2012 Corporate Social Responsibility Highlights

Responsible business practices


We work to be fair, transparent, straightforward and easy to do business with, as our ability to form and sustain long–lasting relationships with our customers and clients is contingent on maintaining their confidence and trust.

In 2012, our commitment to responsible business practices led us to evaluate and update policies surrounding operational risk and governance, build our capital reserves to industry-leading levels and expand our engagement with stakeholders to learn how we can better serve our customers and communities.

In our Consumer Banking business, we worked with Pew Charitable Trusts to launch an enhanced checking Clarity Statement, a two-page document that clearly and concisely explains the fees and policies related to the specific checking account being opened. In our Global Wealth Management business, our commitment to delivering value to clients resulted in client satisfaction with Merrill Lynch Financial Advisors remaining at or near an all-time high in 2012.

Our strength and stability directly affects our shareholders, customers and clients and employees. Proactively managing the risk inherent in our operations as a financial institution is a critical responsibility shared by all employees. In 2012, we continued our efforts to ensure that all of our employees feel personally responsible for identifying and alerting appropriate managers to risk, because a strong risk culture is critical to the future success of Bank of America. Our Risk Framework provides employees with a consistent guide to managing risk across our businesses and geographies, and is reviewed annually by senior management and updated as needed.

Overdraft fees

Our progressive position on debit card overdraft fees at the point of sale has supported our ongoing efforts to provide customers with greater control, choice and clarity. One of the first and most tangible demonstrations of that commitment was our decision to materially help many of our customers who were telling us, “Don't let me spend money I don't have.” So, in response to this feedback, we decided to decline all debit-card transactions at the point of sale when customers didn't have enough money in their accounts to pay for them. We supported that approach by providing several ways to warn customers when their balances were approaching zero. This policy of preventing unexpected debit card overdraft fees, which went well beyond regulations later enacted by the Federal Reserve, has been widely praised by customers, consumer advocates, policymakers and our own employees.

Bank of America's decision on debit card penalty fees is a really big deal, not just for its customers but for the long-term bottom line of the bank.

Martin Eakes
Chief Executive Officer, Center for Responsible Lending


In 2012, the second full year since we implemented this change, customer complaints concerning insufficient funds and overdraft fees continued to decrease while the number of overdrafts decreased by more than half. This was thanks, in part, to the new debit card policy and to the more than 20 million low-balance courtesy alerts we send each month to nearly 8 million unique customers.

The continued positive feedback from our customers and communities confirms the business and social value of our commitment to building long-term customer relationships.

Stakeholder engagement

The Homes for First Responders Program will redevelop vacant, bank-owned real estate in unincorporated Fulton County and offer those homes at low interest rates for qualifying police officers, firefighters, emergency medical technicians and other first responders who serve the city.

Atlanta Neighborhood Development Partnership
Fulton County, GA

We engage daily with stakeholders including customers, clients, investors, regulators, community organizations, employees and others in more than 40 countries in which we do business. We work with these groups through formal, mandated engagements such as shareholder meetings as well as our ongoing outreach to customers, nonprofit and community groups.

Our Market Presidents – 99 across the U.S. – are responsible for overseeing business integration, community involvement and employee engagement in suburban areas from Little Rock, AR and Oklahoma City, OK to large metropolitan areas including New York, NY, Chicago, IL and Los Angeles, CA. They enhance our outreach to our communities – forging new and stronger relationships with leaders of business chambers, economic development authorities, nonprofit organizations and advocacy group leaders, among others. Globally, our Country Presidents fulfill a similar function on behalf of our international businesses as our businesses as our Market Presidents in the U.S.

For example, when Fulton County, Georgia was looking for a way to provide its first responders with affordable housing options, our Georgia market president teamed up with the Atlanta public-private partnership. The Homes for First Responders Program will redevelop vacant, bank-owned real estate in unincorporated Fulton County and offer homes at low interest rates for qualifying police officers, firefighters, emergency medical technicians and other first responders who serve the city.

In addition to the efforts of our Market and Country Presidents, we have established two external councils through which we engage with stakeholders:

  • The Bank of America National Community Advisory Council, a U.S.-focused group of independent civil rights leaders, community representatives and consumer advocates, which offers advice and counsel on critical business and governance issues.
  • The Bank of America Global Advisory Council, which was established in 2012, includes 14 business, academic and public policy leaders who will share their expertise and insights on the bank's global engagement and advise senior executives on trends and emerging opportunities in local markets, including social and environmental issues.



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