Bank of America.
July 18, 2008
Bank of America
Ms. Jennifer J. Johnson
Chief Counsel's Office
730 15th Street, N.W., 10th Floor, W
Office of Thrift
Board of Governors of the Federal Reserve System
1700 G Street, NW
20th Street and Constitution Avenue, NW
Washington, DC 20552
Washington, DC 20551
Ms. Mary Rupp
Secretary of the Board
National Credit Union Administration
1775 Duke Street
Alexandria, VA 22314-3428
Re: Federal Reserve System 12 CFR Part 227: Docket No. R-1314; 12 CFR Part 230: Docket
No. R-1315; 12 CFR Part 226: Docket No. R-1286; Office of Thrift Supervision 12 CFR 535:
Docket ID. OTS 2008-0004; National Credit Union Administration 12 CFR Part 706: RIN 3133
Dear Ms. Johnson, Mr. Bowman and Ms. Rupp:
Bank of America Corporation and its bank affiliates appreciate the opportunity to comment on
the proposed rules that the Board of Governors of the Federal Reserve System, the Office of
Thrift Supervision, and the National Credit Union Administration (collectively, the "Agencies")
published in the Federal Register on May 19, 2008. The comments below will also address the
proposed changes to Regulation AA, Regulation DD, and Regulation Z.
Bank of America is a leader in domestic retail banking - particularly with regard to deposits and
credit cards. We serve more than 59 million households through 6,100 retail banking offices,
nearly 18,500 ATMs and award-winning online banking services. With 24 million U.S.
consumer deposit customers (approximately $525 billion consumer deposits as of June 30, 2008)
and 38 million active U.S. card customers (over $150 billion in managed account balances as of
June 30, 2008), we lead the industry in both domestic deposits and card balances. The Agencies'
proposal, therefore, is of great consequence to Bank of America and its customers.
The proposal would substantially reinvent the business of credit card lending and deposit taking.