the ordinary course of business, including matters related to our processing of unemployment benefits for California and certain other states, the features of our automatic credit card payment service, the adequacy of the Corporation’s anti-money laundering and economic sanctions programs and the processing of electronic payments, including through the Zelle network, and related fraud, which are in various stages; in connection with ongoing litigation, the impact of certain changes to Visa’s and Mastercard’s respective card payment network rules and reductions in interchange fees for U.S.-based merchants; the possibility that the Corporation’s future liabilities may be in excess of its recorded liability and estimated range of possible loss for litigation, and regulatory and government actions; the Corporation’s ability to resolve representations impact of U.S. and warranties repurchase global interest rates (including the potential for ongoing fluctuations in interest rates), inflation, currency exchange rates, economic conditions, trade policies and related claims; tensions, including changes in, or the risks related to the discontinuation of reference rates, including increased expenses and litigation imposition of, tariffs and/or trade barriers and the effectiveness of hedging strategies; economic impacts, volatility and uncertainty resulting therefrom, which may have varying effects across industries and geographies, and geopolitical instability; uncertainties about the financial stability and growth rates of non-U.S. jurisdictions, the risk that those jurisdictions may face difficulties servicing their sovereign debt, and related stresses on financial markets, currencies and trade, and the Corporation’s exposures to such risks, including direct, indirect and operational; the impact of U.S. and global interest rates (including the potential for ongoing adjustments in interest rates), inflation, currency exchange rates, economic conditions, trade policies and tensions, including increased tariffs, and geopolitical instability; the impact of the interest rate, inflationary, macroeconomic, banking and regulatory environment on the Corporation’s assets, business, financial condition and results of operations; the impact of adverse developments affecting the U.S. or global banking industry, including bank failures and liquidity concerns, resulting in worsening economic and market volatility, and regulatory responses thereto; the possibility that future credit losses may be higher than currently expected due to changes in economic

Source: Item 7, 10-K 0000070858-26-000157 vs Item 7, 10-K 0000070858-25-000139

Risk Factors 155 words changed in this paragraph; it is 59% similar to last year's version.
We and our regulators have an increased focus on privacy, information security. security and emerging technologies, such as AI. This includes cybersecurity incidents perpetrated against us, our clients, providers of products and services, counterparties and other third parties, the collection, use and sharing of data, and safeguarding of personally identifiable information and corporate data, as well as the development, implementation, use and management of emerging technologies, including AI, which have resulted in, and will likely continue to result in, related litigation (including class actions) or government enforcement, including with regard to compliance with U.S. and global LRRs, and could subject us to fines, judgments and/or settlements and involve reputational losses. We expect The interconnectedness and complexity of AI models may complicate oversight and compliance, and reliance on third‑party AI models further increases our risks due to also face limited visibility into their training data, methodologies and safeguards. Inaccurate AI outputs, unintended or unauthorized exposure of confidential information, biases and possible infringement of intellectual property rights through the use of AI increase this risk. Also, increasing scrutiny regarding sustainability-related policies, goals, targets and disclosure, which disclosure could result in litigation, regulatory investigations and actions and reputational harm. Misconduct, or the perception of misconduct, by our employees and representatives, including conflicts of interest, unethical, fraudulent, improper or illegal conduct, the failure to fulfill fiduciary obligations, unfair, deceptive, abusive or discriminatory business practices, or violations of policies, procedures or LRRs, including conduct that affects compliance with books and records requirements, have resulted and could result in further litigation and/or government investigations and enforcement actions, and cause significant reputational harm. actions.

Source: Item 1A, 10-K 0000070858-26-000157 vs Item 1A, 10-K 0000070858-25-000139

Legal Proceedings 124 words changed in this paragraph; it is 61% similar to last year's version.
In 2023, the Federal Deposit Insurance Corporation (FDIC) issued a final rule to impose a special assessment to recover certain estimated losses to the Deposit Insurance Fund (DIF) arising from the closures of Silicon Valley Bank and Signature Bank. The estimated losses will be recovered through quarterly special assessments collected from certain insured depository institutions, including the Corporation, and collection began during the three months ended June 30, 2024. As of At December 31, 2024 2025 and 2023, 2024, the Corporation’s accrual for its estimated share of the FDIC special assessment was $244 million and $1.7 billion and $2.1 billion. The Corporation continues decrease in the Corporation’s accrual as of December 31, 2025 reflects quarterly assessments paid during 2025, as well as a $323 million reduction in the Corporation’s estimated share of the FDIC special assessment during the second half of 2025. The final quarterly special assessment payment is scheduled for the first quarter of 2026. The FDIC retains the authority to monitor the FDIC’s estimated loss impose a one‑time supplemental assessment should actual losses to the DIF, DIF exceed the total amount collected, or provide an offset against regular deposit insurance assessments if collections exceed actual losses to the DIF. The Corporation would recognize any such adjustment in the period in which could affect the amount of its accrued liability. underlying determination is made.

Source: Item 3, via Note 12 – Commitments and Contingencies, 10-K 0000070858-26-000157 vs Item 3, via Note 12 – Commitments and Contingencies, 10-K 0000070858-25-000139

Every change, by type

Sentences and paragraphs added, removed or reworded

Sentences and paragraphs of BAC's Risk Factors and MD&A, 10-K 2026-02-25 against 10-K 2025-02-25. Each links to the text at sec.gov.

AddedRisk Factors
and reliance on, third parties and the financial services industry, including the processing and reporting of a large number of complex transactions at increasing speeds in many currencies and jurisdictions, creates additional operational risk.

Read it in 10-K 2026-02-25 at sec.gov ↗

AddedRisk Factors
We use, and expect to increasingly use, emerging technologies, including AI, across our operations, including business processes, services and products, and we expect greater AI adoption by our third parties, clients, counterparties, clearinghouses and financial intermediaries. Expanded use of AI, including emerging third‑party AI services and autonomous AI agents, may result in increased data risk, unpredictable system interactions, inadequate controls or safeguards, AI failure, or produce unintended operations or consequences. AI services used by our clients or third parties may interact with our systems or communicate directly with our employees, and may act without authorization, make execution errors, behave unpredictably or be misaligned with intended outcomes, which could result in additional operational, legal and regulatory risk, and reputational harm.

Read it in 10-K 2026-02-25 at sec.gov ↗

AddedRisk Factors
Emerging technologies, such as AI and quantum computing, are expected to increase these risks. For example, AI lowers the entry barriers to plan and execute cyberattacks, enables more personalized and harder to detect social engineering, and improves vulnerability discovery, which may result in the increased likelihood of exploitation and the speed, scope, scale, and sophistication of cyberattacks. Advances in quantum computing may introduce cryptography risks that threaten the

Read it in 10-K 2026-02-25 at sec.gov ↗

AddedRisk Factors
security of our information and systems and strengthen threat actor capabilities in ways that are difficult to anticipate. These technologies, alone or in combination with others, may amplify the risks they pose.

Read it in 10-K 2026-02-25 at sec.gov ↗

AddedRisk Factors
established by our regulators and other government authorities, could result in further settlements, orders or agreements and additional fines, penalties or judgments, or material regulatory restrictions on our businesses.

Read it in 10-K 2026-02-25 at sec.gov ↗

Show the other 16
AddedRisk Factors
Also, U.S. banking regulators are expected to release proposals in 2026 to revise methodologies for measuring and reporting risk-based capital adequacy, including the calculation of RWA and G-SIB surcharge. The timing and composition of such proposals are uncertain. Final rules issued following those proposals could adversely impact our capital requirements.

Read it in 10-K 2026-02-25 at sec.gov ↗

AddedRisk Factors
Our models may not be sufficiently predictive of future results, including from limited historical patterns, extreme or unanticipated market movements or clients’ behavior and

Read it in 10-K 2026-02-25 at sec.gov ↗

AddedMD&A
Effective in the fourth quarter of 2025, the Corporation elected to change accounting methods for its tax-related affordable housing, eligible wind renewable energy and solar renewable energy equity investments, which were applied on a retrospective basis. The Corporation determined that the new accounting methods are preferable, as they better align the financial statement presentation with the economic impact of these equity investments. The primary impact of the accounting changes is a reclassification between income statement line items that nets income tax credits and benefits against the investment expense. Certain prior-period information presented herein has been revised to reflect the accounting method changes. For more information, see Note 1 – Summary of Significant Accounting Principles to the Consolidated Financial Statements and Exhibit 18 to this Annual Report on Form 10-K.

Read it in 10-K 2026-02-25 at sec.gov ↗

AddedMD&A
The following table provides key performance indicators for deposit spreads, other period-end information, credit and debit card and loan production activities.

Read it in 10-K 2026-02-25 at sec.gov ↗

AddedMD&A
Effective in the fourth quarter of 2025, the Corporation elected to change its accounting methods related to certain tax-related equity investments and applied those changes retrospectively through a cumulative adjustment to retained earnings. For more information, see Note 1 – Summary of Significant Accounting Principles to the Consolidated Financial Statements. Under applicable bank regulatory rules, the Corporation is not required to, and accordingly, did not revise regulatory capital information as of December 31, 2024.

Read it in 10-K 2026-02-25 at sec.gov ↗

AddedMD&A
(2)Effective in the fourth quarter of 2025, the Corporation elected to change its accounting methods for certain tax-related equity investments and applied those changes retrospectively through cumulative adjustment to retained earnings. Under applicable bank regulatory rules, the Corporation is not required to revise previously-filed regulatory capital ratios and, accordingly, did not revise regulatory capital information as of December 31, 2024.

Read it in 10-K 2026-02-25 at sec.gov ↗

AddedMD&A
(1)Represents the decrease in retained earnings due to the Corporation’s election to change its accounting methods for certain tax-related equity investments in the fourth quarter of 2025. Under applicable bank regulatory rules, the Corporation is not required to revise previously-filed regulatory capital ratios and, accordingly, did not revise regulatory capital information as of December 31, 2024.

Read it in 10-K 2026-02-25 at sec.gov ↗

AddedMD&A
(1)Effective October 1, 2025, the Corporation elected to change its accounting methods for certain tax-related equity investments and applied those changes retrospectively. Under applicable bank regulatory rules, the Corporation is not required to revise previously-filed regulatory capital ratios and, accordingly, did not revise regulatory capital information as of December 31, 2024.

Read it in 10-K 2026-02-25 at sec.gov ↗

AddedMD&A
(2)Effective in the fourth quarter of 2025, the Corporation elected to change its accounting methods for certain tax-related equity investments and applied those changes retrospectively through cumulative adjustment to retained earnings. Under applicable bank regulatory rules, the Corporation is not required to revise previously-filed regulatory capital ratios and, accordingly, did not revise regulatory capital information as of December 31, 2024.

Read it in 10-K 2026-02-25 at sec.gov ↗

AddedMD&A
On November 25, 2025, the Federal Reserve, Office of the Comptroller of the Currency and FDIC issued a final rule that modified enhanced SLR requirements for bank holding companies and their insured depository institution subsidiaries, with corresponding revisions to TLAC and long-term debt requirements. Under the final rule, static buffer requirements have been replaced with a dynamic buffer requirement equal to 50 percent of the G-SIB’s Method 1 surcharge, with the buffer capped at one percent for insured depository institutions. The Corporation elected to early adopt the final rule as of January 1, 2026, which decreased the regulatory minimum SLR requirement to 3.75 percent from 5.0 percent for the Corporation, and to 3.75 percent from 6.0 percent for BANA as of the same date. For more information on the Corporation’s Method 1 and Method 2 G-SIB surcharge, see Minimum Capital Requirements in this section.

Read it in 10-K 2026-02-25 at sec.gov ↗

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