What the changes say
- New risks emphasize subsidiary funding constraints, cross-border fragmentation, third-party operational and cybersecurity vulnerabilities, and evolving regulation.
- Bank of America now highlights misconduct and enforcement exposure plus technology-driven competitive risk involving AI, digital assets and distributed-ledger payments.
- 2025 updates refine housing, climate, legal, capital, ratings and macroeconomic risks, including held-for-investment mortgage exposure and U.S. sovereign ratings.
What changed since the prior 10-K
New
- New
fund payments on our other obligations, including debt obligations. Any inability of our subsidiaries to transfer funds, pay dividends or make payments to the parent company may adversely affect our cash flow, liquidity and financial condition
Subsidiaries may be unable to transfer funds or dividends to the parent because of regulatory, capital, liquidity and resolution-planning restrictions.
- New
changes in legislation. These risks are heightened in emerging markets
Fragmented relations with China and other trading partners could bring sanctions, tariffs, data restrictions, supply disruptions, higher costs and currency-related client credit risks.
- New
and reliance on, third parties and the financial services industry, including the processing and reporting of a large number of complex transactions at increasing speeds in many currencies and jurisdictions, creates additional operational risk
Failures or damage at Bank of America or third-party systems could disrupt site access, information protection, transaction processing, services and reporting.
- New
security of our information and systems and strengthen threat actor capabilities in ways that are difficult to anticipate. These technologies, alone or in combination with others, may amplify the risks they pose
Third-party technology weaknesses, software vulnerabilities and delayed incident reporting could leave Bank of America more exposed to cyberattacks and operational failures.
- New
We are highly regulated and subject to evolving government legislation and regulations and certain settlements, orders and agreements with government authorities from time to time
Changing federal, state and foreign regulations and executive actions could increase costs, require more capital, restrict products and complicate reporting.
- New
established by our regulators and other government authorities, could result in further settlements, orders or agreements and additional fines, penalties or judgments, or material regulatory restrictions on our businesses
Misconduct, conflicts, fiduciary failures or confidential-information misuse could trigger overlapping investigations, settlements, fines, penalties and business restrictions across jurisdictions.
- New
We rely on a diversified mix of businesses that deliver a broad range of financial products and services through multiple
Rapid changes in AI, digital assets, automated trading and distributed-ledger payments could require costly product changes and weaken competitiveness.
Dropped
- Dropped
pay dividends or make payments to us may adversely affect our cash flow, liquidity and financial condition
- Dropped
Our operations and information systems and components thereof, and those of our third parties, have been, and in the
- Dropped
machine learning and generative AI) and robotics, increases our cybersecurity risks and exposure, including by making fraud detection and authentication more difficult
- Dropped
Our inability to adapt our business strategies, products and services could harm our business
- Dropped
widespread health emergencies or pandemics, cyberattacks, and military conflicts or other significant geopolitical events
Reworded
- 91% rewritten
We are subject to numerous political, economic, market, reputational, operational, compliance, legal, regulatory and other risks in the jurisdictions in which we operate
The wording now emphasizes global political, economic and market risks, with valuation declines replacing reduced market value and weather events replacing some prior environmental wording.
- 85% rewritten
We may be adversely affected by weaknesses in the U.S. housing market
The update shifts from 2024 to 2025 conditions and identifies regional housing-price dispersion plus held-for-investment residential mortgage and home equity exposures.
- 84% rewritten
Our risk management framework may not be effective in mitigating risk and reducing the potential for losses
The risk taxonomy now calls concentration-related risk financial risk associated with concentration and climate risk, rather than listing concentration and climate separately.
- 79% rewritten
Our operations, businesses and clients could be adversely affected by climate-related matters and impacts
The update removes the broader environmental-sustainability framing and more specifically describes physical, collateral, deposit, credit-facility, insurance and transition risks.
Was: Our operations, businesses and clients could be adversely affected by the impacts related to climate change
- 60% rewritten
U.S. federal banking agencies may require increased capital and liquidity levels, which could adversely impact the Corporation
The substantive capital and liquidity risk is unchanged; the update mainly standardizes the article before SCB.
- 53% rewritten
Reduction in our credit ratings could limit our access to funding or the capital markets, increase borrowing costs or trigger additional collateral or funding requirements
The update adds U.S. sovereign debt ratings as a factor that rating agencies may consider and tightens the funding-access wording.
- 53% rewritten
We are subject to significant financial and reputational harm from potential liability arising from lawsuits and regulatory and government action
The update expands the described enforcement sources to U.S. federal and state authorities, state attorneys general and foreign regulators.
Was: We are subject to significant financial and reputational risks from potential liability arising from lawsuits and regulatory and government action
- 47% rewritten
macroeconomic conditions, as well as result in increased market volatility and disruptions and recessionary risk
The update adds that central-bank actions may respond to uncertain inflation paths, while otherwise retaining the macroeconomic risk description.
Was: macroeconomic conditions, as well as result in additional market volatility and disruptions and recessionary risk
- 46% rewritten
We face significant and increasing competition in the financial services industry
- 44% rewritten
If we are unable to access capital markets, we experience sustained net deposit outflows, or our borrowing costs increase, our liquidity and competitive position may be negatively affected
Was: If we are unable to access the capital markets, have prolonged net deposits outflows, or our borrowing costs increase, our liquidity and competitive position will be negatively affected
- 43% rewritten
We could suffer operational, reputational and financial harm if our models fail to properly anticipate and manage risk
- 42% rewritten
We may be adversely affected by the financial markets, fiscal, monetary, and regulatory policies, and economic conditions
- 41% rewritten
Damage to our reputation could harm our businesses, including our competitive position and business prospects
- 36% rewritten
A failure in or breach of our operations or information systems, or those of third parties or the financial services industry, could cause disruptions, adversely impact our businesses, results of operations and financial condition, and cause legal or reputational harm
- 35% rewritten
Bank of America Corporation is a holding company, is dependent on its subsidiaries for liquidity and may be restricted from transferring funds from subsidiaries
- 29% rewritten
Our concentrations of credit risk could adversely affect our credit losses, results of operations and financial condition
- 25% rewritten
Defaults by one or more counterparties, or market uncertainty about the financial stability of one or more financial services institutions, or the financial services industry generally, could lead to market-wide liquidity disruptions, losses, defaults and related disputes and litigation
Was: could lead to market-wide liquidity disruptions, losses, defaults and related disputes and litigation
- 21% rewritten
Economic or market disruptions and insufficient credit loss reserves may result in a higher provision for credit losses
- 21% rewritten
Changes in the structure of and relationship among the GSEs could adversely impact our business
All 34 risk factors
Headings as the filing states them, in filing order.
Other
- 01We may be adversely affected by the financial markets, fiscal, monetary, and regulatory policies, and economic conditions42% rewritten
- 02macroeconomic conditions, as well as result in increased market volatility and disruptions and recessionary risk47% rewritten
- 03Increased market volatility and adverse changes in financial or capital market conditions may increase our market risk
- 04If asset values decline, we may incur losses and negative impacts, including to capital and liquidity positions and requirements
- 05If we are unable to access capital markets, we experience sustained net deposit outflows, or our borrowing costs increase, our liquidity and competitive position may be negatively affected44% rewritten
- 06Reduction in our credit ratings could limit our access to funding or the capital markets, increase borrowing costs or trigger additional collateral or funding requirements53% rewritten
- 07Bank of America Corporation is a holding company, is dependent on its subsidiaries for liquidity and may be restricted from transferring funds from subsidiaries35% rewritten
- 08fund payments on our other obligations, including debt obligations. Any inability of our subsidiaries to transfer funds, pay dividends or make payments to the parent company may adversely affect our cash flow, liquidity and financial conditionnew
- 09Bank of America Corporation’s liquidity and financial condition, and the ability to pay dividends and obligations, could be adversely affected in the event of a resolution
- 10Economic or market disruptions and insufficient credit loss reserves may result in a higher provision for credit losses21% rewritten
- 11Our concentrations of credit risk could adversely affect our credit losses, results of operations and financial condition29% rewritten
- 12Defaults by one or more counterparties, or market uncertainty about the financial stability of one or more financial services institutions, or the financial services industry generally, could lead to market-wide liquidity disruptions, losses, defaults and related disputes and litigation25% rewritten
- 13We may be adversely affected by weaknesses in the U.S. housing market85% rewritten
- 14Our derivatives businesses may expose us to unexpected risks, which may result in losses and adversely affect liquidity
- 15We are subject to numerous political, economic, market, reputational, operational, compliance, legal, regulatory and other risks in the jurisdictions in which we operate91% rewritten
- 16changes in legislation. These risks are heightened in emerging marketsnew
- 17A failure in or breach of our operations or information systems, or those of third parties or the financial services industry, could cause disruptions, adversely impact our businesses, results of operations and financial condition, and cause legal or reputational harm36% rewritten
- 18and reliance on, third parties and the financial services industry, including the processing and reporting of a large number of complex transactions at increasing speeds in many currencies and jurisdictions, creates additional operational risknew
- 19security of our information and systems and strengthen threat actor capabilities in ways that are difficult to anticipate. These technologies, alone or in combination with others, may amplify the risks they posenew
- 20Failure to satisfy our obligations as servicer for residential mortgage securitizations, loans owned by other entities and other related losses could adversely impact our reputation, servicing costs or results of operations
- 21Changes in the structure of and relationship among the GSEs could adversely impact our business21% rewritten
- 22Our risk management framework may not be effective in mitigating risk and reducing the potential for losses84% rewritten
- 23We are highly regulated and subject to evolving government legislation and regulations and certain settlements, orders and agreements with government authorities from time to timenew
- 24established by our regulators and other government authorities, could result in further settlements, orders or agreements and additional fines, penalties or judgments, or material regulatory restrictions on our businessesnew
- 25We are subject to significant financial and reputational harm from potential liability arising from lawsuits and regulatory and government action53% rewritten
- 26U.S. federal banking agencies may require increased capital and liquidity levels, which could adversely impact the Corporation60% rewritten
- 27Changes in accounting standards or assumptions in applying accounting policies could adversely affect us
- 28Damage to our reputation could harm our businesses, including our competitive position and business prospects41% rewritten
- 29We face significant and increasing competition in the financial services industry46% rewritten
- 30We rely on a diversified mix of businesses that deliver a broad range of financial products and services through multiplenew
- 31We could suffer operational, reputational and financial harm if our models fail to properly anticipate and manage risk43% rewritten
- 32Failure to properly manage data may adversely affect our ability to manage compliance risk and business needs, and result in errors in our operations, reporting and decision-making, and compliance with LRRs
- 33Our operations, businesses and clients could be adversely affected by climate-related matters and impacts79% rewritten
- 34Our ability to attract, develop and retain qualified employees is critical to our success, business prospects and competitive position
Other Bank of America 10-Ks
- 2025 10-K risk factors
32 risks. Market volatility, funding access, credit losses, and asset valuations dominate Bank of America’s financial risks.
Filed Feb 25, 2025
About this page
Item 1A of the 10-K on EDGAR was split into its risk factors and, where the company's previous 10-K is on file, each heading was matched to last year's and the text compared word for word. The headings are the filing's own. The one-line readings and the overview were written by a language model from the text of the new, dropped, and rewritten risks; they refer to risks by position and cannot misquote a heading.