FORM 3
 UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

INITIAL STATEMENT OF BENEFICIAL OWNERSHIP OF SECURITIES

Filed pursuant to Section 16(a) of the Securities Exchange Act of 1934 or Section 30(h) of the Investment Company Act of 1940
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(Print or Type Responses)
1. Name and Address of Reporting Person *
  ROSSOTTI CHARLES O
 2. Date of Event Requiring Statement (Month/Day/Year)
01/28/2009		 3. Issuer Name and Ticker or Trading Symbol
BANK OF AMERICA CORP /DE/ [BAC]
(Last)
(First)
(Middle)
101 SOUTH TRYON, NC1-002-29-01		 4. Relationship of Reporting Person(s) to Issuer
(Check all applicable)
__X__ Director _____ 10% Owner
_____ Officer (give title below) _____ Other (specify below)
5. If Amendment, Date Original Filed(Month/Day/Year)
(Street)

NC 28255		 6. Individual or Joint/Group Filing(Check Applicable Line)
_X_ Form filed by One Reporting Person
___ Form filed by More than One Reporting Person
(City)
(State)
(Zip)
Table I - Non-Derivative Securities Beneficially Owned
1.Title of Security
(Instr. 4)		 2. Amount of Securities Beneficially Owned
(Instr. 4)		 3. Ownership Form: Direct (D) or Indirect (I)
(Instr. 5)		 4. Nature of Indirect Beneficial Ownership
(Instr. 5)
Common Stock 3,867
D
 

Reminder: Report on a separate line for each class of securities beneficially owned directly or indirectly. SEC 1473 (7-02)
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Table II - Derivative Securities Beneficially Owned (e.g., puts, calls, warrants, options, convertible securities)
1. Title of Derivative Security
(Instr. 4)		 2. Date Exercisable and Expiration Date
(Month/Day/Year)		 3. Title and Amount of Securities Underlying Derivative Security
(Instr. 4)		 4. Conversion or Exercise Price of Derivative Security 5. Ownership Form of Derivative Security: Direct (D) or Indirect (I)
(Instr. 5)		 6. Nature of Indirect Beneficial Ownership
(Instr. 5)
Date Exercisable Expiration Date Title Amount or Number of Shares
Stock Unit Plan   (1)   (2) Common Stock 6,206 $ 0 (2) D  

Reporting Owners

Reporting Owner Name / Address Relationships
Director 10% Owner Officer Other
ROSSOTTI CHARLES O
101 SOUTH TRYON
NC1-002-29-01
NC 28255		   X      

Signatures

Charles O. Rossotti/Roger C. McClary POA 02/02/2009
**Signature of Reporting Person Date

Explanation of Responses:

* If the form is filed by more than one reporting person, see Instruction 5(b)(v).
** Intentional misstatements or omissions of facts constitute Federal Criminal Violations. See 18 U.S.C. 1001 and 15 U.S.C. 78ff(a).
(1) Received in exchange for Merrill Lynch & Co., Inc. (Merrill) stock units at an exchange ratio of .8595 of a Bank of America stock unit for each Merrill stock unit held prior to the merger on January 1, 2009. These stock units are payable in cash at the end of the deferral period as provided for in the Fee Deferral Plan. The closing price of Merrill stock on the last day prior to the effective time of the merger was $11.64 per share.
(2) These stock units are payable in cash at the end of the deferral period as provided for in the Fee Deferral Plan.

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