BANK OF AMERICA

Investor Relations

PAC & Related Activities

This statement sets forth basic principles concerning the company's stance on political contributions and activities. Together with our other policies and procedures, included in our Code of Conduct and Political Action Committee (PAC) governance documents, it guides our company’s and associates’ approach to political involvement. By following this statement and our other policies and procedures, by adhering to applicable laws and regulations, and by applying sound judgment to political activities, we can further demonstrate our commitment to becoming the world's most admired company.

Bank of America Corporate Political Contributions Policy Statement

As a global financial services company, Bank of America must be and is committed to participation in the political process in a manner that is consistent with solid corporate governance practices and in compliance with legal requirements. It is in this spirit that we encourage our associates to be active in our democratic society and provide them opportunities to do so through the Bank of America Political Action Committee program and other volunteer activities.

Bank of America Political Action Committee Program

Bank of America maintains a political action committee (PAC) program. As permitted by federal law, Bank of America underwrites the costs of administering the PAC program, but is prohibited from directly contributing to the PACs. The PAC program is funded through associates’ voluntary personal contributions. These contributions are reported to relevant federal, state and local campaign finance agencies as required by law.

To fulfill their mandate for leadership, integrity and effectiveness, Bank of America’s PAC program administrators adhere to established governance and compliance procedures that ensure consistent funding decisions and compliance with all campaign finance and regulations applicable to the financial services industry, including Municipal Securities Rulemaking Board Rules.

Corporate Political Contributions

Bank of America and its affiliates do not make corporate contributions to candidates for public office. In appropriate circumstances, however, Bank of America may make contributions to state or local ballot measures, non-candidate organizations such as political convention host committees or organizations organized under Section 527 of the Internal Revenue Code, and presidential inaugural committees to the extent permitted by applicable law.

Bank of America forbids the use of its facilities, equipment, or other assets for political purposes without consent and to the extent prohibited by applicable law.

Associate Political Contributions and Activities

Just as political issues are important to the Company, we recognize their importance to our individual associates. Therefore, the Code of Conduct outlines company policies with regard to associate political involvement.

Bank of America encourages informed participation in governmental, regulatory and elective processes. Bank of America respects the rights of its associates to support issues and candidates of their choosing, and associates may elect to make personal political contributions, either directly or through company-sponsored or other political committees as permitted by applicable local, state and federal laws, as well as the laws of any applicable jurisdiction outside of the United States. Of course, associate contributions are not reimbursable by Bank of America.

Additionally, Bank of America associates are encouraged to participate in political activities on their own time and in accordance with their individual desires and political preferences. When engaging in political activities, apart from official responsibilities associates are expected to make it clear that they are acting as an individual and not as a representative of the Company.

Associates who wish to accept an appointment to public office or file as a candidate for election need to first obtain the approval consistent with corporate policy to avoid any conflict of interest.

2012 Political Contributions

As a global financial services company, Bank of America is committed to participation in the political process in a manner that is consistent with solid corporate governance practices and in compliance with legal requirements. Bank of America maintains a political action committee (PAC) program to allow the Company’s associates to be engaged in the political process. Our 2012 PAC contributions are reported to, and available at the following federal and state government agency websites:

Bank of America PACWebsite
Bank of America Corporation Federal PACBank of America Corporation Federal PAC
Bank of America Corporation State PACs Bank of America State PAC Websites

Bank of America and its affiliates do not make corporate contributions to candidates for public office. In appropriate circumstances, however, Bank of America may make contributions to organizations structured under Section 527 of the Internal Revenue Code. In 2012 Bank of America did not make any contributions to 527 organizations.

Additional Information

For additional information concerning Bank of America’s political activities and related policies and procedures, contact Bank of America’s Public Policy Department at 617-434-9578.