BANK OF AMERICA

Investor Relations

Political Activities

Bank of America Corporate Political Contributions Policy Statement

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.

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 employees to be active in our democratic society and provide them opportunities to do so through the PAC program and other voluntary activities.

Bank of America Political Action Committee Program

Bank of America maintains a PAC program to allow the Company’s employees to be engaged in the political process. Where permitted by applicable 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 only through employees’ voluntary personal contributions. These contributions are reported to relevant federal, state, and local campaign finance agencies as required by law, and are available here:

Bank of America Corporation Federal PAC
Bank of America Federal & State PAC
CLICK HERE FOR PDF OF CONTRIBUTIONS
Bank of America Corporation State PACs Bank of America Rhode Island PAC
Bank of America New York PAC
Bank of America Florida PAC
Bank of America Maryland PAC
Bank of America Massachusetts PAC

If you have a problem clicking on the above links, copy and paste the link into your web browser.

Archive of Political Expenditure Report


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.

Contributions from the PAC program support candidates, parties, or committees whose views on specific issues are consistent with Bank of America’s interests. Consideration is given to candidates who represent the communities we serve and who show support for policies and initiatives that are important to the Company. PAC program contributions are made without regard to the private political preferences of the Company’s Executive Management Team or any other Company executive.

Trade Association Memberships

Bank of America often shares interests with groups that advocate and shape public policy positions on issues that are important to the financial services industry and the global business community. We believe that we are better when we are connected to others as we work to bring about consensus and advocate for issues of importance to us and the communities we serve. Some of the organizations in which Bank of America is an active member and which received more than $25,000 in dues in 2013 are listed below.

NATIONAL, REGIONAL, AND GLOBAL ORGANIZATIONS:

  • The Aldersgate Group
  • American Bankers Association
  • American Chamber of Commerce to the EU
  • Asia Securities Industry and Financial Markets Association
  • Association for Financial Markets in Europe
  • British Bankers’ Association
  • Business for Social Responsibility
  • Business Roundtable
  • Center for Climate and Energy Solutions (C2ES) Business
  • Environmental Leadership Council
  • Center for Strategic and International Studies
  • Centre for European Policy Studies
  • The Clearing House Association
  • Climate Markets & Investment Association
  • Consumer Bankers Association
  • Council on Foreign Relations
  • Electronic Payments Coalition
  • Eurofi — Financial Services in Europe
  • The European Institute
  • Finance and Leasing Association
  • Financial Services Forum
  • Financial Services Roundtable
  • Futures and Options Association
  • Futures Industry Association
  • Global Coalition on Aging
  • Global Financial Markets Association
  • International Capital Market Association
  • International Swaps and Derivatives Association
  • Investment Company Institute
  • Mortgage Bankers’ Association
  • National Business Coalition on E-Commerce & Privacy
  • The Risk Management Association
  • Securities Industry and Financial Markets Association
  • State bankers’ associations
  • UK’s Association of Foreign Banks
  • UK Cards Association
  • U.S. Chamber of Commerce
  • U.S. Partnership for Renewable Energy Finance

When Bank of America makes payments to these organizations, including membership fees and dues, we restrict the organization from using the funds for any election-related activity at the federal, state, or local level, including contributions and expenditures (including independent expenditures) in support of, or opposition to, any candidate for any office, ballot initiative campaign, political party committee, or PAC.

Corporate Political Contributions

Bank of America and its affiliates do not make corporate contributions to candidates for public office, political parties, or PACs. In appropriate circumstances, however, Bank of America may make contributions to non-candidate organizations such as political convention host committee, organizations organized under Section 527 of the Internal Revenue Code, or presidential inaugural committees, to the extent permitted by applicable law. In 2013, Bank of America made contributions to the following 527 organizations:

  • Democratic Governors Association
  • Republican Governors Association
  • Republican Attorneys General Association/Republican State Leadership Committee
  • Democratic Attorneys General Association
  • Democratic Legislative Campaign Committee
  • Republican Legislative Campaign Committee/Republican State Leadership Committee

Bank of America does not use corporate funds to make independent political expenditures but may, from time to time, use corporate or PAC funds to support or oppose state or local ballot initiatives that affect the business environment. These contributions are reported in accordance with any applicable laws or regulations. Bank of America may occasionally support groups organized under Section 501(c)(4) of the Internal Revenue Code on public policy matters, but does not support the election of any specific candidate or for the purpose of funding specific expenditures or communications.

When Bank of America makes any of these contributions, it does so to promote the interests of the company and without regard to the private political preferences of its executives. Consideration is given to entities that support policies and initiatives that are important to the Company. 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.

Employee Political Contributions and Activities

Bank of America encourages informed participation in governmental, regulatory, and elective processes. Bank of America respects the rights of its employees to support issues and candidates of their choosing, and employees 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. Employee contributions are not reimbursed by Bank of America.

Additionally, Bank of America employees 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 Bank of America responsibilities, employees are expected to make it clear that they are acting as an individual and not as a representative of the Company.

Employees who wish to accept an appointment to public office or file as a candidate for election must first obtain approval consistent with Bank of America policy to avoid any conflict of interest.

Compliance and Monitoring

The Bank of America Code of Conduct guides us in all that we do. The Code, which is grounded in our company’s values, provides basic guidelines of business practice, as well as professional and personal conduct, that all employees are expected to adopt and uphold.

The Code influences how we do business as we continue to build a stronger, more streamlined and customer-focused company. The Code covers a range of issues from anti-bribery and anti-corruption to our risk framework and workplace safety. Our Code specifically covers how our employees may engage in the political process and how we interact with representatives of all levels of government on behalf of Bank of America.

All political activities carried out on behalf of Bank of America are managed by the Public Policy Department leadership, who report to the Corporate Communications and Public Policy Executive.  The Corporate Communications and Public Policy Executive is responsible for the department’s policies, activities and legal compliance with the advice of the Compliance Department and legal counsel.  The Public Policy Executive reports not less than annually to the Corporate Governance Committee, which is comprised solely of independent members of our Board of Directors, on significant policies and practices concerning political contributions, major lobbying priorities and principal trade association activities that relate to the Company’s public policy objectives.

In general, Bank of America employees may make personal contributions, within applicable legal limits, to political candidates, political parties, political action committees, and other entities that make political expenditures. Financial industry regulations and state or local laws prohibit employees of particular lines of business or employees with certain coverage responsibilities from making certain political contributions or engaging in certain political activities. Bank of America has identified the employees who are covered by such restrictions and requires that those employees pre-clear any contributions with designated Compliance personnel.

Bank of America maintains a robust government relations and political activity compliance program.  We are committed to complying with internal policies, all relevant state, federal, and international laws and regulations including SEC Rule 206(4)-5, MSRB Rule G-37, CFTC Rule 23.451, and applicable state and local restrictions on corporate political activity.  All contributions made and disclosed by Bank of America are in compliance with Bank of America’s internal policies. 

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.