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Bank of America Private BankAP
Bank of America Private Bank review

Bank of America, National Association

Two stars: serious findings on the record, a recurring failure and a very recent adverse finding.

Booking centreUnited States
RegulatorOCC
Legal formLocally incorporated subsidiary
GroupBank of America Corporation
Founded1904
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PPLI.com
Private Bank Rating
2 out of 5 stars
Editorial assessment on UHNW criteria
Reviewed 6 November 2026 · Q4 2026 edition
Updated every quarter
Rating signed byNoam CohenEditor, Bank Intelligence
About the rating
2 out of 5, Q4 2026 edition
Not publishedpricing on request
7matters on the record, 2022 to 2026
Not publishedminimum relationship
The editor's opinion

Why Bank of America Private Bank has two stars

Bank of America Private Bank earns two stars. What holds the rating down: serious adverse findings against this licence holder in the last ten years. The same kind of failure has recurred. In its favour: custody assets are protected by statute in the booking centre, with conditions a family should read. Still to be confirmed: whether past findings were remediated and whether external asset managers have a dedicated desk. These points carry no weight until they are documented.

Noam Cohen, Editor, Bank IntelligenceReviewed 6 November 2026, Q4 2026 edition. The rating weighs the public record together with what clients and their advisers tell us in confidence; retail products, branches and apps play no part.

Where Bank of America Private Bank stands out

  • Custody assets are protected by statute in the booking centre, with conditions a family should read.
  • Deposits are covered by a statutory protection scheme.
  • A broad range of private banking services is published for this booking unit.
  • Ownership is public, with some detail missing.
  • No politically exposed person holds a significant stake.

What to weigh

  • Serious adverse findings against this licence holder in the last ten years.
  • The same kind of failure has recurred.
  • The last adverse finding is very recent.
  • Only a summary of the custody terms is public.
  • No fee schedule is published; pricing is given on request.
  • The bank has not shown publicly that the failings behind past findings were put right.
Rating on public information
PPLI.com rating

Rating set by the editor on 5 November 2026 from client experience and intelligence held by PPLI.com. It will be reviewed in the next quarterly edition.

The rating expresses the opinion of PPLI.com on the date shown. It is not a statement of fact about the bank, not a credit rating, not a forecast of failure and not investment advice.

The record

Regulatory and legal record

What regulators, prosecutors and courts have decided, recorded against the legal entity they named, with the status, the amounts as published and a link to the original document. Claims and investigations still under way are marked as open.

202613 October 2026

Penalty for wilful Bank Secrecy Act violations, including missed and late suspicious activity reports

The Financial Crimes Enforcement Network assessed the penalty on Bank of America, National Association under consent order 2026-03, in which the bank admitted wilful violations of the Bank Secrecy Act from at least 1 January 2018 to 1 July 2025. Its Event Processor monitoring system caused over USD 5 billion of suspicious activity to be missed or reported late, over USD 600 million of suspicious money order deposits went unreported, and due diligence on correspondent accounts for foreign banks failed. The OCC imposed USD 750 million the same day, credited against the FinCEN penalty, and OFAC announced a USD 11.6 million settlement. On the same day the OCC imposed a separate civil money penalty of USD 750 million on the bank for the same failings (AA-ENF-2026-41).

Financial Crimes Enforcement Network (with the OCC)Resolution with admissionPenalty USD 1.20 billion; Penalty occ USD 750 millionAdmission of the factsPrimary source
202613 October 2026

Settlement of apparent violations of several US sanctions programmes

Bank of America, N.A. agreed on 13 October 2026 to pay USD 11,662,930 to OFAC to settle its potential civil liability for 475 apparent violations of several US sanctions programmes between September 2021 and April 2025, involving about USD 14.8 million of transactions. OFAC treated the violations as non-egregious.

has agreed to pay $11,662,930 to settle its potential civil liability for 475
Office of Foreign Assets Control (US Treasury)Settlement without admissionSettlement USD 11.7 millionPrimary source
202423 December 2024

Cease and desist order over deficiencies in anti-money laundering and sanctions compliance

The Office of the Comptroller of the Currency issued cease and desist order AA-ENF-2024-56 against Bank of America, National Association for violations and unsafe or unsound practices in its Bank Secrecy Act and sanctions compliance programmes, including late suspicious activity reports and failure to correct a customer due diligence deficiency already identified. The order cites weak internal controls, governance, independent testing and training, carries no penalty and remains in force.

Office of the Comptroller of the CurrencyFinal decisionPrimary source
202328 November 2023

Consent order over false demographic data in mortgage reporting

The CFPB found that Bank of America, N.A. loan officers failed to ask mortgage applicants for demographic information and recorded false answers in the bank's mortgage lending reports, and on 28 November 2023 ordered a civil money penalty of USD 12 million (2023-CFPB-0016).

Respondent must pay a civil money penalty of $12,000,000 to the Bureau.
Consumer Financial Protection BureauSettlement without admissionPenalty USD 12 millionCFPB order terminated 5 June 2025Primary source
202311 July 2023

Orders over repeat fees, withheld card rewards and credit card accounts opened without authorisation

The Consumer Financial Protection Bureau found that Bank of America, National Association charged repeat non-sufficient funds fees, withheld credit card rewards it had promised and, since at least 2012, opened credit card accounts without customers' authorisation. It imposed USD 90 million in penalties and more than USD 100 million of redress to customers, and the OCC separately imposed USD 60 million over the repeat fees.

Consumer Financial Protection Bureau (with the OCC)Settlement without admissionPenalty USD 90 millionPrimary source
202214 July 2022

Orders over frozen accounts and denied fraud claims on state unemployment benefit cards

The OCC and the CFPB found that Bank of America, N.A., which ran the unemployment benefit prepaid card programme for 12 states, used an automated fraud filter to freeze accounts and deny cardholders' claims of unauthorised transactions without reasonable investigation. On 14 July 2022 the OCC imposed a civil money penalty of USD 125 million and a cease and desist order, and the CFPB a penalty of USD 100 million, with redress for affected cardholders.

The Bank shall make payment of a civil money penalty in the total amount of one hundred twenty-five million ($125,000,000)

The OCC terminated its cease and desist order on 18 June 2026; the penalties remain part of the record.

Office of the Comptroller of the Currency and Consumer Financial Protection BureauSettlement without admissionPenalty occ USD 125 million; Penalty cfpb USD 100 millionOCC cease and desist order terminated 18 June 2026Primary source
20224 May 2022

Consent order over the handling of garnishment orders on out-of-state accounts

The CFPB found that Bank of America, N.A. unlawfully processed garnishment notices against out-of-state customers' accounts and relied on a deposit-agreement clause waiving their garnishment protections, and on 4 May 2022 ordered a civil money penalty of USD 10 million and about USD 592,000 of redress (2022-CFPB-0002).

Respondent must pay a civil money penalty of $10,000,000 to the Bureau.
Consumer Financial Protection BureauSettlement without admissionPenalty USD 10 million; Redress USD 592,000Primary source
Clients and standing

Client experience and financial standing

What clients meet at Bank of America Private Bank, read from complaint registers, ombudsman decisions and court records, independent reporting and what clients and their advisers tell PPLI.com in confidence. Announcements by the bank, awards and marketing material are left out.

UHNW client ratings

2.1 out of 5, based on 41 client ratings for this booking centre.

What clients report

The CFPB complaint database holds 190,060 complaints against Bank of America, National Association as of 6 November 2026, a count that covers all customers of the national bank and is mostly retail. The July 2023 CFPB orders concerned retail practices, repeat non-sufficient funds fees, withheld card rewards and unauthorised credit card accounts, and returned more than USD 100 million to customers. No complaints figure is published separately for private bank clients. The broker-dealer affiliate Merrill Lynch, Pierce, Fenner & Smith shows 878 arbitration disclosures on FINRA BrokerCheck.

Worth raising with the bank

  • Ask whether the OCC cease and desist order of December 2024, which remains in force, affects account opening or cross-border payments for private clients, and what the bank must still complete before it is lifted.

Financial standing

Credit ratings published by the agencies, dated by the latest agency or bank document that confirms them
AgencyRatingOutlookAs ofRated company
Moody'sAa2 / P-1StableOctober 2026Bank of America, N.A.
S&PA+ / A-1StableOctober 2026Bank of America, N.A.
FitchAA / F1+StableOctober 2026Bank of America, N.A.
Moody'sA1 / P-1StableOctober 2026Bank of America Corporation (parent)

In the press

What it costs

What Bank of America Private Bank charges

Bank of America Private Bank does not publish its private banking fees. We searched its website on 6 November 2026 for a fee schedule, a tariff or a pricing page. We read its legal, documents and client information pages and searched the site in each language it uses. 96 of the 151 banks we cover publish theirs. A family cannot see what a relationship with Bank of America Private Bank would cost before asking, so the cost transparency element of the PPLI.com rating gives Bank of America Private Bank no credit for a published schedule, and the bank cannot be placed in our fee comparison. If Bank of America Private Bank publishes a schedule, we will read it and add it in the next edition.

Pricing not published

Banks that publish their fees, and how they compare, are listed on the comparison page. If you hold a proposal from Bank of America Private Bank, our editors can place it against the published fees of other banks in confidence: write to [email protected].

The bank at a glance

Identity, protection and services

Legal identity

Legal nameBank of America, National Association
LEIB4TYDEB6GKMZO031MB27
LicenceNational bank (OCC), FDIC insured, FDIC cert 3510  Source
RegulatorOCC
Legal formLocally incorporated subsidiary
OwnerBank of America Corporation

Ownership

Group parentBank of America Corporation (listed, NYSE)  Source
ControlWidely held; no shareholder with 10% or more  Source

Ownership is shown as published, with its date. It describes who owns the bank; it does not, by itself, suggest any wrongdoing by the bank or its owners.

Financial strength, as reported

Credit ratingsMoody's Aa2 / P-1; S&P A+ / A-1; Fitch AA / F1+
CET1 (Standardized) ratio11.4% (31 Dec 2025)
Total assetsUSD 2,654,645 m (30 Jun 2026)  Source

Rows without a source link are taken from the published reports of Bank of America Corporation (consolidated). Sources: Bank of America 2025 Annual Report; Bank of America credit ratings page (as of 14 Oct 2026).

Services published for this booking unit

Discretionary management
Advisory mandates
Multi currency accounts
Consolidated reporting
External asset manager desk

Offered at this booking centreOffered by the group, not confirmed hereNot located, which does not mean unavailable
Checked on the bank's own pages, 2 November 2026.

Access and costs

Minimum relationshipNot published
US personsNot published
Fee scheduleNot published
Third party paymentsNot published
Transfer out termsNot published

Protection of client assets

Deposit protectionNational banks are FDIC insured: USD 250,000 per depositor, per bank, for each ownership category. Securities are not deposits.
Custody law12 CFR 9.13(b) requires a national bank to keep fiduciary account assets separate from the bank's own assets; securities at a broker-dealer are customer property under SIPA with SIPC protection. Re-use and lending are governed by account agreements and regulator rules rather than a single statute.
Custody termsNot published

Before opening an account

  • Custody agreement. The applicable legal framework is set out above. Ask for the agreement that would govern your account and check how securities are titled, whether any sub-custodian is used, and when the bank may take a lien.
  • A portfolio-backed credit line. If you intend to borrow against the portfolio, ask for the eligibility and haircut schedule, the margin-call timetable and the charges for holding or transferring pledged securities.
  • Transferring assets out. Ask which positions can be transferred without selling them, who approves exceptions, and how charges are calculated for each position and market.
Your experience

Rate Bank of America Private Bank

If you bank with Bank of America Private Bank or advise clients who do, your experience forms part of its PPLI.com rating. Every response is read by the editor and treated in strict confidence.

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Our commitment to confidentiality

Your name, email and telephone number are seen only by the PPLI.com editor. They are never published, never passed to Bank of America Private Bank or any other bank, and never used for marketing. We may contact you once to clarify your assessment. Once verified by our editors, your assessment can lead to a disclosed adjustment of this bank's PPLI.com rating. It is never published with your name.

Sources

All 17 documents cited on this page, by subject.

Regulatory and legal record

  1. Financial Crimes Enforcement Network (with the OCC): Penalty for wilful Bank Secrecy Act violations, including missed and late suspicious activity reports, 13 October 2026fincen.gov
  2. Office of Foreign Assets Control (US Treasury): Settlement of apparent violations of several US sanctions programmes, 13 October 2026ofac.treasury.gov
  3. Office of the Comptroller of the Currency: Cease and desist order over deficiencies in anti-money laundering and sanctions compliance, 23 December 2024occ.gov
  4. Consumer Financial Protection Bureau: Consent order over false demographic data in mortgage reporting, 28 November 2023files.consumerfinance.gov
  5. Consumer Financial Protection Bureau (with the OCC): Orders over repeat fees, withheld card rewards and credit card accounts opened without authorisation, 11 July 2023consumerfinance.gov
  6. Office of the Comptroller of the Currency and Consumer Financial Protection Bureau: Orders over frozen accounts and denied fraud claims on state unemployment benefit cards, 14 July 2022occ.gov
  7. Consumer Financial Protection Bureau: Consent order over the handling of garnishment orders on out-of-state accounts, 4 May 2022files.consumerfinance.gov

Client experience and press

  1. Business Today: Bank of America hit by $1.2 billion penalty: why US regulators are cracking down on the bank, 14 October 2026businesstoday.in
  2. NPR: Bank of America to pay $250 million for illegal fees, fake accounts, 11 July 2023mprnews.org

Identity, ownership, finances and services

  1. api.fdic.gov: Institutionsapi.fdic.gov · Licence
  2. GLEIF: Ultimate parentapi.gleif.org · Group parent
  3. d1io3yog0oux5.cloudfront.net: Bank of America 2025 Annual Reportd1io3yog0oux5.cloudfront.net · Financial strength
  4. investor.bankofamerica.com: Bank of America credit ratings page (as of 14 Oct 2026)investor.bankofamerica.com · Financial strength
  5. Bank of America Private Bank: About usprivatebank.bankofamerica.com · Services
  6. Bank of America Private Bank: Creditprivatebank.bankofamerica.com · Services
  7. Bank of America Private Bank: Solutionsprivatebank.bankofamerica.com · Services

The bank

  1. Bank of America Private Bank, websiteprivatebank.bankofamerica.com

For Bank of America Private Bank

Before we publish a significant negative finding that is not already public, we give the bank the facts and time to comment, on the same timetable for every bank. Decisions of regulators and courts are shown as they were published. Corrections we verify are published with the date of the change. Write to [email protected] quoting reference BK-US-BOFA-DE0303.

Reviewing this file with us

Families and their advisers read this file before they open an account. It can only be as complete as the documents we can find, and much of what sets a private bank apart, from its custody terms to the way a client team works, is rarely published.

If you represent Bank of America Private Bank, one of our Bank Intelligence analysts can go through the file with you: correct anything that is out of date, add terms and documents that are not yet public, and set out what has improved since our last edition. The review is a paid engagement for the analyst's time and research.

The rating itself stays with our editor and follows what the documents show, so we cannot promise a particular result. When a review changes the file, this page notes that the bank took part, with the date and what was added.

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About this file

Researched by the PPLI.com research desk from the public sources listed. The rating is our editorial opinion; read how we rate.

Important information. Editorial opinion of PPLI.com on the date shown, based on public information, client experience and editorial judgment. Not a statement of fact, a credit rating or investment, legal, tax or financial advice; verify with the bank and your own advisers before acting. No liability is accepted for reliance on this content. Bank names and logos are used for identification only. Ratings are updated every quarter. This is the Q4 2026 edition, and a rating can change between editions if something material happens. Full disclaimer
Rating signed by Noam Cohen, Editor, Bank IntelligenceReviewed 6 November 2026Methodology 2.4Reference BK-US-BOFA-DE0303
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