United States Securities and Exchange Commission
Washington, D.C. 20549
NOTICE OF EXEMPT SOLICITATION
Pursuant to Rule 14a-103
Name of the Registrant: Bank of America Corporation
Name of persons relying on exemption: Inspire Investing, LLC
Address of persons relying on exemption: 3597 E Monarch Sky Ln, Suite 330, Meridian, ID 83646
As over 100 investors and financial professionals, serving thousands of clients and managing/ advising on over $250 billion in assets, we, the Undersigned, urge shareholders to vote YES on Proposal Item No. 5 - Report on Risks of Politicized De-banking sponsored by Leonard E. Crumpler/Bowyer Research.
No American should be denied access to basic financial services because of their religious or political views. Unfortunately, there have been numerous examples recently of organizations or persons being denied deposit accounts or payment processing or having their accounts frozen under circumstances that strongly suggest are discriminatory. Notable examples include Indigenous Advance (an organization that helps orphans and widows in Uganda), Nigel Farage (former leader of Brexit), and National Committee for Religious Freedom (Ambassador Sam Brownback’s religious freedom organization).1 In each of these instances, financial institutions have leveraged vague and subjective policies like “reputational risk” or “hate” speech that are indicative of the larger systemic biases for viewpoint discrimination at these institutions. Recent testimony before Congress in March 2024 has also shown that the federal law enforcement has colluded with virtually all of the country’s largest financial institutions to profile faithful Americans and mainstream conservative and religious organizations as domestic terrorist threats because of their views.2 This activity is an existential threat to free speech and religious liberty.
Beyond the civil liberties concerns mentioned above, there are also serious legal, regulatory, and financial risks to companies involved in de-banking and corporate political activism. The Proposal would assist both the company and shareholders by identifying these sources of risks—risks that have already materialized to the substantial detriment of other companies in recent years. For example, Bowyer Research, on behalf of Alliance Defending Freedom, has explained how de-banking, or even the appearance of it, has attracted substantial regulatory and political backlash, government oversight, and is legally suspect.3 In a recent white paper entitled Corporate Political Activism and Shareholder Value, Bowyer Research also analyzed corporate performance data from a number of different angles (including brand erosion and stock performance, risk, and risk/adjusted return) and reached the conclusion that corporate politicking on divisive social issues “at the very least raises legitimate financial concerns” for investors. 4
1 https://storage.googleapis.com/vds_storage/document/resources/Debanking%20Incidences.pdf
2 https://judiciary.house.gov/sites/evo-subsites/republicans-judiciary.house.gov/files/evo-media-document/Tedesco%20Testimony.pdf
3 https://www.sec.gov/Archives/edgar/data/1390777/000109690624000590/bowy_px14a6g.htm
4 https://bowyerresearch.com/docs/Corporate%20Political%20Activism%20and%20Shareholder%20Value.pdf
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In light of these growing concerns, we are calling on financial organizations, including Bank of America Corporation, to provide greater transparency and disclosure to shareholders. That is why we are urging shareholders to vote YES on Proposal Item No. 5 that asks the company to issue a report on how it oversees risks related to discrimination against individuals based on their race, color, religion (including religious views), sex, national origin, or political views, and whether such discrimination may impact individuals’ exercise of their constitutionally protected civil rights.
Sincerely,
The Undersigned
Robert Netzly CEO Inspire Investing | Michael Skillman CEO Faith Investor Services | Matt Monson Partner Sovereign’s Capital
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William Flaig CEO and Founder American Conservative Values ETF | Sarah Newman Vice President Innovest Portfolio Solutions, LLC | Kevin Freeman CEO and Founder Freeman Global
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Justin Bennett Associate First Trust Advisors | Dan Wallick Managing Partner & CIO Wallick Investments, LLC | Chris Murray President Murray Financial Group
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Art Ally President Timothy Plan | Matt Cunningham Investment Advisor Inspire Advisors | Ronald Thompson Financial Advisor LPL Financial
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Matthew Daugavietas Wealth Advisor Inspire Advisors | David Eck Wealth Advisor Oakstreet Financial | Borja Barragan CEO Altum Faithful Investing
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Michael Graef Financial Planner Christian Wealth Management | Paul McWilliams Founding Advisor Inspire Advisors | Matthew Bonito Financial Adivisor Upward Management Group
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Luke Andrews Financial Advisor Inspire Advisors | Darrell Lyons CEO Pax Financial Group, LLC | John Wildern CEO LIFE Advisor Group
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Eric Boyum Financial Advisor Inspire Advisors | Derek Mauldin Financial Advisor/RIA Kingdom Focused Financial | Derek Hastings CFP Inspire Advisors
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Johnathan Cunningham Financial Advisor Inspire Advisors | David Zumbusch Owner & CFP Inspire Advisors MN | Terrence Rocks Founder/Advisor Teleios Financial Partners
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Matthew Baldini Wealth Advisor Inspire Advisors | Paul Bryer Financial Advisor Inspire Advisors | Aaron Hoffman Financial Advisor Inspire Advisors
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Scott Harlan Financial Planner/Practice Owner Inspire Advisors HH | Jaime Pagotto Compliance Specialist Kingdom Focused Financial | Jay Richardson Investment Advisor Kingdom Wealth Stewards
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Rick Figueroa CEO Patron Partners Wealth Advisors | Jon Nettles CEO Revo Financial | Daniel Catone CEO Arimathea
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William Poland Financial Advisor Carolina Financial Advisors | Matthew Mohlman President Monument Ventures | Kurt Spackman President/CEO Capital Resource Mgmt, Inc.
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Bruce Parmenter Financial Advisor Ameriprise Financial | Carole Murray Treasurer Murray Financial Group, Inc. | Benjamin Wilhelm CEO Lone Oak Financial
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Rachel McDonough Financial Advisor Wealth Squared | Evan Frazier Founder & CEO Tekwise Financial Planners | Jon Halverson Partner Talanton LLC
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William Feus CEO Gray Rock Financial Planning | Steve French Founding Advisor Harvest Money | IYF | Randy Umbaugh Financial Advisor Diligent Wealth Mgmt.
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Ronald Harczak Financial Advisor Steward Guide Wealth Partners | Daniel Bailey Financial Advisor Ambassador Advisors | Gerry Frigon CIO Taylor Frigon Capital
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Craig Mardi Financial Advisor Cetera Advisor Networks | Dennis Williams Financial Advisor WSI Financial Partners, LLC | Thomas Payne Founder Prosperitas Wealth Management
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Ron Zunker Financial Advisor PAX Financial Group | Nolan Dill Financial Advisor CFD Investments | Steve Ellis Financial Advisor Sage Oak Financial
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Daryl Schafer Financial Advisor Culbertson Financial Services | William Holt Financial Advisor UBS | Eric Dorman Financial Advisor Affiliated Financial Planners
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Mark Trice Financial Advisor ClearVista Financial | Michael Smith Founder/CEO Kingdom Focused Financial | Joseph James Vice President Greater Texas Financial Solutions
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William Woodyard Vice President LifeSmart Financial | Brock Baker Financial Advisor Inspire Advisors | Doug Gathright Financial Advisor LifeSmart Financial |
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George Williams Financial Advisor WSI Financial Partners LLC | Jacob Chandler Owner/Financial Advisor Chandler Wealth Mgmt, Inc. | Jevon Webster CFP Inspire Advisors
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Douglas Hanson Financial Advisor Christian Wealth Management | Ryan DeAmicis Wealth Advisor Christian Wealth Management | Jesse Hamilton Financial Advisor ClearVista Financial
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Erik Bloomfeldt Investment Advisor Insight Financial | Heidi Foster Vice President American Wealth Management | Dr. Erik Davidson Asst. Clinical Professor of Finance Baylor University
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John Moore Founder John Moore Associates | Ron Bergenske Financial Advisor LPL Financial | Kenneth Wince Financial Advisor LPL Financial
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Micky Reeves Senior Wealth Advisor EverSource Wealth Advisors | Jerrold Ganz Financial Advisor Jerry Ganz Financial Planning | Charles Immekus Financial Advisor Dedicated Financial Services
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Jeff Hybiak CIO SEM Wealth Management | Beau Zumbusch CEO Inspire Advisors Minnesota | Ed Lytle Financial Advisor ERL Financial Services, LLC
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Shane Enete Associate Professor of Finance Biola University | Laura Simpson Financial Advisor PAX Financial Group | Daniel Hardt Managing Partner Dan Hardt Financial Services
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Jonathan Hunt Financial Advisor Intentional Wealth | Matt Carr Owner/Financial Advisor TruPurpose Advisors | Salvador Rodriguez Financial Advisor Cetera Financial Specialists
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John Ruzza CFP Cambridge | Mark Nicholas Founder/Financial Adviser Transform Retirement | Tony Adkison Financial Advisor Stewardship Advisory Group
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Henry Groves Financial Advisor Stephens, Inc. | Paul Carlson Owner/Wealth Manager 4:8 Financial | Matthew Holt Financial Advisor CWM
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James Jon Benet Financial Advisor Triumphant Portfolio Mgmt, LLC | Larry Moss Certified Financial Planner Northwest Investments | J. Michael Salley President/CEO Salley Wealth Advisors Group
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Brent Jackson President Harvest Financial | Jerry Bowyer President Bowyer Research | Mike Ching Founder/President Nardene Wealth Management
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Andrew Lehman Financial Advisor Inspire Advisors | Joseph Verissimo Owner/Financial Advisor Christian Wealth Management | Andrew Hreha Institutional Fixed Income Stephens, Inc.
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Joseph Allen Financial Advisor/RIA Inspire Advisors | Gerard Farkas Owner Gerard Farkas & Associates | Ryan Munoz Wealth Advisor Inspire Advisors
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Luke Zumbusch Financial Planner Inspire Advisors MN | Thomas Strobhar President Strobhar Financial | Stephen Werner Financial Advisor/RIA Covenant Financial Group
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Robert Franer III Owner/Wealth Advisor Castellum Financial Advice | James Kreid President Rock Solid Retirement Strategies | Mark Reynolds Wealth Advisor Terrier Financial Group
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| Scott Shepard Director, Free Enterprise Project National Center for Public Policy Research |
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