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

 

William Flaig

CEO and Founder

American Conservative Values ETF

Sarah Newman

Vice President

Innovest Portfolio Solutions, LLC

Kevin Freeman

CEO and Founder

Freeman Global

 

Justin Bennett

Associate

First Trust Advisors

Dan Wallick

Managing Partner & CIO

Wallick Investments, LLC

Chris Murray

President

Murray Financial Group

 

Art Ally

‍‍‍President

Timothy Plan

Matt Cunningham

Investment Advisor

Inspire Advisors

Ronald Thompson

Financial Advisor

LPL Financial

 

Matthew Daugavietas

Wealth Advisor

Inspire Advisors

David Eck

Wealth Advisor

Oakstreet Financial

Borja Barragan

CEO

Altum Faithful Investing

 

Michael Graef

Financial Planner

Christian Wealth Management

Paul McWilliams

Founding Advisor

Inspire Advisors

Matthew Bonito

Financial Adivisor

Upward Management Group

 

Luke Andrews

Financial Advisor

Inspire Advisors

Darrell Lyons

CEO

Pax Financial Group, LLC

John Wildern

CEO

LIFE Advisor Group

 

Eric Boyum

Financial Advisor

Inspire Advisors

Derek Mauldin

Financial Advisor/RIA

Kingdom Focused Financial

Derek Hastings

CFP

Inspire Advisors

 

Johnathan Cunningham

Financial Advisor

Inspire Advisors

David Zumbusch

Owner & CFP

Inspire Advisors MN

Terrence Rocks

Founder/Advisor

Teleios Financial Partners

 


2


 

Matthew Baldini

Wealth Advisor

Inspire Advisors

Paul Bryer

Financial Advisor

Inspire Advisors

Aaron Hoffman

Financial Advisor

Inspire Advisors

 

Scott Harlan

Financial Planner/Practice Owner

Inspire Advisors HH

Jaime Pagotto

Compliance Specialist

Kingdom Focused Financial

Jay Richardson

Investment Advisor

Kingdom Wealth Stewards

 

Rick Figueroa

CEO

Patron Partners Wealth Advisors

Jon Nettles

‍CEO‍‍

Revo Financial

Daniel Catone

CEO

Arimathea

 

William Poland

‍‍Financial Advisor

Carolina Financial Advisors

Matthew Mohlman

President

Monument Ventures

Kurt Spackman

President/CEO

Capital Resource Mgmt, Inc.

 

Bruce Parmenter

‍Financial Advisor‍

‍Ameriprise Financial

Carole Murray

‍Treasurer‍

Murray Financial Group, Inc.

Benjamin Wilhelm

CEO‍

‍Lone Oak Financial

 

Rachel McDonough

Financial Advisor

Wealth Squared

Evan Frazier

Founder & CEO

Tekwise Financial Planners

Jon Halverson

Partner

Talanton LLC

 

William Feus

CEO

Gray Rock Financial Planning

Steve French

Founding Advisor

Harvest Money | IYF

Randy Umbaugh

Financial Advisor

Diligent Wealth Mgmt.

 

Ronald Harczak

‍Financial Advisor

Steward Guide Wealth Partners

Daniel Bailey

‍Financial Advisor‍

‍Ambassador Advisors

Gerry Frigon

CIO

Taylor Frigon Capital

 

Craig Mardi

‍‍Financial Advisor

Cetera Advisor Networks

Dennis Williams

‍‍Financial Advisor

WSI Financial Partners, LLC

Thomas Payne

‍‍‍Founder

Prosperitas Wealth Management

 

Ron Zunker

‍‍‍Financial Advisor

PAX Financial Group

Nolan Dill

Financial Advisor‍‍

CFD Investments

Steve Ellis

Financial Advisor‍‍

Sage Oak Financial

 

Daryl Schafer

‍‍‍Financial Advisor

Culbertson Financial Services

William Holt

‍‍‍Financial Advisor

UBS

Eric Dorman

‍‍‍Financial Advisor

Affiliated Financial Planners

 

Mark Trice

‍‍‍Financial Advisor

ClearVista Financial

Michael Smith

‍‍‍Founder/CEO

Kingdom Focused Financial

Joseph James

‍‍‍Vice President

Greater Texas Financial Solutions

 

William Woodyard

‍‍‍Vice President

LifeSmart Financial

Brock Baker

‍‍‍Financial Advisor

Inspire Advisors

Doug Gathright

‍‍‍Financial Advisor

LifeSmart Financial


3


 

George Williams

‍‍‍Financial Advisor

WSI Financial Partners LLC

Jacob Chandler

Owner/Financial Advisor

Chandler Wealth Mgmt, Inc.

Jevon Webster

‍‍‍CFP

Inspire Advisors

 

Douglas Hanson

‍‍‍Financial Advisor

Christian Wealth Management

Ryan DeAmicis

‍‍‍‍Wealth Advisor

Christian Wealth Management

Jesse Hamilton

Financial Advisor

ClearVista Financial

 

Erik Bloomfeldt

Investment Advisor

Insight Financial

Heidi Foster

Vice President

American Wealth Management

Dr. Erik Davidson

Asst. Clinical Professor of Finance

Baylor University

 

John Moore

Founder

John Moore Associates

Ron Bergenske

Financial Advisor‍‍

LPL Financial

Kenneth Wince

Financial Advisor‍‍

LPL Financial

 

Micky Reeves

Senior Wealth Advisor‍‍

EverSource Wealth Advisors

Jerrold Ganz

‍Financial Advisor

Jerry Ganz Financial Planning‍‍

Charles Immekus

‍‍Financial Advisor

Dedicated Financial Services‍‍

 

Jeff Hybiak

‍‍CIO

SEM Wealth Management

Beau Zumbusch

‍‍CEO

Inspire Advisors Minnesota

Ed Lytle

‍‍‍Financial Advisor

ERL Financial Services, LLC

 

Shane Enete

‍‍‍Associate Professor of Finance

Biola University

Laura Simpson

‍‍‍Financial Advisor

PAX Financial Group

Daniel Hardt

Managing Partner

Dan Hardt Financial Services

 

Jonathan Hunt

‍‍‍Financial Advisor

Intentional Wealth

Matt Carr

Owner/Financial Advisor

TruPurpose Advisors

Salvador Rodriguez

‍Financial Advisor

Cetera Financial Specialists

 

John Ruzza

CFP

Cambridge

Mark Nicholas

Founder/Financial Adviser

Transform Retirement

Tony Adkison

‍‍‍Financial Advisor

Stewardship Advisory Group

 

Henry Groves

‍‍‍Financial Advisor

Stephens, Inc.

Paul Carlson

Owner/Wealth Manager

4:8 Financial

Matthew Holt

‍‍‍Financial Advisor

CWM

 

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

 

Brent Jackson

‍‍‍President

Harvest Financial

Jerry Bowyer

President

Bowyer Research

Mike Ching

Founder/President

Nardene Wealth Management

 


4


 

Andrew Lehman

Financial Advisor

Inspire Advisors

Joseph Verissimo

Owner/Financial Advisor

Christian Wealth Management

Andrew Hreha

Institutional Fixed Income

Stephens, Inc.

 

Joseph Allen

Financial Advisor/RIA

Inspire Advisors

Gerard Farkas

Owner

Gerard Farkas & Associates

Ryan Munoz

Wealth Advisor

Inspire Advisors

 

Luke Zumbusch

Financial Planner

Inspire Advisors MN

Thomas Strobhar

President

Strobhar Financial

Stephen Werner

Financial Advisor/RIA

Covenant Financial Group

 

Robert Franer III

Owner/Wealth Advisor

Castellum Financial Advice

James Kreid

President

Rock Solid Retirement Strategies

Mark Reynolds

Wealth Advisor

Terrier Financial Group

 

 

Scott Shepard

Director, Free Enterprise Project

National Center for Public Policy Research

 


5