BANK OF AMERICA CORP DE

Commercial credit risk is evaluated and managed with the goal that concentrations of credit exposure continue to be aligned with our risk appetite. We review, measure and manage concentrations of credit exposure by industry, product, geography, customer relationship and loan size. We also review, measure and manage commercial real estate loans by geographic location and property type. In addition, within our non-U.S. portfolio, we evaluate exposures by region and by country. Tables 29, 31 and 34 summarize our concentrations. We also utilize syndications of exposure to third parties, loan sales, hedging and other risk mitigation techniques to manage the size and risk profile of the commercial credit portfolio. For more information on our industry concentrations, see Table 31 and Commercial Portfolio Credit Risk Management – Industry Concentrations on page 33.

For more information on our accounting policies regarding delinquencies, nonperforming status and net charge-offs, see Note 1 – Summary of Significant Accounting Principles to the Consolidated Financial Statements of the Corporation’s 2024 Annual Report on Form 10-K and Note 5 – Outstanding Loans and Leases and Allowance for Credit Lossesto the Consolidated Financial Statements.

Commercial Credit Portfolio

Outstanding commercial loans and leases increased $11.8 billion during the three months ended March 31, 2025 due to growth in U.S. and non-U.S. commercial, primarily in Global Markets and Global Banking. During the three months ended March 31, 2025, commercial credit quality deteriorated as reservable criticized utilized exposure increased primarily driven by commercial real estate due to the sustained high interest rate environment. Nonperforming commercial loans increased $142 million during the three months ended March 31, 2025, primarily in non-U.S. commercial and commercial real estate. Commercial net charge-offs decreased $137 million compared

to the same period in 2024 primarily due to lower charge-offs in the commercial real estate office portfolio.

With the exception of the office property type, which is further discussed in the Commercial Real Estate section herein, credit quality of commercial borrowers has remained relatively stable since December 31, 2024; however, we are closely monitoring emerging trends, including ongoing negotiations regarding international trade policies, as well as borrower performance in the current environment. Recent demand for office space continues to be stagnant, and future demand for office space continues to be uncertain as companies evaluate space needs with employment models that utilize a mix of remote and conventional office use.

The commercial allowance for loan and lease losses of $4.7 billion remained relatively unchanged during the three months ended March 31, 2025. For more information, see Allowance for Credit Losses on page 36.

Total commercial utilized credit exposure increased $1.3 billion during the three months ended March 31, 2025 to $740.8 billion driven by higher loans and leases partially offset by decreases in derivative assets and loans held-for-sale. The utilization rate for loans and leases, standby letters of credit (SBLCs) and financial guarantees, and commercial letters of credit, in the aggregate, was 56 percent and 55 percent at March 31, 2025 and December 31, 2024.

Table 25 presents commercial credit exposure by type for utilized, unfunded and total binding committed credit exposure. Commercial utilized credit exposure includes SBLCs and financial guarantees and commercial letters of credit that have been issued and for which we are legally bound to advance funds under prescribed conditions during a specified time period, and excludes exposure related to trading account assets. Although funds have not yet been advanced, these exposure types are considered utilized for credit risk management purposes.

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(1)Commercial utilized exposure includes loans of $5.2 billion and $4.0 billion accounted for under the fair value option at March 31, 2025 and December 31, 2024.

(2)Commercial unfunded exposure includes commitments accounted for under the fair value option with a notional amount of $2.0 billion and $2.2 billion at March 31, 2025 and December 31, 2024.

(3)Excludes unused business card lines, which are not legally binding.

(4)Includes the notional amount of unfunded legally binding lending commitments, net of amounts distributed (i.e., syndicated or participated) to other financial institutions. The distributed amounts were $10.6 billion and $10.4 billion at March 31, 2025 and December 31, 2024.

(5)Derivative assets are carried at fair value, reflect the effects of legally enforceable master netting agreements and have been reduced by cash collateral of $26.5 billion and $30.1 billion at March 31, 2025 and December 31, 2024. Not reflected in utilized and committed exposure is additional non-cash derivative collateral held of $56.7 billion and $59.7 billion at March 31, 2025 and December 31, 2024, which consists primarily of other marketable securities.

Nonperforming commercial loans increased $142 million during the three months ended March 31, 2025, primarily in non-U.S. commercial and commercial real estate. Table 26 presents our commercial loans and leases portfolio and related credit quality information at March 31, 2025 and December 31, 2024.

(1)Includes card-related products.

(2)Commercial loans accounted for under the fair value option includes U.S. commercial of $4.0 billion and $2.8 billion and non-U.S. commercial of $1.2 billion and $1.3 billion at March 31, 2025 and December 31, 2024 For more information on the fair value option, see Note 15 – Fair Value Optionto the Consolidated Financial Statements.

Table 27 presents net charge-offs and related ratios for the three months ended March 31, 2025 and 2024.

(1)Net charge-off ratios are calculated as annualized net charge-offs divided by average outstanding loans and leases, excluding loans accounted for under the fair value option.

Table 28 presents commercial reservable criticized utilized exposure by loan type. Criticized exposure corresponds to the

Special Mention, Substandard and Doubtful asset categories as defined by regulatory authorities. Total commercial reservable criticized utilized exposure increased $1.2 billion during the three months ended March 31, 2025 primarily driven by commercial real estate. At March 31, 2025 and December 31,

2024, 92 percent and 91 percent of commercial reservable criticized utilized exposure was secured.

(1)Total commercial reservable criticized utilized exposure includes loans and leases of $26.7 billion and $25.5 billion and commercial letters of credit of $994 million and $977 million at March 31, 2025 and December 31, 2024.

(2)Percentages are calculated as commercial reservable criticized utilized exposure divided by total commercial reservable utilized exposure for each exposure category.

Commercial and Industrial

Commercial and industrial loans include U.S. commercial and non-U.S. commercial portfolios.

U.S. Commercial

At March 31, 2025, 60 percent of the U.S. commercial loan portfolio, excluding small business, was managed in Global Banking, 23 percent in Global Markets, 16 percent in GWIM (loans that provide financing for asset purchases, business investments and other liquidity needs for high net worth clients) and the remainder primarily in Consumer Banking. U.S. commercial loans increased $6.4 billion, or two percent, during the three months ended March 31, 2025 primarily driven by Global Banking and Global Markets. Reservable criticized utilized exposure remained relatively unchanged.

Non-U.S. Commercial

At March 31, 2025, 57 percent of the non-U.S. commercial loan portfolio was managed in Global Banking and 43 percent in Global Markets. Non-U.S. commercial loans increased $3.8 billion, or three percent, during the three months ended March 31, 2025 primarily driven by Global Banking. Reservable criticized utilized exposure decreased $151 million, or eight percent. For information on the non-U.S. commercial portfolio, see Non-U.S. Portfolio on page 35.

Commercial Real Estate

Commercial real estate primarily includes commercial loans secured by non-owner-occupied real estate and is dependent on the sale or lease of the real estate as the primary source of repayment. Outstanding loans of $65.5 billion remained relatively unchanged during the three months ended March 31, 2025. The commercial real estate portfolio is primarily managed in Global Banking and consists of loans made primarily to public

and private developers, and commercial real estate firms. The portfolio remains diversified across property types and geographic regions. California represented the largest state concentration at 21 percent of commercial real estate at both March 31, 2025 and December 31, 2024.

Reservable criticized utilized exposure increased $1.3 billion, or 13 percent, during the three months ended March 31, 2025 primarily driven by industrial/warehouse and multi-family rental loans that are being impacted by the elevated interest rate environment. Office loans represented the largest property type concentration at 22 percent of the commercial real estate portfolio at March 31, 2025, and approximately one percent of total loans for the Corporation. This property type is roughly 75 percent Class A and had an origination loan-to-value of approximately 55 percent.

Reservable criticized exposure for the office property type was $5.2 billion at March 31, 2025, representing an increase of $168 million, or three percent, from December 31, 2024, with an aggregate loan-to-value of approximately 85 percent based on property appraisals completed in the last twelve months. Approximately $3.4 billion of office loans are scheduled to mature by the end of 2025.

During the three months ended March 31, 2025, net charge-offs decreased $181 million to $123 million compared to the same period in 2024 driven by office loans. We use a number of proactive risk mitigation initiatives to reduce adversely rated exposure in the commercial real estate portfolio, including transfers of deteriorating exposures for management by independent special asset officers and the pursuit of loan restructurings or asset sales to achieve the best results for our customers and the Corporation.

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Table 29 presents outstanding commercial real estate loans by geographic region, based on the geographic location of the collateral, and by property type.

U.S. Small Business Commercial

The U.S. small business commercial loan portfolio is comprised of small business card loans and small business loans primarily managed in Consumer Banking. Credit card-related products were 53 percent of the U.S. small business commercial portfolio at both March 31, 2025 and December 31, 2024 and represented 98 percent of net charge-offs for the three months ended March 31, 2025 and 2024. Accruing loans that were past due 90 days or more remained relatively unchanged during the three months ended March 31, 2025.

Nonperforming Commercial Loans, Leases and Foreclosed Properties Activity

Table 30 presents the nonperforming commercial loans, leases and foreclosed properties activity during the three months ended March 31, 2025 and 2024. Nonperforming loans do not include loans accounted for under the fair value option. During the three months ended March 31, 2025, nonperforming commercial loans and leases increased $142 million to $3.5 billion. At March 31, 2025, nearly 100 percent of commercial nonperforming loans, leases and foreclosed properties were secured, and 36 percent were contractually current. Commercial nonperforming loans were carried at 86 percent of their unpaid principal balance, as the carrying value of these loans has been reduced to the estimated collateral value less costs to sell.

(1)Balances do not include nonperforming loans held-for-sale of $583 million and $379 million at March 31, 2025 and 2024.

(2)Includes U.S. small business commercial activity. Small business card loans are excluded as they are not classified as nonperforming.

(3)Commercial loans and leases may be returned to performing status when all principal and interest is current and full repayment of the remaining contractual principal and interest is expected, when the loan otherwise becomes well-secured and is in the process of collection, or when a modified loan demonstrates a sustained period of payment performance.

(4)Outstanding commercial loans exclude loans accounted for under the fair value option.

Industry Concentrations

Table 31 presents commercial committed and utilized credit exposure by industry. For information on net notional credit protection purchased to hedge funded and unfunded exposures for which we elected the fair value option, as well as certain other credit exposures, see Commercial Portfolio Credit Risk Management – Risk Mitigation.

Commercial credit exposure is diversified across a broad range of industries. Total commercial committed exposure increased $4.8 billion during the three months ended March 31, 2025 to $1.3 trillion. The increase in commercial committed exposure was concentrated in Finance companies, Government & public education and Capital goods.

For information on industry limits, see Commercial Portfolio Credit Risk Management – Risk Mitigation in the MD&A of the Corporation’s 2024 Annual Report on Form 10-K.

Asset managers and funds, our largest industry concentration with committed exposure of $190.2 billion, decreased $3.7 billion, or two percent, during the three months ended March 31, 2025, which was primarily driven by investment-grade exposures.

Finance companies, our second largest industry concentration with committed exposure of $109.8 billion, increased $8.0 billion, or eight percent, during the three months ended March 31, 2025. The increase in committed exposure was primarily driven by increases in Consumer finance, Thrifts and mortgage finance and Diversified financials.

Capital goods, our third largest industry concentration with committed exposure of $101.9 billion, increased $3.1 billion, or three percent, during the three months ended March 31, 2025. The increase in committed exposure was driven by increases in Trading companies and distributors, Machinery and Electrical equipment, partially offset by a decrease in Industrial conglomerates.

Various macroeconomic challenges, including geopolitical tensions, higher costs associated with inflationary pressures experienced over the past several years and elevated interest rates, have led to uncertainty in the U.S. and global economies and have adversely impacted, and may continue to adversely impact, a number of industries. We continue to monitor these risks as well as the ongoing negotiations regarding international trade policies.

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(1)Includes U.S. small business commercial exposure.

(2)Includes the notional amount of unfunded legally binding lending commitments, net of amounts distributed (i.e., syndicated or participated) to other financial institutions. The distributed amounts were $10.6 billion and $10.4 billion at March 31, 2025 and December 31, 2024.

(3)Industries are viewed from a variety of perspectives to best isolate the perceived risks. For purposes of this table, the real estate industry is defined based on the primary business activity of the borrowers or counterparties using operating cash flows and primary source of repayment as key factors.

Risk Mitigation

We purchase credit protection to cover the funded portion as well as the unfunded portion of certain credit exposures. To lower the cost of obtaining our desired credit protection levels, we may add credit exposure within an industry, borrower or counterparty group by selling protection.

At March 31, 2025 and December 31, 2024, net notional credit default protection purchased in our credit derivatives portfolio to hedge our funded and unfunded exposures for which we elected the fair value option, as well as certain other credit exposures, was $12.0 billion and $10.4 billion. We recorded net gains of $3 million for the three months ended March 31, 2025 compared to net losses of $25 million for the three months ended March 31, 2024. The gains and losses on these instruments were largely offset by gains and losses on the related exposures. The Value-at-Risk (VaR) results for the exposures under the fair value option are included in the fair value option portfolio information in Table 37. For more information, see Trading Risk Management on page 38.

Tables 32 and 33 present the maturity profiles and the credit exposure debt ratings of the net credit default protection portfolio at March 31, 2025 and December 31, 2024.

(1)Represents net credit default protection purchased.

(2)Ratings are refreshed on a quarterly basis.

(3)Ratings of BBB- or higher are considered to meet the definition of investment grade.

(4)NR is comprised of index positions held and any names that have not been rated.

For more information on credit derivatives and counterparty credit risk valuation adjustments, see Note 3 – Derivativesto the Consolidated Financial Statements of the Corporation’s 2024 Annual Report on Form 10-K.

Non-U.S. Portfolio

Our non-U.S. credit and trading portfolios are subject to country risk. We define country risk as the risk of loss from unfavorable economic and political conditions, currency fluctuations, social instability and changes in government policies. A risk management framework is in place to measure, monitor and manage non-U.S. risk and exposures. In addition to the direct risk of doing business in a country, we also are exposed to indirect country risks (e.g., related to the collateral received on secured financing transactions or related to client clearing activities). These indirect exposures are managed in the normal course of business through credit, market and operational risk governance rather than through country risk governance. For more information on our non-U.S. credit and trading portfolios, see Non-U.S. Portfolio in the MD&A of the Corporation’s 2024 Annual Report on Form 10-K. For more information on risks related to our non-U.S. portfolio, see the Geopolitical section within Item 1A. Risk Factors of the Corporation’s 2024 Annual Report on Form 10-K.

Table 34 presents our 20 largest non-U.S. country exposures at March 31, 2025. These exposures accounted for 89 percent of our total non-U.S. exposure at both March 31, 2025 and December 31, 2024. Net country exposure for these 20 countries increased $6.1 billion from December 31, 2024 primarily driven by increases in Germany, India and Singapore.

Our largest non-U.S. country exposure at March 31, 2025 was the United Kingdom with net exposure of $59.9 billion, which decreased $2.1 billion from December 31, 2024 primarily due to lower deposits with the central bank. Our second largest non-U.S. country exposure was Germany with net exposure of $40.0 billion at March 31, 2025, which increased $3.0 billion from December 31, 2024 primarily due to increased exposure to sovereign institutions.

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