Managed Account Advisors LLC

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with
a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same
event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BANK OF AMERICA, NATIONAL
ASSOCIATION

(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the
IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
MONETARY AUTHORITY OF SINGAPORE ("MAS")
2.
Principal Sanction:
Censure
Other Sanctions: 
ADOPT CERTAIN MEASURES TO ADDRESS DEFICIENCIES, REPORT PROGRESS ON QUARTERLY BASIS, CONDUCT INDEPENDENT REVIEWS, AND INCREASE
STATUTORY RESERVES.
3.
Date Initiated (MM/DD/YYYY): 
07/16/2012
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
N/A
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
REFERENCE RATE SUBMISSIONS FOR SIBOR, SOR, AND FOREIGN EXCHANGE BENCHMARK RATES FOR NON-DELIVERABLE FORWARDS CONTRACTS FOR
MALAYSIAN RINGGIT, INDONESIAN RUPIAH, VIETNAMESE DONG, AND THAI BAHT ADMINISTERED BY THE ASSOCIATION OF BANKS IN SINGAPORE ("ABS
BENCHMARKS").
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE MAS TOOK ADMINISTRATIVE ACTION AGAINST BANK OF AMERICA, NATIONAL ASSOCIATION (SINGAPORE BRANCH) ("BANA SINGAPORE") AND
EIGHTEEN OTHER BANKS IN THE MARKET FOR DEFICIENCIES IN GOVERNANCE, RISK MANAGEMENT, INTERNAL CONTROLS, AND SURVEILLANCE SYSTEMS
FROM 2007 TO 2011 RELATED TO THE SUBMISSION PROCESSES FOR SINGAPORE DOLLAR INTEREST RATE BENCHMARKS - SPECIFICALLY, SIBOR AND SOR
- AND FOREIGN EXCHANGE SPOT BENCHMARKS IN FOUR EMERGING MARKET ASIAN CURRENCIES. IN ADDITION, THE MAS DETERMINED BANA SINGAPORE
PERSONNEL ENGAGED IN ELECTRONIC COMMUNICATIONS IN WHICH THEY INITIATED, RECEIVED, ACKNOWLEDGED, OR RELAYED REQUESTS TO
IMPROPERLY INFLUENCE SUBMISSIONS FOR CERTAIN OF THE ABOVE-REFERENCED ABS BENCHMARKS. THE MAS STATED IT HAD NOT MADE THE FINDING
THAT THE ABS BENCHMARKS HAD BEEN MANIPULATED BY ANY OF THE NINETEEN BANKS SUBJECT TO ITS ORDER, BUT FOUND THAT THE ACTION OF THE
BANA SINGAPORE (AND OTHER BANKS') PERSONNEL REFLECTED A LACK OF PROFESSIONAL CONDUCT AND INTEGRITY.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:

Other
11. Resolution Date (MM/DD/YYYY):
06/14/2013
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
THE MAS IS REQUIRING BANA SINGAPORE TO ADOPT MEASURES TO ADDRESS THE DEFICIENCIES, REPORT ITS PROGRESS IN ADDRESSING THESE
DEFICIENCIES ON A QUARTERLY BASIS, AND CONDUCT INDEPENDENT REVIEWS TO ENSURE THE ROBUSTNESS OF THE REMEDIAL MEASURES. BANA
SINGAPORE WAS NOT FINED, BUT INSTEAD WAS REQUIRED TO POST WITH THE MAS FOR ONE YEAR A STATUTORY RESERVE OF 700 MILLION
SINGAPORE DOLLARS (APPROXIMATELY US$551 MILLION) WHICH IS REFUNDABLE UPON SATISFACTION OF THE MAS'S ORDER ON REMEDIAL
MEASURES.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived: 
PURSUANT TO SECTION 49(2) OF THE SINGAPORE BANKING ACT, THE MAS REQUIRED BANA SINGAPORE TO POST THE ABOVE-REFERENCED
STATUTORY RESERVE OF 700 MILLION SINGAPORE DOLLARS (APPROXIMATELY US$551 MILLION). IN ADDITION, THE MAS REQUIRED BANA
SINGAPORE TO MEET CERTAIN MILESTONES OVER THE NEXT YEAR TO ADOPT MEASURES TO ADDRESS THE DEFICIENCIES, REPORT THEIR
PROGRESS IN ADDRESSING THESE DEFICIENCIES ON A QUARTERLY BASIS, AND CONDUCT INDEPENDENT REVIEWS TO ENSURE THE ROBUSTNESS
OF THE REMEDIAL MEASURES.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON JUNE 13, 2013, THE MAS SENT BANA SINGAPORE A LETTER SETTING FORTH: (I) CERTAIN CONCLUSIONS REGARDING THE DEFICIENCIES THE AMS
IDENTIFIED IN THE REVIEW REPORTS AND RELATED DOCUMENTATION BANA SINGAPORE HAD SUBMITTED TO THE MAS REGARDING THE ABS REFERENCE
RATES; (II) DIRECTING BANA SINGAPORE, PURSUANT TO SECTION 49(2) OF THE SINGAPORE BANKING ACT, TO TAKE CERTAIN MEASURES TO ADDRESS
GOVERNANCE AND CONTROL DEFICIENCIES; AND (III) DIRECTING BANA SINGAPORE, PURSUANT TO SECTION 38(1) OF THE SINGAPORE BANKING ACT,
TO MAINTAIN AN ADDITIONAL STATUTORY RESERVE OF 700 MILLION SINGAPORE DOLLARS (APPROXIMATELY US$551 MILLION) WITH THE MAS FOR A
PERIOD OF ONE YEAR. ON JUNE 14, 2013, THE MAS MADE A PUBLIC ANNOUNCEMENT REGARDING THE CONCLUSION OF ITS INQUIRY INTO THE ABS
BENCHMARKS AND PROVIDED MARKET-WIDE FINDINGS WITH RESPECT TO COMMUNICATIONS DEEMED TO DEMONSTRATE A LACK OF PROFESSIONAL
CONDUCT AND INTEGRITY. BANA SINGAPORE HAS COMPLETED THE ACTIONS REQUIRED BY MAS, INCLUDING COMPLETING THE ENHANCEMENTS TO ITS
SUBMISSION PRACTICES WITH THE MAS.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with
a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same
event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates

If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BANK OF AMERICA, NATIONAL
ASSOCIATION
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the
IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
THE COMPTROLLER OF THE CURRENCY OF THE UNITED STATES OF AMERICA
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
REMEDIATION ACTIONS
3.
Date Initiated (MM/DD/YYYY): 
04/13/2011
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
AA-EC-11-12
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESIDENTIAL MORTGAGE LOAN SERVICING
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON APRIL 13, 2011, THE COMPTROLLER OF THE CURRENCY OF THE UNITED STATES OF AMERICA ("OCC") ISSUED A CEASE AND DESIST CONSENT ORDER
("ORDER") AGAINST BANK OF AMERICA, NATIONAL ASSOCIATION ("BANA"). THE ORDER IDENTIFIED CERTAIN DEFICIENCIES AND UNSAFE OR UNSOUND
PRACTICES IN RESIDENTIAL MORTGAGE SERVICING AND IN BANA'S INITIATION AND HANDLING OF FORECLOSURE PROCEEDINGS. THE ORDER FINDS
THAT IN CONNECTION WITH CERTAIN FORECLOSURES OF LOANS IN IT IS RESIDENTIAL SERVICING PORTFOLIO, BANA; (A) FILED OR CAUSED TO BE
FILED IN COURTS EXECUTED AFFIDAVITS MAKING VARIOUS ASSERTIONS THAT WERE NOT BASED ON THE AFFIANTS' PERSONAL KNOWLEDGE OR REVIEW
OF RELEVANT BOOKS AND RECORDS; (B) FILED OR CAUSED TO BE FILED IN COURTS NUMEROUS AFFIDAVITS OR OTHER MORTGAGE-RELATED
DOCUMENTS THAT WERE NOT PROPERLY NOTARIZED; (C) LITIGATED FORECLOSURE PROCEEDINGS AND INITIATED NON-JUDICIAL FORECLOSURE
PROCEEDINGS WITHOUT ALWAYS ENSURING THAT THE PROMISSORY NOTE OR THE MORTGAGE DOCUMENT WERE PROPERLY ENDORSED OR ASSIGNED
AND, IF NECESSARY, IN THE POSSESSION OF THE APPROPRIATE PARTY AT THE APPROPRIATE TIME; (D) FAILED TO DEVOTE SUFFICIENT RESOURCES TO

ENSURE PROPER ADMINISTRATION OF ITS FORECLOSURE PROCESSES; (E) FAILED TO DEVOTE TO ITS FORECLOSURE PROCESSES ADEQUATE
OVERSIGHT, INTERNAL CONTROLS, POLICIES AND PROCEDURES, COMPLIANCE RISK MANAGEMENT, INTERNAL AUDIT, THIRD PARTY MANAGEMENT AND
TRAINING; AND (F) FAILED TO SUFFICIENTLY OVERSEE THIRD-PARTY PROVIDERS HANDING FORECLOSURE-RELATED SERVICES.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
04/13/2011
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
REMEDIATION ACTIONS
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived: 
THE ORDER REQUIRES THAT BANA CEASE AND DESIST AND REQUIRES BANA'S BOARD TO MAINTAIN A COMPLIANCE COMMITTEE THAT IS
RESPONSIBLE FOR MONITORING AND COORDINATING BANA'S COMPLIANCE WITH THE ORDER. THE ORDER PROVIDES FOR BANA TO: (A) SUBMIT A
COMPREHENSIVE ACTION PLAN THAT INCLUDES A COMPLIANCE PROGRAM, THIRD-PARTY MANAGEMENT POLICIES AND PROCEDURES, CONTROLS
AND OVERSIGHT OF BANA'S ACTIVITIES WITH RESPECT TO THE MORTGAGE ELECTRONIC REGISTRATION SYSTEM AND COMPLIANCE WITH
MERSCORP'S MEMBERSHIP RULES, TERMS, AND CONDITIONS; (B) RETAIN AN INDEPENDENT CONSULTANT TO CONDUCT AN INDEPENDENT REVIEW
OF RESIDENTIAL FORECLOSURE ACTIONS REGARDING INDIVIDUAL BORROWERS; (C) PLAN FOR OPERATION OF MANAGEMENT INFORMATION
SYSTEMS; (D) SUBMIT A PLAN FOR EFFECTIVE COORDINATION OF COMMUNICATIONS WITH BORROWERS RELATED TO LOSS MITIGATION OR LOAN
MODIFICATION AND FORECLOSURE ACTIVITIES; (E) CONDUCT AN ASSESSMENT OF BANA'S RISKS IN MORTGAGE SERVICING OPERATIONS; AND (F)
SUBMIT PERIODIC WRITTEN PROGRESS REPORTS DETAILING THE FORM AND MANNER OF ALL ACTIONS TAKEN TO SECURE COMPLIANCE WITH THE
ORDER.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
BANA SUBMITTED AN OFFER OF SETTLEMENT TO THE OCC. IN THE OFFER OF SETTLEMENT, BANA AGREED TO CONSENT TO THE ENTRY OF THE ORDER,
WITHOUT ADMITTING OR DENYING ANY WRONGDOING. THE ORDER WAS ISSUED ON APRIL 13, 2011, AND MADE THE FINDINGS OF VIOLATIONS
DESCRIBED ABOVE IN ITEM 7. THE SANCTIONS IMPOSED ARE EXPLAINED ABOVE IN ITEM 12.C. ON FEBRUARY 27, 2012, BANA ENTERED INTO AN
AGREEMENT WITH THE OCC, WITHOUT ADMITTING OR DENYING ANY WRONGDOING, TO FORGO THE ASSESSMENT OF CIVIL MONEY PENALTIES AND TO
RELEASE FROM CERTAIN CLAIMS IN THE ORDER SO LONG AS BANA: (A) PROVIDES BORROWERS ASSISTANCE AND CERTAIN PAYMENTS PURSUANT TO A
SETTLEMENT AGREEMENT WITH THE UNITED STATES OF AMERICA, ACTING THROUGH THE UNITED STATES DEPARTMENT OF JUSTICE AND WITH THE
ATTORNEYS GENERAL OF VARIOUS STATES, TO SETTLE CERTAIN POTENTIAL STATE AND FEDERAL CLAIMS RELATING TO BANA'S RESIDENTIAL MORTGAGE
ORIGINATION, SERVICING AND FORECLOSURE PRACTICES; (B) PROVIDES DETAILED REPORTS AND ACCOUNTING FOR THE PAYMENTS DESCRIBED ABOVE;
AND (C) SHALL MAKE AVAILABLE CERTAIN DOCUMENTS ASSOCIATED WITH THE PAYMENTS ABOVE UPON THE REQUEST OF THE OCC. ON JUNE 17, 2015,
THE OCC TERMINATED THIS ORDER AGAINST BANA BECAUSE THE OCC DETERMINED THAT THE PROTECTION OF THE DEPOSITORS, OTHER CUSTOMERS,
AND SHAREHOLDERS OF BANA, AS WELL AS ITS SAFE AND SOUND OPERATION, DOES NOT REQUIRE THE CONTINUED EXISTENCE OF THE ORDER ISSUED
IN APRIL, 2011 AND BANA HAS SATISFIED ALL OF THE REQUIREMENTS OF AN AMENDMENT TO THE ORDER ISSUED IN FEBRUARY, 2013.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)

11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with
a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same
event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BANK OF AMERICA, NATIONAL
ASSOCIATION
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
FIA CARD SERVICES, NATIONAL
ASSOCIATION
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the
IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
CONSUMER FINANCIAL PROTECTION BUREAU
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST; RESTITUTION; UNDERTAKINGS

3.
Date Initiated (MM/DD/YYYY): 
04/07/2014
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2014-CFPB-0004
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
CREDIT PROTECTION AND IDENTITY PROTECTION PRODUCTS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON APRIL 7, 2014, THE CONSUMER FINANCIAL PROTECTION BUREAU ("CFPB") ISSUED A CONSENT ORDER AGAINST BANK OF AMERICA, NATIONAL
ASSOCIATION AND FIA CARD SERVICES, NATIONAL ASSOCIATION. THE ORDER IDENTIFIED DEFICIENCIES IN CONNECTION WITH FULFILLMENT OF
CUSTOMER PROCESSING CONCERNING THE PROVISION OF IDENTITY THEFT PROTECTION PRODUCTS AS WELL AS VENDOR AND RISK MANAGEMENT
PROTOCOLS CONCERNING SO-CALLED "ADD-ON" PRODUCTS. IN ADDITION, THE CFPB IDENTIFIED WHAT IT ALLEGED WERE DECEPTIVE STATEMENTS IN
CONNECTION WITH THE MARKETING AND SALE OF CREDIT CARD DEBT CANCELLATION PRODUCTS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
04/07/2014
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 20,000,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived: 
WITHOUT ADMITTING OR DENYING ANY FINDINGS OF FACT OR VIOLATIONS OF LAW OR WRONGDOING, BANK OF AMERICA, NATIONAL
ASSOCIATION AND FIA CARD SERVICES, NATIONAL ASSOCIATION CONSENTED TO A CIVIL MONETARY PENALTY OF $20,000,000 AND TO CEASE
AND DESIST FROM ENGAGING IN FURTHER VIOLATIONS OF LAW IN CONNECTION WITH THE MARKETING AND ADMINISTRATION OF CREDIT
PROTECTION PRODUCTS AND THE BILLING AND ADMINISTRATION OF IDENTITY PROTECTION PRODUCTS. FURTHER, THE CONSENT ORDER
REQUIRES A RESTITUTION PLAN TO BE SUBMITTED TO THE CFPB AND, FOLLOWING APPROVAL, THE PROVISION OF RESTITUTION TO BORROWERS.
IN ADDITION, THE CONSENT ORDER REQUIRES THE SUBMISSION OF ENHANCED VENDOR MANAGEMENT POLICIES; ENHANCED RISK MANAGEMENT
POLICIES AND PROCEDURES; AND ENHANCED INTERNAL AUDIT REVIEWS OF ADD-ON PRODUCTS TO ASSESS UNFAIR, DECEPTIVE, OR ABUSIVE
ACTS OR PRACTICES ("UDAAP") RISK.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
WITHOUT ADMITTING OR DENYING ANY FINDINGS OF FACT OR VIOLATIONS OF LAW OR WRONGDOING, BANK OF AMERICA, NATIONAL ASSOCIATION AND
FIA CARD SERVICES, NATIONAL ASSOCIATION CONSENTED TO A CIVIL MONETARY PENALTY OF $20,000,000 AND TO CEASE AND DESIST FROM
ENGAGING IN FURTHER VIOLATIONS OF LAW IN CONNECTION WITH THE MARKETING AND ADMINISTRATION OF CREDIT PROTECTION PRODUCTS AND THE
BILLING AND ADMINISTRATION OF IDENTITY PROTECTION PRODUCTS. FURTHER, THE CONSENT ORDER REQUIRES A RESTITUTION PLAN TO BE
SUBMITTED TO THE CFPB AND, FOLLOWING APPROVAL, THE PROVISION OF RESTITUTION TO BORROWERS. IN ADDITION, THE CONSENT ORDER
REQUIRES THE SUBMISSION OF ENHANCED VENDOR MANAGEMENT POLICIES; ENHANCED RISK MANAGEMENT POLICIES AND PROCEDURES; AND
ENHANCED INTERNAL AUDIT REVIEWS OF ADD-ON PRODUCTS TO ASSESS UNFAIR, DECEPTIVE, OR ABUSIVE ACTS OR PRACTICES ("UDAAP") RISK.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with
a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same
event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BANK OF AMERICA, NATIONAL
ASSOCIATION
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
FIA CARD SERVICES, NATIONAL
ASSOCIATION
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the
IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
THE OFFICE OF THE COMPTROLLER OF THE CURRENCY
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
RESTITUTION; UNDERTAKINGS
3.
Date Initiated (MM/DD/YYYY): 
04/07/2014
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
AA-EC-2014-6
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
IDENTITY PROTECTION PRODUCTS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON APRIL 7, 2014, THE COMPTROLLER OF THE CURRENCY OF THE UNITED STATES OF AMERICA ("OCC") ISSUED A CONSENT ORDER AGAINST BANK OF
AMERICA, NATIONAL ASSOCIATION AND FIA CARD SERVICES, NATIONAL ASSOCIATION. THE ORDER IDENTIFIED DEFICIENCIES IN CONNECTION WITH
FULFILLMENT OF CUSTOMER PROCESSING CONCERNING THE PROVISION OF IDENTITY THEFT PROTECTION PRODUCTS AS WELL AS VENDOR AND RISK
MANAGEMENT PROTOCOLS CONCERNING SO-CALLED "ADD-ON" PRODUCTS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
04/07/2014
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 25,000,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived: 
WITHOUT ADMITTING OR DENYING THE FINDINGS, BANK OF AMERICA, NATIONAL ASSOCIATION AND FIA CARD SERVICES, NATIONAL ASSOCIATION
CONSENTED TO A CIVIL MONETARY PENALTY OF $25,000,000. FURTHER, THE CONSENT ORDER REQUIRES A RESTITUTION PLAN TO BE SUBMITTED
TO THE OCC AND, FOLLOWING APPROVAL, THE PROVISION OF RESTITUTION TO BORROWERS. IN ADDITION, THE CONSENT ORDER REQUIRES THE
SUBMISSION OF ENHANCED VENDOR MANAGEMENT POLICIES; ENHANCED RISK MANAGEMENT POLICIES AND PROCEDURES; AND ENHANCED
INTERNAL AUDIT REVIEWS OF ADD-ON PRODUCTS TO ASSESS UNFAIR, DECEPTIVE, OR ABUSIVE ACTS OR PRACTICES ("UDAAP") RISK.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response

must fit within the space provided).
WITHOUT ADMITTING OR DENYING THE FINDINGS, BANK OF AMERICA, NATIONAL ASSOCIATION AND FIA CARD SERVICES, NATIONAL ASSOCIATION
CONSENTED TO A CIVIL MONETARY PENALTY OF $25,000,000. FURTHER, THE CONSENT ORDER REQUIRES A RESTITUTION PLAN TO BE SUBMITTED TO
THE OCC AND, FOLLOWING APPROVAL, THE PROVISION OF RESTITUTION TO BORROWERS. IN ADDITION, THE CONSENT ORDER REQUIRES THE
SUBMISSION OF ENHANCED VENDOR MANAGEMENT POLICIES; ENHANCED RISK MANAGEMENT POLICIES AND PROCEDURES; AND ENHANCED INTERNAL
AUDIT REVIEWS OF ADD-ON PRODUCTS TO ASSESS UNFAIR, DECEPTIVE, OR ABUSIVE ACTS OR PRACTICES ("UDAAP") RISK.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with
a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same
event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BANK OF AMERICA, NATIONAL
ASSOCIATION
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the
IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:

SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
THE COMPTROLLER OF THE CURRENCY OF THE UNITED STATES OF AMERICA
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
REMEDIAL SANCTIONS
3.
Date Initiated (MM/DD/YYYY): 
11/11/2014
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
AA-EC-14-99
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
FOREIGN EXCHANGE
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON NOVEMBER 11, 2014, THE OFFICE OF THE COMPTROLLER OF THE CURRENCY OF THE UNITED STATES OF AMERICA ("OCC") ISSUED A CONSENT
ORDER AND A CONSENT ORDER FOR THE ASSESSMENT OF A CIVIL MONEY PENALTY AGAINST BANK OF AMERICA, N.A. ("BANK OF AMERICA") RELATED TO
ITS FOREIGN EXCHANGE (FX) BUSINESS ("ORDERS") FROM 2008 THROUGH 2013. THE OCC FOUND, AND BANK OF AMERICA NEITHER ADMITTED NOR
DENIED, THAT BANK OF AMERICA HAD DEFICIENCIES IN ITS INTERNAL CONTROLS AND HAD ENGAGED IN UNSAFE OR UNSOUND BANKING PRACTICES
WITH RESPECT TO THE OVERSIGHT AND GOVERNANCE OF BANK OF AMERICA'S FX TRADING BUSINESS SUCH THAT THE BANK FAILED TO DETECT AND
PREVENT CERTAIN CONDUCT. SPECIFICALLY, THE OCC FOUND THAT: A) BANK OF AMERICA'S COMPLIANCE RISK ASSESSMENT LACKED SUFFICIENT
GRANULARITY AND FAILED TO IDENTIFY THE RISKS RELATED TO SALES, TRADING AND SUPERVISORY EMPLOYEES IN THAT BUSINESS ("EMPLOYEE"); B)
BANK OF AMERICA'S TRANSACTION MONITORING AND COMMUNICATIONS SURVEILLANCE LACKED AN ADEQUATE ANALYSIS OF RISK-BEHAVIOR RELATED
TO EMPLOYEE MARKET CONDUCT IN ITS WHOLESALE FOREIGN EXCHANGE BUSINESS WHERE IT IS ACTING AS PRINCIPAL ("FX TRADING"); C) BANK OF
AMERICA'S COMPLIANCE TESTING PROCEDURES WERE INADEQUATE TO MEASURE ADHERENCE TO ITS STANDARDS OF EMPLOYEE CONDUCT AND FIRM
POLICIES APPLICABLE TO EMPLOYEE MARKET CONDUCT IN FX TRADING; AND D) BANK OF AMERICA'S RISK ASSESSMENT AND COVERAGE OF THE FX
TRADING BUSINESS NEEDED IMPROVEMENT TO IDENTIFY AND MITIGATE COMPLIANCE RISKS RELATED TO EMPLOYEE MARKET CONDUCT; E) BANK OF
AMERICA'S CUSTOMER INFORMATION CONTROLS WERE INADEQUATE REGARDING THE WM/REUTERS ORDER BOOK TO PREVENT THE MISUSE OF
CUSTOMER INFORMATION; F) BANK OF AMERICA'S RISK AND PROFITABILITY REPORTING WAS INADEQUATE TO IDENTIFY POTENTIAL EMPLOYEE MARKET
MISCONDUCT IN FX TRADING; AND G) BANK OF AMERICA'S FX BUSINESS SUPERVISION ROUTINES WERE INADEQUATE BECAUSE THEY CREATED "GAPS"
IN THE EMPLOYEE MARKET CONDUCT SUPERVISORY FRAMEWORK.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
11/11/2014
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 250,000,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
REMEDIAL ACTIONS
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to

requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived: 
THE SETTLEMENT RESULTED IN THE OCC ISSUING THE ORDERS FINDING THAT BANK OF AMERICA HAD DEFICIENCIES IN ITS INTERNAL CONTROLS
AND HAD ENGAGED IN UNSAFE OR UNSOUND BANKING PRACTICES WITH RESPECT TO THE OVERSIGHT AND GOVERNANCE OF BANK OF AMERICA'S
FX TRADING BUSINESS SUCH THAT THE BANK FAILED TO DETECT AND PREVENT CERTAIN CONDUCT. BANK OF AMERICA NEITHER ADMITTED NOR
DENIED THE FINDINGS. IN THE ORDERS, BANK OF AMERICA AGREED TO MAKE A PAYMENT OF A CIVIL MONEY PENALTY IN THE TOTAL AMOUNT OF
$250 MILLION. THE PAYMENT WAS MADE ON NOVEMBER 17, 2014. ALSO, BANK OF AMERICA COMMITTED (AND HAD ALREADY BEGUN) TAKING ALL
NECESSARY AND APPROPRIATE STEPS TO REMEDY THE DEFICIENCIES AND UNSAFE OR UNSOUND PRACTICES IDENTIFIED BY THE OCC AND HAS
BEGUN IMPLEMENTING PROCEDURES TO REMEDIATE THE PRACTICES ADDRESSED IN THE ORDERS. SPECIFICALLY, BANK OF AMERICA AGREED TO:
A) MAINTAIN A BOARD COMPLIANCE COMMITTEE RESPONSIBLE FOR MONITORING AND COORDINATING BANK OF AMERICA'S COMPLIANCE WITH
THE PROVISIONS IN THE ORDERS; B) SUBMIT TO THE OCC AN ACTION PLAN DESCRIBING THE ACTIONS THAT ARE NECESSARY AND APPROPRIATE
TO ACHIEVE COMPLIANCE WITH CERTAIN ASPECTS OF THE ORDERS; C) SUBMIT AN ACCEPTABLE OVERSIGHT AND GOVERNANCE WRITTEN PLAN TO
PROVIDE FOR CERTAIN MANAGEMENT OVERSIGHT AND GOVERNANCE RELATING TO EMPLOYEE MARKET CONDUCT IN FX TRADING; D) SUBMIT AN
ACCEPTABLE COMPLIANCE RISK ASSESSMENT WRITTEN PLAN TO PROVIDE FOR A COMPLIANCE RISK ASSESSMENT SUFFICIENTLY GRANULAR TO
IDENTIFY RISKS RELATED TO EMPLOYEE MARKET CONDUCT IN FX TRADING; E) SUBMIT AN ACCEPTABLE MONITORING AND SURVEILLANCE WRITTEN
PLAN TO PROVIDE FOR APPROPRIATE MONITORING AND COMMUNICATIONS SURVEILLANCE RELATED TO EMPLOYEE MARKET CONDUCT IN FX
TRADING; F) SUBMIT AN ACCEPTABLE COMPLIANCE TESTING WRITTEN PLAN TO PROVIDE FOR APPROPRIATE COMPLIANCE TESTING RELATED TO
EMPLOYEE MARKET CONDUCT IN FX TRADING; (CONTINUED IN 13 BELOW)
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
(CONTINUED FROM 12.C. ABOVE) G) SUBMIT AN ACCEPTABLE INTERNAL AUDIT WRITTEN PLAN FOR THE INTERNAL AUDIT PROGRAM TO ADEQUATELY
ADDRESS EMPLOYEE MARKET CONDUCT IN FX TRADING; AND H) SUBMIT AN ACCEPTABLE OTHER TRADING ACTIVITIES WRITTEN PLAN TO ENSURE THAT
BANK OF AMERICA PROACTIVELY USES A RISK-BASED APPROACH TO APPLY EMPLOYEE MARKET CONDUCT REMEDIAL MEASURES IN THE ORDERS TO
OTHER WHOLESALE TRADING AS PRINCIPAL FOR THE BANK OF AMERICA AND BENCHMARK ACTIVITIES AS APPROPRIATE AND DEFINED IN THE BANK OF
AMERICA'S WRITTEN PLAN. [ITEM 13 SUMMARY] IN SETTLEMENT OF THIS MATTER, BANK OF AMERICA CONSENTED AND AGREED TO THE ISSUANCE OF
THE ORDERS, WHICH THE OCC HAS DETERMINED TO ACCEPT AND HAS ISSUED. THE ALLEGATIONS, DISPOSITIONS, FINDINGS AND SANCTIONS OF THE
ORDERS ARE DESCRIBED ABOVE IN ITEMS 7 AND 12.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with
a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same
event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BANK OF AMERICA, NATIONAL
ASSOCIATION
(For individuals, Last, First,
Middle)

This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the
IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
COMPTROLLER OF THE CURRENCY
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST; REMEDIAL ACTIONS
3.
Date Initiated (MM/DD/YYYY): 
05/29/2015
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
AA-EC-2015-1 AND AA-EC-2015-2
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON MAY 29, 2015, THE COMPTROLLER OF THE CURRENCY ("OCC") ISSUED AN ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF A CIVIL
MONEY PENALTY (TOGETHER, THE "ORDERS") AGAINST BANK OF AMERICA, N.A. ("BANA") RELATING TO THE SERVICEMEMBERS CIVIL RELIEF ACT ("SCRA")
AND BANA'S SWORN DOCUMENT AND COLLECTIONS LITIGATION PRACTICES. IN THE ORDERS, THE OCC IDENTIFIED (I) UNSAFE OR UNSOUND PRACTICES
IN CONNECTION WITH BANA'S EFFORTS TO COMPLY WITH THE SCRA, (II) SCRA VIOLATIONS, AND (III) UNSAFE OR UNSOUND PRACTICES IN
CONNECTION WITH BANA'S SWORN DOCUMENT AND COLLECTIONS LITIGATION PRACTICES. REGARDING THE SCRA, THE ORDERS STATED BANA FAILED
TO HAVE EFFECTIVE POLICIES AND PROCEDURES TO ENSURE COMPLIANCE WITH SCRA; FAILED TO DEVOTE SUFFICIENT FINANCIAL, STAFFING, AND
MANAGERIAL RESOURCES TO ENSURE PROPER ADMINISTRATION OF ITS SCRA COMPLIANCE PROCESSES; FAILED TO DEVOTE TO ITS SCRA COMPLIANCE
PROCESSES ADEQUATE INTERNAL CONTROLS, COMPLIANCE RISK MANAGEMENT, INTERNAL AUDIT, THIRD PARTY MANAGEMENT, AND TRAINING; AND
ENGAGED IN VIOLATIONS OF THE SCRA. REGARDING THE SWORN DOCUMENT AND COLLECTIONS LITIGATION PROCESS, THE ORDERS STATED THAT BANA
FILED OR CAUSED TO BE FILED IN COURTS AFFIDAVITS EXECUTED BY ITS EMPLOYEES OR EMPLOYEES OF THIRD PARTY SERVICE PROVIDERS MAKING
ASSERTIONS THAT, IN MANY CASES, WERE NOT BASED ON PERSONAL KNOWLEDGE OR REVIEW OF RELEVANT BOOKS AND RECORDS; FILED OR CAUSED
TO BE FILED IN COURT AFFIDAVITS WHEN BANA DID NOT FOLLOW PROPER NOTARY PROCEDURES; FAILED TO DEVOTE SUFFICIENT FINANCIAL,
STAFFING, AND MANAGERIAL RESOURCES TO ENSURE PROPER ADMINISTRATION OF ITS SWORN DOCUMENT AND COLLECTIONS LITIGATION PROCESSES;
AND FAILED TO SUFFICIENTLY OVERSEE OUTSIDE COUNSEL AND OTHER THIRD-PARTY PROVIDERS HANDLING SWORN DOCUMENT AND COLLECTIONS
LITIGATION SERVICES.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:

Settled
11. Resolution Date (MM/DD/YYYY):
05/29/2015
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 30,000,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
REMEDIAL ACTIONS
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived: 
IN THE ORDERS, BANA AGREED TO PAY A CIVIL MONEY PENALTY IN THE TOTAL AMOUNT OF $30 MILLION, HAS BEGUN CORRECTIVE ACTION, AND IS
COMMITTED TO TAKING ALL NECESSARY AND APPROPRIATE STEPS TO REMEDY THE DEFICIENCIES, UNSAFE OR UNSOUND PRACTICES, AND
VIOLATIONS OF LAW IDENTIFIED BY THE OCC, AND TO ENHANCE ITS SCRA COMPLIANCE PRACTICES AND SWORN DOCUMENT AND COLLECTIONS
LITIGATION PRACTICES. SPECIFICALLY, BANA AGREED TO: (A) APPOINT AND MAINTAIN A COMPLIANCE COMMITTEE TO MONITOR AND OVERSEE
BANA'S COMPLIANCE WITH THE ORDERS AND TO APPROVE MEASURES TO ENSURE COMPLIANCE; (B) SUBMIT AN ACCEPTABLE PLAN CONTAINING A
COMPLETE DESCRIPTION OF THE ACTIONS TO ACHIEVE COMPLIANCE WITH THE ORDERS; (C) SUBMIT A WRITTEN PLAN TO EFFECTIVELY
IMPLEMENT AN ENTERPRISE-WIDE COMPLIANCE RISK MANAGEMENT PROGRAM REGARDING COMPLIANCE WITH ALL APPLICABLE LAWS,
REGULATIONS, AND REGULATORY GUIDANCE; (D) CONDUCT A WRITTEN, COMPREHENSIVE ASSESSMENT OF ITS RISK IN SCRA COMPLIANCE
OPERATIONS, INCLUDING BUT NOT LIMITED TO, OPERATIONAL, COMPLIANCE, LEGAL, AND REPUTATIONAL RISKS; (E) SUBMIT ACCEPTABLE
WRITTEN PLANS TO ENSURE ITS COMPLIANCE WITH THE SCRA AND WITH REGARD TO COLLECTIONS LITIGATION; (F) SUBMIT PLANS TO CONDUCT
A SCRA REVIEW AND A COLLECTIONS LITIGATION REVIEW OF ACCOUNTS, SCRA AND COLLECTIONS LITIGATION REMEDIATION, AND SCRA
INTERNAL AUDIT; (G) SUBMIT POLICIES AND PROCEDURES FOR SCRA THIRD PARTY MANAGEMENT AND IMPROVEMENTS TO ITS MANAGEMENT
INFORMATION SYSTEMS FOR SCRA COMPLIANCE ACTIVITIES, AND TO PROVIDE CERTAIN REPORTS TO THE COMPLIANCE COMMITTEE; (H) SUBMIT
WRITTEN PLANS, PROGRAMS, POLICIES, AND PROCEDURES REQUIRED BY THE ORDERS; AND (I) SUBMIT A WRITTEN PROGRESS REPORT DEALING
THE FORM AND MANNER OF ALL ACTIONS TAKEN TO SECURE COMPLIANCE WITH THE PROVISION OF THE ORDERS AND THE RESULTS THEREOF.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
IN SETTLEMENT OF THIS MATTER, BANA CONSENTED AND AGREED TO THE ISSUANCE OF THE ORDERS, WHICH THE OCC HAS DETERMINED TO ACCEPT
AND HAS ISSUED. BANA NEITHER ADMITS NOR DENIES THE FINDINGS IN THE ORDERS. THE ALLEGATIONS, DISPOSITIONS, FINDINGS AND SANCTIONS OF
THE ORDERS ARE DESCRIBED ABOVE IN ITEMS 7 AND 12.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with
a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same
event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates

If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BANK OF AMERICA, NATIONAL
ASSOCIATION
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the
IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
THE OFFICE OF THE COMPTROLLER OF THE CURRENCY
2.
Principal Sanction:
Restitution
Other Sanctions: 
UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
12/07/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
#2010-239
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Derivative(s)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE COMPTROLLER OF THE CURRENCY (THE "COMPTROLLER") EXAMINED CERTAIN ACTIVITIES RELATED TO THE PARTICIPATION OF CERTAIN BANK OF
AMERICA, NATIONAL ASSOCIATION (THE "BANK") EMPLOYEES IN THE SALE OF CERTAIN DERIVATIVE FINANCIAL PRODUCTS TO MUNICIPALITIES AND
NON-PROFIT ORGANIZATIONS, AND REVIEWED INFORMATION INDICATING THAT CERTAIN BANK EMPLOYEES ENGAGED IN ILLEGAL BIDDING ACTIVITY
RELATED TO THE SALE OF THOSE DERIVATIVE FINANCIAL PRODUCTS VARIOUSLY BETWEEN 1998 AND JANUARY 2004. FOLLOWING THE REVIEW, THE
BANK AND THE COMPTROLLER ENTERED INTO A FORMAL WRITTEN AGREEMENT TO ENSURE THAT THE BANK PROACTIVELY AND APPROPRIATELY MANAGES
ITS COMPLIANCE RISK RELATED TO VARIOUS COMPETITIVELY BID TRANSACTIONS, INCLUDING THOSE RELATED TO DERIVATIVE FINANCIAL PRODUCTS
TO MUNICIPALITIES AND NON-PROFIT ORGANIZATIONS.
8.
Current Status?      
 Pending
 On Appeal
 Final

9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
12/07/2010
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PAYMENT OF UNJUST ENRICHMENT IN THE AMOUNT OF $9,217,218 AND UNDERTAKING
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived: 
THE BANK HAS ENTERED INTO A WRITTEN AGREEMENT ON DECEMBER 7, 2010, WITH THE COMPTROLLER OF THE CURRENCY. UNDER THE TERMS OF
THE WRITTEN AGREEMENT, THE BANK AGREED TO INSTITUTE AND/OR CONTINUE CERTAIN POLICIES AND PROCEDURES, INCLUDING COMPLIANCE,
TRAINING AND AUDIT PROGRAMS, RELATING TO COMPETITIVELY BID TRANSACTIONS FOR THE SALE OF DERIVATIVE FINANCIAL PRODUCTS TO
MUNICIPALITIES AND NON-PROFIT ORGANIZATIONS THAT ARE INTENDED TO INVEST OR RE-INVEST THE PROCEEDS OF BONDS ISSUED BY THESE
ORGANIZATIONS OR TO MANAGE OR TRANSFER THE INTEREST RATES OF BONDS ISSUED BY THE ORGANIZATIONS. IN ADDITION, THE BANK AGREED
TO DO A FORMAL ASSESSMENT OF ALL BUSINESS LINES THAT ENGAGE IN CERTAIN TYPES OF COMPETITIVELY BID TRANSACTIONS, TO COMPLETE A
FORMAL EVALUATION OF THE OPERATIONAL POLICIES AND PROCEDURES APPLICABLE TO SUCH BUSINESSES TO ENSURE THAT ADEQUATE
POLICIES AND PROCEDURES EXIST TO ENSURE COMPLIANCE WITH SAFE AND SOUND BANKING PRACTICES, LAW, AND REGULATIONS RELATED TO
THE COMPETITIVELY BID TRANSACTIONS, AND TO DEVELOP AN INTERNAL TRAINING PROGRAM TO ENSURE COMPLIANCE WITH ALL LAWS AND
REGULATIONS RELATED TO COMPETITIVELY BID TRANSACTIONS. UPON APPROVAL BY THE COMPTROLLER, THE BANK MUST IMMEDIATELY BEGIN TO
IMPLEMENT THE POLICIES, PROCEDURES AND PROGRAMS CALLED FOR BY THE AGREEMENT. FINALLY, THE BANK AGREED TO PAY UNJUST
ENRICHMENT IN THE AMOUNT OF $9,217,218 TO CERTAIN COUNTERPARTIES INDENTIFIED BY THE COMPTROLLER.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
THE BANK HAS ENTERED INTO A WRITTEN AGREEMENT ON DECEMBER 7, 2010, WITH THE COMPTROLLER OF THE CURRENCY. UNDER THE TERMS OF THE
WRITTEN AGREEMENT, THE BANK AGREED TO INSTITUTE AND/OR CONTINUE CERTAIN POLICIES AND PROCEDURES, INCLUDING COMPLIANCE, TRAINING
AND AUDIT PROGRAMS, RELATING TO COMPETITIVELY BID TRANSACTIONS FOR THE SALE OF DERIVATIVE FINANCIAL PRODUCTS TO MUNICIPALITIES AND
NON-PROFIT ORGANIZATIONS THAT ARE INTENDED TO INVEST OR RE-INVEST THE PROCEEDS OF BONDS ISSUED BY THESE ORGANIZATIONS OR TO
MANAGE OR TRANSFER THE INTEREST RATES OF BONDS ISSUED BY THE ORGANIZATIONS. IN ADDITION, THE BANK AGREED TO DO A FORMAL
ASSESSMENT OF ALL BUSINESS LINES THAT ENGAGE IN CERTAIN TYPES OF COMPETITIVELY BID TRANSACTIONS, TO COMPLETE A FORMAL EVALUATION
OF THE OPERATIONAL POLICIES AND PROCEDURES APPLICABLE TO SUCH BUSINESSES TO ENSURE THAT ADEQUATE POLICIES AND PROCEDURES EXIST
TO ENSURE COMPLIANCE WITH SAFE AND SOUND BANKING PRACTICES, LAW, AND REGULATIONS RELATED TO THE COMPETITIVELY BID TRANSACTIONS,
AND TO DEVELOP AN INTERNAL TRAINING PROGRAM TO ENSURE COMPLIANCE WITH ALL LAWS AND REGULATIONS RELATED TO COMPETITIVELY BID
TRANSACTIONS. UPON APPROVAL BY THE COMPTROLLER, THE BANK MUST IMMEDIATELY BEGIN TO IMPLEMENT THE POLICIES, PROCEDURES AND
PROGRAMS CALLED FOR BY THE AGREEMENT. FINALLY, THE BANK AGREED TO PAY UNJUST ENRICHMENT IN THE AMOUNT OF $9,217,218 TO CERTAIN
COUNTERPARTIES INDENTIFIED BY THE COMPTROLLER.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with
a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same
event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BANK OF AMERICA, NA
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the
IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
COMPTROLLER OF THE CURRENCY
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST; REMEDIAL ACTIONS
3.
Date Initiated (MM/DD/YYYY): 
06/29/2015
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
AA-EC-2015-18 AND AA-EC-2015-19
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 

7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON JUNE 29, 2015, THE COMPTROLLER OF THE CURRENCY ("OCC") ISSUED A CONSENT ORDER AND A CONSENT ORDER FOR A CIVIL MONEY PENALTY
(TOGETHER, THE "ORDERS") AGAINST BANK OF AMERICA, N.A. ("BANA") RELATING TO THE BANA'S PRACTICES THAT RESULTED IN VIOLATIONS OF THE
NATIONAL FLOOD INSURANCE ACT OF 1968, AS AMENDED, AND THE FLOOD DISASTER PROTECTION ACT OF 1973, AS AMENDED (COLLECTIVELY,
"FDPA"), 42 U.S.C. § 4001, ET SEQ., AND THEIR IMPLEMENTING REGULATIONS. SPECIFICALLY, THE OCC FOUND THAT, SINCE AT LEAST 2011, BANA
VIOLATED 42 U.S.C. § 4012A(E) (PLACEMENT OF FLOOD INSURANCE BY LENDER) AND 12 C.F.R. §§ 22.3 (REQUIREMENT TO PURCHASE FLOOD
INSURANCE WHERE AVAILABLE) AND 22.9 (NOTICE OF SPECIAL FLOOD HAZARDS AND AVAILABILITY OF FEDERAL DISASTER RELIEF ASSISTANCE) IN
MAKING, INCREASING, EXTENDING, RENEWING, AND/OR SERVICING "DESIGNATED LOANS" (LOANS SECURED BY BUILDINGS OR MOBILE HOMES LOCATED
IN SPECIAL FLOOD HAZARD AREAS IN WHICH FLOOD INSURANCE IS AVAILABLE UNDER THE NATIONAL FLOOD INSURANCE ACT OF 1968). THE OCC
FOUND THAT THESE VIOLATIONS RESULTED FROM DEFICIENT POLICIES, PROCEDURES, AND PROCESSES AND AN INEFFECTIVE FDPA COMPLIANCE
PROGRAM.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
06/29/2015
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 1,104,530.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
REMEDIAL ACTIONS
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived: 
IN THE ORDERS, BANA AGREED TO PAY A CIVIL MONEY PENALTY IN THE TOTAL AMOUNT OF $1,104,530.00, WHICH WAS PAID ON JULY 1, 2015,
AND HAS AGREED TO CERTAIN REMEDIAL ACTIONS. SPECIFICALLY, BANA AGREED TO: (A) APPOINT AND MAINTAIN A COMPLIANCE COMMITTEE TO
MONITOR AND OVERSEE BANA'S COMPLIANCE WITH THE ORDERS AND TO APPROVE MEASURES TO ENSURE COMPLIANCE; (B) SUBMIT AN
ACCEPTABLE PLAN CONTAINING A COMPLETE DESCRIPTION OF THE ACTIONS TO ACHIEVE COMPLIANCE WITH THE ORDERS; (C) SUBMIT A
WRITTEN PLAN TO EFFECTIVELY IMPLEMENT AN ENTERPRISE-WIDE PROGRAM TO ENSURE BANA'S COMPLIANCE WITH THE FDPA, ITS
IMPLEMENTING REGULATIONS, AND FDPA-RELATED REGULATORY GUIDANCE; (D) SUBMIT POLICIES AND PROCEDURES FOR OUTSOURCING FDPA
COMPLIANCE FUNCTIONS TO ANY AGENT, INDEPENDENT CONTRACTOR, CONSULTING FIRM, LAW FIRM, OR OTHER THIRD-PARTY (INCLUDING ANY
AFFILIATE OF BANA); (E) DEVELOP A COMPREHENSIVE WRITTEN FDPA COMPLIANCE AUDIT PROGRAM; AND (F) SUBMIT THE WRITTEN PLANS,
PROGRAMS, POLICIES, AND PROCEDURES REQUIRED BY THE ORDERS FOR REVIEW AND DETERMINATION OF NO SUPERVISORY OBJECT WITHIN A
SPECIFIC TIME.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
IN SETTLEMENT OF THIS MATTER, BANA CONSENTED AND AGREED TO THE ISSUANCE OF THE ORDERS, WHICH THE OCC HAS DETERMINED TO ACCEPT
AND HAS ISSUED. BANA NEITHER ADMITS NOR DENIES THE FINDINGS IN THE ORDERS. THE ALLEGATIONS, DISPOSITIONS, FINDINGS AND SANCTIONS OF
THE ORDERS ARE DESCRIBED ABOVE IN ITEMS 7 AND 12.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)

11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with
a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same
event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BANK OF AMERICA, NATIONAL
ASSOCIATION
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the
IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
BANGKO SENTRAL NG PILIPINAS
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
09/26/2017
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
NONE
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6.
Principal Product Type:
Other
Other Product Types: 
FOREIGN EXCHANGE TRANSACTIONS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE BANGKO SENTRAL NG PILIPINAS (BS") APPROVED THE IMPOSITION OF A MONETARY PENALTY ON THE FIRM FOR THE FOLLOWING VIOLATIONS OF
THE MANUAL OF REGULATIONS ON FOREIGN EXCHANGE TRANSACTIONS: DEFICIENCY IN E/FOREIGN CURRENCY DEPOSIT UNIT (FCDU) ASSET COVER
REQUIREMENT, FALSE/ERRONEOUS CERTIFICATION OF COMPLIANCE WITH E/FCDU COVER AND BREACH ON THE CAP ON ALLOWABLE LENDING OF FCDU
FUNDS TO REGULAR BANKING UNITS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Other
11. Resolution Date (MM/DD/YYYY):
10/12/2017
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 1,306,930.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
THE MONETARY BOARD IMPOSED A PENALTY IN THE AMOUNT OF PHP67,303,484.29 (APPROX. USD1,306,930) ON THE FIRM.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived: 
THE MONETARY BOARD IMPOSED A PENALTY IN THE AMOUNT OF PHP67,303,484.29 (APPROX. USD1,306,930) ON THE FIRM. PURSUANT TO THE
BSP'S RULES, THE FIRM'S DEMAND DEPOSIT ACCOUNT WITH THE BSP SHALL BE AUTOMATICALLY DEBITED THE ABOVE REFERENCED AMOUNT UPON
THE LAPSE OF FIFTEEN CALENDAR DAYS FROM RECEIPT OF THE FINAL BILLING LETTER. THEREFORE, THE AMOUNT MAY BE DEBITED NO EARLIER
THAN OCTOBER 12, 2017.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
THE MONETARY BOARD IMPOSED A PENALTY IN THE AMOUNT OF PHP67,303,484.29 (APPROX. USD1,306,930) ON THE FIRM. PURSUANT TO THE BSP'S
RULES, THE FIRM'S DEMAND DEPOSIT ACCOUNT WITH THE BSP SHALL BE AUTOMATICALLY DEBITED THE ABOVE REFERENCED AMOUNT UPON THE LAPSE
OF FIFTEEN CALENDAR DAYS FROM RECEIPT OF THE FINAL BILLING LETTER. THEREFORE, THE AMOUNT MAY BE DEBITED NO EARLIER THAN OCTOBER 12,
2017.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with

a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same
event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BANK OF AMERICA, NATIONAL
ASSOCIATION
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the
IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
OFFICE OF ANTIBOYCOTT COMPLIANCE, BUREAU OF INDUSTRY AND SECURITY, U.S. DEPARTMENT OF COMMERCE
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
11/13/2017
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CASE NO. 16-03
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 

7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE OFFICE OF ANTIBOYCOTT COMPLIANCE, BUREAU OF INDUSTRY AND SECURITY, U.S. DEPARTMENT OF COMMERCE ("BIS") ALLEGED, AS SET FORTH IN
A PROPOSED CHARGING LETTER, THAT BANK OF AMERICA N.A. ("BOFA"), ON THIRTEEN OCCASIONS, VIOLATED THE EXPORT ADMINISTRATION
REGULATIONS (CURRENTLY CODIFIED AT 15 C.F.R. 730-774 (2017) ("REGULATIONS"), WHICH ARE ISSUED UNDER THE AUTHORITY OF THE EXPORT
ADMINISTRATION ACT OF 1979, AS AMENDED. THE ALLEGATIONS WERE RESOLVED PURSUANT TO A SETTLEMENT AGREEMENT BETWEEN BIS AND BOFA.
UNDER THE SETTLEMENT AGREEMENT, BIS ENTERED AN ORDER IMPOSING A CIVIL PENALTY, BUT DID NOT INITIATE ANY ADMINISTRATIVE OR JUDICIAL
PROCEEDING OR MAKE A REFERRAL TO THE DEPARTMENT OF JUSTICE FOR CRIMINAL PROCEEDINGS AGAINST BOFA WITH RESPECT TO SECTION 8 OF
THE EXPORT ADMINISTRATION ACT OR PART 760 OF THE REGULATIONS. NO FINDINGS OF VIOLATIONS WERE MADE.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
11/13/2017
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 44,625.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
N/A
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived: 
PURSUANT TO THE SETTLEMENT AGREEMENT BETWEEN BOFA AND BIS, BIS ISSUED AN ORDER IMPOSING A CIVIL MONEY PENALTY OF $44,625 ON
BOFA. NO FINDINGS OF VIOLATIONS WERE MADE AND NO OTHER SANCTIONS WERE IMPOSED ON BOFA.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
BOFA ENTERED INTO A SETTLEMENT AGREEMENT WITH BIS. THE SETTLEMENT AGREEMENT RESOLVED ALLEGATIONS BY THE BIS THAT BOFA, ON
THIRTEEN OCCASIONS, VIOLATED THE EXPORT ADMINISTRATION REGULATIONS (CURRENTLY CODIFIED AT 15 C.F.R. 730-774 (2017) ("REGULATIONS"),
WHICH ARE ISSUED UNDER THE AUTHORITY OF THE EXPORT ADMINISTRATION ACT OF 1979, AS AMENDED. UNDER THE SETTLEMENT AGREEMENT, BIS
ENTERED AN ORDER IMPOSING A CIVIL PENALTY, BUT DID NOT INITIATE ANY ADMINISTRATIVE OR JUDICIAL PROCEEDING OR MAKE A REFERRAL TO THE
DEPARTMENT OF JUSTICE FOR CRIMINAL PROCEEDINGS AGAINST BOFA WITH RESPECT TO SECTION 8 OF THE EXPORT ADMINISTRATION ACT OR PART
760 OF THE REGULATIONS. NO FINDINGS OF VIOLATIONS WERE MADE.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with
a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same

event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BANK OF AMERICA, NATIONAL
ASSOCIATION
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the
IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
SECURITIES AND EXCHANGE COMMISSION OF THE REPUBLIC OF THE PHILIPPINES
2.
Principal Sanction:
Suspension
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
11/28/2017
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
N/A
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE SECURITIES AND EXCHANGE COMMISSION OF THE PHILIPPINES ("PHILIPPINES SEC") ALLEGED THAT THE FIRM DID NOT MEET CERTAIN REPORTING
REQUIREMENTS IN THE PHILIPPINES REGARDING ITS REGIONAL AREA HEADQUARTERS ("RHQ"), WHICH HAD NOT ENGAGED IN ANY OPERATIONS IN THE

PHILIPPINES FOR DECADES AND DID NOT PLAN TO ENGAGE IN ANY OPERATIONS IN THE PHILIPPINES IN THE FUTURE.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
11/28/2017
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
N/A
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived: 
THE PHILIPPINES SEC SUSPENDED THE FIRM'S RHQ LICENSE TO TRANSACT BUSINESS IN THE PHILIPPINES.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
AN RHQ IS A SPECIAL TYPE OF "BRANCH" WHOSE AUTHORIZED ACTIVITIES ARE LIMITED TO ACTING AS AN ADMINISTRATIVE BRANCH OF A
MULTINATIONAL COMPANY ENGAGED IN INTERNATIONAL TRADE AND PRINCIPALLY SERVES AS A SUPERVISION, COMMUNICATIONS AND COORDINATION
CENTER FOR ITS SUBSIDIARIES, BRANCHES OR AFFILIATES IN THE ASIA-PACIFIC REGION AND OTHER FOREIGN MARKETS. THE FIRM'S RHQ HAD BEEN
DORMANT FOR DECADES AND DID NOT ENGAGE IN ANY SECURITIES ACTIVITIES. AS A MEANS TO DEREGISTER THE RHQ, THE FIRM REQUESTED THAT THE
PHILIPPINES SEC SUSPEND ITS LICENSE AND THE PHILIPPINES SEC GRANTED THE FIRM'S REQUEST.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with
a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same
event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates

If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BANK OF AMERICA
CORPORATION
(For individuals, Last, First,
Middle)
CRD
Number:
7691
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
MERRILL LYNCH, PIERCE,
FENNER & SMITH
INCORPORATED
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the
IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
ATTORNEY GENERAL OF THE STATE OF NEW YORK INVESTOR PROTECTION BUREAU
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
AGREEMENT NOT TO ENGAGE, OR ATTEMPT TO ENGAGE, IN CONDUCT IN VIOLATION OF ANY APPLICABLE LAWS, AGREEMENT TO PROVIDE CERTAIN
MATERIALS TO THE NYAG
3.
Date Initiated (MM/DD/YYYY): 
03/22/2018
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
AGREEMENT NO. 18-025
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):

THE ATTORNEY GENERAL OF THE STATE OF NEW YORK INVESTOR PROTECTION BUREAU ALLEGED THAT BANK OF AMERICA CORPORATION (BAC) AND THE
FIRM (1) CONCEALED FROM ITS INSTITUTIONAL CLIENTS THAT ORDERS WERE ROUTED TO AND EXECUTED BY "ELECTRONIC LIQUIDITY PROVIDERS," (2)
MISSTATED THE COMPOSITION OF ORDERS AND TRADES IN ITS DARK POOL, AND (3) DID NOT ACCURATELY DESCRIBE ITS USE OF A PROPRIETARY
"VENUE RANKING" ANALYSIS, IN VIOLATION OF THE MARTIN ACT AND EXECUTIVE LAW § 63(12).
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
03/22/2018
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 42,000,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
AGREEMENT NOT TO ENGAGE, OR ATTEMPT TO ENGAGE, IN CONDUCT IN VIOLATION OF ANY APPLICABLE LAWS, AGREEMENT TO PROVIDE CERTAIN
MATERIALS TO THE NYAG
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived: 
IN CONNECTION WITH THE AGREEMENT, BOFAML AGREED (1) NOT TO ENGAGE, OR ATTEMPT TO ENGAGE, IN CONDUCT IN VIOLATION OF ANY
APPLICABLE LAWS, INCLUDING BUT NOT LIMITED TO THE MARTIN ACT AND EXECUTIVE LAW § 63(12); (2) TO PAY A PENALTY IN THE AMOUNT OF
$42,000,000; AND (3) PROVIDE THE NYAG A SUMMARY OF THE REVIEW OF ITS ELECTRONIC TRADING POLICIES AND PROCEDURES.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
IN CONNECTION WITH THE AGREEMENT, BOFAML AGREED (1) NOT TO ENGAGE, OR ATTEMPT TO ENGAGE, IN CONDUCT IN VIOLATION OF ANY
APPLICABLE LAWS, INCLUDING BUT NOT LIMITED TO THE MARTIN ACT AND EXECUTIVE LAW § 63(12); (2) TO PAY A PENALTY IN THE AMOUNT OF
$42,000,000; AND (3) PROVIDE THE NYAG A SUMMARY OF THE REVIEW OF ITS ELECTRONIC TRADING POLICIES AND PROCEDURES.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with
a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same
event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BANK OF AMERICA
CORPORATION
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the
IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
BUNDESANSTALT FUR FINANZDIENSTLEISTUNGSAUFSICHT (BAFIN)
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
FEE FOR COSTS OF PROCEEDING
3.
Date Initiated (MM/DD/YYYY): 
04/23/2018
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
N/A
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE BAFIN ALLEGED THAT NECESSARY AND REASONABLE SUPERVISORY AND ORGANIZATIONAL MEASURES WHICH COULD HAVE ENSURED THE CORRECT
AND COMPLETE SUBMISSION OF VOTING RIGHTS NOTIFICATIONS WITHIN THE TIME STIPULATED WERE NOT TAKEN ON TIME OR TO THE ADEQUATE
EXTENT BY THE COMPANY CONCERNED, WHICH LED TO VIOLATIONS OF VOTING RIGHTS NOTIFICATION REQUIREMENTS.
8.
Current Status?      
 Pending
 On Appeal
 Final

9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Other
11. Resolution Date (MM/DD/YYYY):
05/14/2018
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 1,635,872.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
THE BAFIN IMPOSED A FINE ON THE FIRM IN THE AMOUNT OF EUR 1,340,000/USD 1,635,872 AND A FEE FOR COSTS OF THE PROCEEDING IN THE
AMOUNT OF EUR 7,500/USD 9,156.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived: 
THE BAFIN IMPOSED A FINE ON THE FIRM IN THE AMOUNT OF EUR 1,340,000/USD 1,635,872 AND A FEE FOR COSTS OF THE PROCEEDING IN THE
AMOUNT OF EUR 7,500/USD 9,156. THE EFFECTIVE DATE OF THE NOTICE IS TWO WEEKS AFTER THE DELIVERY OF THE NOTICE - DURING WHICH
TIME THE FIRM CAN APPEAL THE NOTICE. THE FIRM DID NOT APPEAL THE NOTICE AND THE NOTICE BECAME EFFECTIVE ON MAY 14, 2018.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
THE BAFIN IMPOSED A FINE ON THE FIRM IN THE AMOUNT OF EUR 1,340,000/USD 1,635,872 AND A FEE FOR COSTS OF THE PROCEEDING IN THE
AMOUNT OF EUR 7,500/USD 9,156. THE EFFECTIVE DATE OF THE NOTICE IS TWO WEEKS AFTER THE DELIVERY OF THE NOTICE - DURING WHICH TIME
THE FIRM CAN APPEAL THE NOTICE. THE FIRM DID NOT APPEAL THE NOTICE AND THE NOTICE BECAME EFFECTIVE ON MAY 14, 2018.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with
a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same
event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.

ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BANK OF AMERICA, NATIONAL
ASSOCIATION
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the
IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
U.S. COMMODITY FUTURES TRADING COMMISSION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST; UNDERAKING
3.
Date Initiated (MM/DD/YYYY): 
09/19/2018
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CFTC DOCKET NO. 18-34
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
U.S. DOLLAR INTERNATIONAL SWAPS AND DERIVATIVES ASSOCIATION FIX
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE U.S. COMMODITY FUTURES TRADING COMMISSION (CFTC) ALLEGED THAT, ON OCCASION FROM JANUARY 2007 THROUGH DECEMBER 2012, THE
FIRM, BY AND THROUGH CERTAIN OF ITS TRADERS, ATTEMPTED TO MANIPULATE THE U.S. DOLLAR INTERNATIONAL SWAPS AND DERIVATIVES
ASSOCIATION FIX (USD ISDAFIX), A BENCHMARK RELATED TO INTEREST-RATE PRODUCTS, TO BENEFIT THE FIRM'S DERIVATIVES POSITIONS IN
VIOLATION OF SECTION 9(A)(2) OF THE COMMODITY EXCHANGE ACT (CEA); SECTION 6(C) AND 6(D) OF THE CEA, FOR CONDUCT OCCURRING PRIOR TO
AUGUST 15, 2011; AND SECTION 6(C)(1), 6(C)(1)(A), 6(C)(3) AND 6(D) OF THE CEA, AND REGULATIONS 180.1(A) AND 180.2, FOR CONDUCT OCCURRING
ON OR AFTER AUGUST 15, 2011.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
09/19/2018
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 30,000,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived: 
WITHOUT ADMITTING OR DENYING THE FINDINGS OR CONCLUSIONS IN THE ORDER, THE FIRM CONSENTED TO THE IMPOSITION OF THE
FOLLOWING SANCTIONS: (1) TO CEASE AND DESIST FROM VIOLATING SECTIONS 6(C)(1), 6(C)(1)(A), 6(C)(3), 6(D), AND 9(A)(2) OF THE CEA AND
REGULATIONS 180.1(A) AND 180.2 THEREUNDER, (2) TO PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $30,000,000, AND (3) TO COMPLY
WITH CERTAIN UNDERTAKINGS.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
WITHOUT ADMITTING OR DENYING THE FINDINGS OR CONCLUSIONS IN THE ORDER, THE FIRM CONSENTED TO THE IMPOSITION OF THE FOLLOWING
SANCTIONS: (1) TO CEASE AND DESIST FROM VIOLATING SECTIONS 6(C)(1), 6(C)(1)(A), 6(C)(3), 6(D), AND 9(A)(2) OF THE CEA AND REGULATIONS
180.1(A) AND 180.2, (2) TO PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $30,000,000, WHICH THE FIRM PAID ON SEPTEMBER 24, 2018, AND (3)
CONTINUE TO UNDERTAKE CERTAIN REMEDIATION EFFORTS, INCLUDING PROVIDING A REPORT TO THE CFTC WITHIN 120 DAYS OF THE ORDER
ADDRESSING REMEDIATION EFFORTS BOTH PRIOR TO AND SINCE ENTRY OF THE ORDER, AND PROVIDING AN ADDITIONAL REPORT TO THE CFTC, NO
LATER THAN 365 DAYS FROM ENTRY OF THE ORDER, EXPLAINING HOW THE FIRM HAS COMPLIED WITH THE UNDERTAKINGS SET FORTH IN THE ORDER.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with
a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same
event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.

ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BANK OF AMERICA, NATIONAL
ASSOCIATION
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the
IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
RESERVE BANK OF INDIA ("RBI")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
02/25/2019
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
EFD.CO.SO/590/02.03.044/2018-19
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE RESERVE BANK OF INDIA ("RBI") ALLEGED THAT THE FIRM'S RECONCILIATION OF LOGS GENERATED FROM SWIFT WAS NOT SUFFICIENT AND
VIOLATED THE DIRECTION OF THE RBI.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):

02/25/2019
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 144,952.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
N/A
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived: 
THE RBI ORDERED THE FIRM TO PAY A MONETARY PENALTY IN THE AMOUNT OF INR10,000,000, WHICH IS APPROXIMATELY USD $144,952.00.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
THE RBI ORDERED THE FIRM TO PAY A MONETARY PENALTY IN THE AMOUNT OF INR10,000,000, WHICH IS APPROXIMATELY USD $144,952.00.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with
a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same
event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BANK OF AMERICA, NATIONAL
ASSOCIATION
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.

If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the
IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
BANGKO SENTRAL NG PILIPINAS
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
04/11/2019
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
NONE
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
FOREIGN EXCHANGE TRANSACTIONS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE BANGKO SENTRAL NG PILIPINAS (BSP) APPROVED THE IMPOSITION OF A MONETARY PENALTY ON THE FIRM FOR NON-COMPLIANCE WITH THE 100.0
PERCENT EXPANDED/FOREIGN CURRENCY DEPOSIT UNIT (E/FCDU) ASSET COVER REQUIREMENT.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Other
11. Resolution Date (MM/DD/YYYY):
04/26/2019
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 19,473.80
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:

THE MONETARY BOARD IMPOSED A PENALTY IN THE AMOUNT OF PHP1,011,442.07 (USD19,473.80) ON THE FIRM.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived: 
THE MONETARY BOARD IMPOSED A PENALTY IN THE AMOUNT OF PHP1,011,442 (USD19,473.80) ON THE FIRM. PURSUANT TO THE BSP'S RULES,
THE FIRM'S DEMAND DEPOSIT ACCOUNT WITH THE BSP SHALL BE AUTOMATICALLY DEBITED THE ABOVE REFERENCED AMOUNT UPON THE LAPSE
OF FIFTEEN CALENDAR DAYS FROM RECEIPT OF THE FINAL BILLING LETTER. THEREFORE, THE AMOUNT MAY BE DEBITED NO EARLIER THAN APRIL
26, 2019.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
THE MONETARY BOARD IMPOSED A PENALTY IN THE AMOUNT OF PHP1,011,442 (USD19,473.80) ON THE FIRM. PURSUANT TO THE BSP'S RULES, THE
FIRM'S DEMAND DEPOSIT ACCOUNT WITH THE BSP SHALL BE AUTOMATICALLY DEBITED THE ABOVE REFERENCED AMOUNT UPON THE LAPSE OF FIFTEEN
CALENDAR DAYS FROM RECEIPT OF THE FINAL BILLING LETTER. THEREFORE, THE AMOUNT MAY BE DEBITED NO EARLIER THAN APRIL 26, 2019.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with
a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same
event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
7691
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
MERRILL LYNCH, PIERCE,
FENNER & SMITH
INCORPORATED
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 

B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the
IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
11. Resolution Date (MM/DD/YYYY):
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived: 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with
a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same
event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BANK OF AMERICA
CORPORATION
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the
IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
BUNDESANSTALT FUR FINANZDIENSTLEISTUNGSAUFSICHT (BAFIN)
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 

08/22/2022
 Exact
 Explanation
If not exact, provide explanation:
RECEIVED ON 08/08/2022, DEEMED FINAL AND BINDING ON 08/22/2022.
4.
Docket/Case Number:
WA 15-WP 3121-2020/0001; WA 15-WP 3121-2020/0002; WA 15=WP 3121-2020/0003; WA 15-WP 3120-2020/0012
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE BUNDESANSTALT FUR FINANZDIENSTLEISTUNGSAUFSICHT (BAFIN) APPROVED THE IMPOSITION OF AN ADMINISTRATIVE FINE ON BANK OF AMERICA
CORPORATION FOR FAILURE TO TAKE THE SUPERVISORY AND ORGANISATIONAL MEASURES THAT WOULD HAVE BEEN REQUIRED IN ORDER TO ENSURE
THE CORRECT AND COMPLETE SUBMISSION OF VOTING RIGHTS NOTIFICATIONS WITHIN THE PRESCRIBED PERIOD, IN BREACH OF SECTION 130(1) OF
THE GERMAN ACT ON BREACHES OF ADMINISTRATIVE REGULATIONS IN CONJUNCTION WITH SECTIONS 33 (1) SENTENCE 1, SECTION 38(1) SENTENCE 1
AND 39 (1) OF THE GERMAN SECURITIES TRADING ACT.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Other
11. Resolution Date (MM/DD/YYYY):
08/22/2022
 Exact
 Explanation
If not exact, provide explanation:
RECEIVED ON 08/08/2022, DEEMED FINAL AND BINDING ON 08/22/2022.
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 5,071,950.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
COSTS OF THE PROCEEDING
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived: 
BAFIN IMPOSED A PENALTY IN THE AMOUNT OF EUR5,100,000 (APPROXIMATELY USD5,071,950) ON BAC AND COSTS OF THE PROCEEDING IN THE
AMOUNT OF EUR7,500 (APPROXIMATELY USD 7,479). THE PAYMENTS WERE MADE IN ACCORDANCE WITH THE TERMS OF THE ORDER.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
BAFIN IMPOSED A PENALTY IN THE AMOUNT OF EUR5,100,000 (APPROXIMATELY USD5,071,950) ON BAC AND COSTS OF THE PROCEEDING IN THE
AMOUNT OF EUR7,500 (APPROXIMATELY USD 7,479). THE PAYMENTS WERE MADE IN ACCORDANCE WITH THE TERMS OF THE ORDER.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Item 11.H. of Part
1A or Item 2.F. of Part 1B of Form ADV.
Civil Judicial

Check Part 1A item(s) being responded to:
11.H(1)(a)
11.H(1)(b)
11.H(1)(c)
11.H(2)
Check Part 1B item(s) being responded to:
2.F(1)
2.F(2)
2.F(3)
2.F(4)
2.F(5)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with
a completed Execution Page.
One event may result in more than one affirmative answer to Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the
same event. Unrelated civil judicial actions must be reported on separate DRPs.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BANK OF AMERICA
CORPORATION
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.H.
(1)(a), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the
IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) 
SECURITIES AND EXCHANGE COMMISSION
2.
Principal Relief Sought:
Civil Penalty(ies)/Fine(s)
Other Relief Sought: 
INJUNCTION
3.
Filing Date of Court Action (MM/DD/YYYY):
08/03/2009
 Exact
 Explanation
If not exact, provide explanation:
4.
Principal Product Type:
No Product
Other Product Types: 

5.
Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case
Number): 
U.S. DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK; 09-CV-6829
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 
7.
Describe the allegations related to this civil action (your response must fit within the space provided): 
THE SECURITIES AND EXCHANGE COMMISSION ("SEC") ALLEGED THAT BANK OF AMERICA CORPORATION (THE "CORPORATION") VIOLATED SECTION
14(A) OF THE SECURITIES EXCHANGE ACT OF 1934 (THE "EXCHANGE ACT") AND RULE 14A-9 THEREUNDER BY FAILING TO DISCLOSE IN THE
CORPORATION'S JOINT PROXY STATEMENT FILED ON NOVEMBER 3, 2008 THE INCENTIVE COMPENSATION THAT MERRILL LYNCH & CO., INC. COULD, IN
ITS DISCRETION, AWARD TO ITS EMPLOYEES PRIOR TO COMPLETION OF ITS MERGER WITH THE CORPORATION.
8.
Current Status? 
 Pending
 On Appeal
 Final
9.
If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 
10. If pending, date notice/process was served (MM/DD/YYYY):
 Exact
 Explanation
If not exact, provide explanation:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.
11. How was matter resolved:
Consent
12. Resolution Date (MM/DD/YYYY): 
02/24/2010
 Exact
 Explanation
If not exact, provide explanation:
13. Resolution Detail:
A.  Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $ 150,000,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
THE CORPORATION AGREED, FOR A PERIOD OF THREE YEARS, TO COMPLY WITH AND MAINTAIN CERTAIN REQUIREMENTS RELATED TO THE
CORPORATION'S CORPORATE GOVERNANCE AND DISCLOSURE PRACTICES.
C.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement, or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived:
N/A
14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must fit
within the space provided). 
ON FEBRUARY 24, 2010, A FINAL CONSENT JUDGMENT (THE "FINAL JUDGMENT") WAS ENTERED BY THE COURT. UNDER THE TERMS OF THE FINAL
JUDGMENT, THE CORPORATION AGREED TO PAY $1 IN DISGORGEMENT AND A $150 MILLION CIVIL PENALTY TO BE DISTRIBUTED TO SHAREHOLDERS AS
PART OF THE SEC'S FAIR FUNDS PROGRAM AT A LATER DATE IN ACCORDANCE WITH FURTHER ORDER OF THE COURT. IN ADDITION, AS PART OF THE
FINAL JUDGMENT, THE CORPORATION AGREED, FOR A PERIOD OF THREE YEARS, TO COMPLY WITH AND MAINTAIN CERTAIN REQUIREMENTS RELATED TO
THE CORPORATION'S CORPORATE GOVERNANCE AND DISCLOSURE PRACTICES.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Item 11.H. of Part
1A or Item 2.F. of Part 1B of Form ADV.
Civil Judicial
Check Part 1A item(s) being responded to:
11.H(1)(a)
11.H(1)(b)
11.H(1)(c)
11.H(2)

Check Part 1B item(s) being responded to:
2.F(1)
2.F(2)
2.F(3)
2.F(4)
2.F(5)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with
a completed Execution Page.
One event may result in more than one affirmative answer to Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the
same event. Unrelated civil judicial actions must be reported on separate DRPs.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BANK OF AMERICA
CORPORATION
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.H.
(1)(a), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the
IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) 
SECURITIES AND EXCHANGE COMMISSION
2.
Principal Relief Sought:
Civil Penalty(ies)/Fine(s)
Other Relief Sought: 
INJUNCTION
3.
Filing Date of Court Action (MM/DD/YYYY):
01/12/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Principal Product Type:
No Product
Other Product Types: 
5.
Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case
Number): 

U.S. DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK; 10-CV-0215(JSR)
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 
N/A
7.
Describe the allegations related to this civil action (your response must fit within the space provided): 
THE SECURITIES AND EXCHANGE COMMISSION ("SEC") ALLEGED THAT BANK OF AMERICA CORPORATION (THE "CORPORATION") VIOLATED THE FEDERAL
PROXY RULES BY FAILING TO DISCLOSE INFORMATION CONCERNING MERRILL LYNCH & CO., INC.'S KNOWN AND ESTIMATED LOSSES IN THE FOURTH
QUARTER OF 2008 PRIOR TO THE SHAREHOLDER VOTE ON DECEMBER 5, 2008 TO APPROVE THE MERGER BETWEEN THE TWO COMPANIES.
8.
Current Status? 
 Pending
 On Appeal
 Final
9.
If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 
10. If pending, date notice/process was served (MM/DD/YYYY):
 Exact
 Explanation
If not exact, provide explanation:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.
11. How was matter resolved:
Consent
12. Resolution Date (MM/DD/YYYY): 
02/24/2010
 Exact
 Explanation
If not exact, provide explanation:
13. Resolution Detail:
A.  Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $ 150,000,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
THE CORPORATION AGREED, FOR A PERIOD OF THREE YEARS, TO COMPLY WITH AND MAINTAIN CERTAIN REQUIREMENTS RELATED TO THE
CORPORATION'S CORPORATE GOVERNANCE AND DISCLOSURE PRACTICES.
C.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement, or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived:
N/A
14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must fit
within the space provided). 
ON FEBRUARY 24, 2010, A FINAL CONSENT JUDGMENT (THE "FINAL JUDGMENT") WAS ENTERED BY THE COURT. UNDER THE TERMS OF THE FINAL
JUDGMENT, THE CORPORATION AGREED TO PAY $1 IN DISGORGEMENT AND A $150 MILLION CIVIL PENALTY TO BE DISTRIBUTED TO SHAREHOLDERS AS
PART OF THE SEC'S FAIR FUNDS PROGRAM AT A LATER DATE IN ACCORDANCE WITH FURTHER ORDER OF THE COURT. IN ADDITION, AS PART OF THE
FINAL JUDGMENT, THE CORPORATION AGREED, FOR A PERIOD OF THREE YEARS, TO COMPLY WITH AND MAINTAIN CERTAIN REQUIREMENTS RELATED TO
THE CORPORATION'S CORPORATE GOVERNANCE AND DISCLOSURE PRACTICES.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Item 11.H. of Part
1A or Item 2.F. of Part 1B of Form ADV.
Civil Judicial
Check Part 1A item(s) being responded to:
11.H(1)(a)
11.H(1)(b)
11.H(1)(c)
11.H(2)
Check Part 1B item(s) being responded to:
2.F(1)
2.F(2)
2.F(3)
2.F(4)
2.F(5)

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with
a completed Execution Page.
One event may result in more than one affirmative answer to Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the
same event. Unrelated civil judicial actions must be reported on separate DRPs.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BANK OF AMERICA
CORPORATION
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.H.
(1)(a), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the
IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) 
ATTORNEY GENERAL OF THE STATE OF NEW YORK
2.
Principal Relief Sought:
Civil Penalty(ies)/Fine(s)
Other Relief Sought: 
DISGORGEMENT; INJUNCTION; RESTITUTION; ATTORNEYS' FEES AND OTHER EQUITABLE RELIEF
3.
Filing Date of Court Action (MM/DD/YYYY):
02/04/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Principal Product Type:
No Product
Other Product Types: 
5.
Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case
Number): 
SUPREME COURT OF THE STATE OF NEW YORK, COUNTY OF NEW YORK
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 

7.
Describe the allegations related to this civil action (your response must fit within the space provided): 
THE ATTORNEY GENERAL OF THE STATE OF NEW YORK ALLEGES THAT BANK OF AMERICA CORPORATION ("BAC"), ITS FORMER CEO KENNETH D. LEWIS
AND ITS FORMER CFO JOSEPH L. PRICE ENGAGED IN ACTS AND PRACTICES IN CONNECTION WITH THE MERGER (THE "MERGER") BETWEEN BAC AND
MERRILL LYNCH & CO. INC. ("MERRILL LYNCH") THAT VIOLATED CERTAIN PROVISIONS OF THE NEW YORK GENERAL BUSINESS LAW (THE "MARTIN ACT")
AND THE NEW YORK EXECUTIVE LAW.
8.
Current Status? 
 Pending
 On Appeal
 Final
9.
If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 
10. If pending, date notice/process was served (MM/DD/YYYY):
02/04/2010
 Exact
 Explanation
If not exact, provide explanation:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.
11. How was matter resolved:
Settled
12. Resolution Date (MM/DD/YYYY): 
03/25/2014
 Exact
 Explanation
If not exact, provide explanation:
13. Resolution Detail:
A.  Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
BAC AGREED TO PAY THE NEW YORK ATTORNEY GENERAL $15,000,000 (AS COSTS OF INVESTIGATION AND SUBSEQUENT LITIGATION) AS WELL AS
MAKING SEVERAL CORPORATE GOVERNANCE CHANGES.
C.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement, or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived:
BAC AGREED TO PAY THE NEW YORK ATTORNEY GENERAL $15,000,000 (AS COSTS OF INVESTIGATION AND SUBSEQUENT LITIGATION) AS WELL AS
MAKING SEVERAL CORPORATE GOVERNANCE CHANGES.
14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must fit
within the space provided). 
ON FEBRUARY 4, 2010, THE NEW YORK ATTORNEY GENERAL FILED A CIVIL COMPLAINT IN THE SUPREME COURT OF NEW YORK STATE, ENTITLED PEOPLE
OF THE STATE OF NEW YORK V. BANK OF AMERICA, ET AL. THE COMPLAINT NAMES AS DEFENDANTS BAC AND BAC'S FORMER CHIEF EXECUTIVE AND
CHIEF FINANCIAL OFFICERS, KENNETH D. LEWIS, AND JOSEPH L. PRICE, AND ALLEGES VIOLATIONS OF SECTIONS 352, 352-C(1)(A), 352-C(1)(C), AND
353 OF THE NEW YORK MARTIN ACT, AND SECTION 63(12) OF THE NEW YORK EXECUTIVE LAW. THE COMPLAINT ATTACKS THE SUFFICIENCY AND
ACCURACY OF BAC'S DISCLOSURES AND ITS PRACTICES RELATED TO BAC'S MERGER WITH MERRILL LYNCH, INCLUDING: (I) THE DISCLOSURE OF
MERRILL LYNCH'S FINANCIAL CONDITION AND ITS INTERIM AND PROJECTED LOSSES DURING THE FOURTH QUARTER OF 2008, (II) BAC'S CONTACTS
WITH FEDERAL GOVERNMENT OFFICIALS REGARDING BAC'S CONSIDERATION OF INVOKING THE MATERIAL ADVERSE EFFECT CLAUSE IN THE MERGER
AGREEMENT WITH MERRILL LYNCH AND THE POSSIBILITY OF OBTAINING ADDITIONAL GOVERNMENT ASSISTANCE, (III) THE DISCLOSURE OF THE
PAYMENT AND TIMING OF YEAR-END INCENTIVE COMPENSATION TO MERRILL LYNCH EMPLOYEES, AND (IV) PUBLIC STATEMENTS REGARDING THE DUE
DILIGENCE CONDUCTED IN CONNECTION WITH THE MERGER AND POSITIVE STATEMENTS REGARDING THE MERGER. THE COMPLAINT SEEKS AN
UNSPECIFIED AMOUNT IN DISGORGEMENT, PENALTIES, RESTITUTION, AND DAMAGES, COSTS AND OTHER EQUITABLE RELIEF, ALTHOUGH THE NYAG
WITHDREW ITS DEMAND FOR DAMAGES. ON MARCH 25, 2014, BAC ENTERED INTO A SETTLEMENT AGREEMENT TERMINATING THE NEW YORK ATTORNEY
GENERAL'S LAWSUIT AGAINST BAC.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Item 11.H. of Part
1A or Item 2.F. of Part 1B of Form ADV.
Civil Judicial
Check Part 1A item(s) being responded to:
11.H(1)(a)
11.H(1)(b)
11.H(1)(c)
11.H(2)

Check Part 1B item(s) being responded to:
2.F(1)
2.F(2)
2.F(3)
2.F(4)
2.F(5)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with
a completed Execution Page.
One event may result in more than one affirmative answer to Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the
same event. Unrelated civil judicial actions must be reported on separate DRPs.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BANK OF AMERICA, N.A.
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BAC HOME LOANS SERVICING,
LP F/K/A COUNTRYWIDE HOME
LOANS SERVICING, LP
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
COUNTRYWIDE HOME LOANS,
INC.
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
COUNTRYWIDE FINANCIAL
CORPORATION
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
COUNTRYWIDE MORTGAGE
VENTURES, LLC
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
COUNTRYWIDE BANK, FSB
(For individuals, Last, First,

Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BANK OF AMERICA
CORPORATION
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.H.
(1)(a), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the
IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) 
U.S. DEPARTMENT OF JUSTICE AND THE ATTORNEYS GENERAL OF 49 STATES AND THE DISTRICT OF COLUMBIA
2.
Principal Relief Sought:
Civil Penalty(ies)/Fine(s)
Other Relief Sought: 
RESTITUTION; ADDITIONAL SERVICING & ORIGINATION STANDARDS
3.
Filing Date of Court Action (MM/DD/YYYY):
04/05/2012
 Exact
 Explanation
If not exact, provide explanation:
4.
Principal Product Type:
Other
Other Product Types: 
RESIDENTIAL MORTGAGE LOAN SERVICING AND ORIGINATION
5.
Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case
Number): 
U.S. DISTRICT COURT FOR THE DISTRICT OF COLUMBIA, DOCKET NUMBER 1:12-CV-00361-RMC
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 
7.
Describe the allegations related to this civil action (your response must fit within the space provided): 
ON MARCH 12, 2012, THE DEPARTMENT OF JUSTICE AND THE ATTORNEYS GENERAL OF 49 STATES AND THE DISTRICT OF COLUMBIA FILED A COMPLAINT
("COMPLAINT") AND CONSENT JUDGMENT AGAINST BANK OF AMERICA CORPORATION, BANK OF AMERICA, N.A., BAC HOME LOANS SERVICING, LP F/K/A
COUNTRYWIDE HOME LOANS SERVICING, LP, COUNTRYWIDE HOME LOANS, INC., COUNTRYWIDE FINANCIAL CORPORATION, COUNTRYWIDE MORTGAGE
VENTURES, LLC, AND/OR COUNTRYWIDE BANK, FSB (TOGETHER, "BANK OF AMERICA") AND OTHER MAJOR MORTGAGE SERVICERS TO SETTLE A NUMBER
OF RELATED INVESTIGATIONS INTO RESIDENTIAL LOAN SERVICING AND ORIGINATION PRACTICES (THE "SETTLEMENT"). THE COMPLAINT ALLEGED THE
DEFENDANT'S MISCONDUCT RELATED TO ITS ORIGINATION AND SERVICING OF SINGLE FAMILY RESIDENTIAL MORTGAGES CAUSED THE DEFENDANTS TO
HAVE VIOLATED, AMONG OTHER LAWS, THE UNFAIR AND DECEPTIVE ACTS AND PRACTICES LAWS OF THE PLAINTIFF STATES, THE FALSE CLAIMS ACT,
THE FINANCIAL INSTITUTIONS REFORM, RECOVERY, AND ENFORCEMENT ACT OF 1989, THE SERVICEMEMBERS CIVIL RELIEF ACT, AND THE BANKRUPTCY
CODE AND FEDERAL RULES OF BANKRUPTCY PROCEDURE.
8.
Current Status? 
 Pending
 On Appeal
 Final
9.
If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 

10. If pending, date notice/process was served (MM/DD/YYYY):
 Exact
 Explanation
If not exact, provide explanation:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.
11. How was matter resolved:
Settled
12. Resolution Date (MM/DD/YYYY): 
04/05/2012
 Exact
 Explanation
If not exact, provide explanation:
13. Resolution Detail:
A.  Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $ 0.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
THE TOTAL AMOUNT OF THE SETTLEMENT IS $10,956,615,075.00, AND CONSISTS OF THE THREE COMPONENTS AS FURTHER DESCRIBED IN 13.C.
UP TO $120 MILLION OF THIS AMOUNT MAY BE TREATED AS A CIVIL PENALTY AT THE DISCRETION OF THE STATES AND DISTRICT OF COLUMBIA.
THE AMOUNT IS BEING DISCLOSED IN THIS SECTION 13.B INSTEAD OF IN THE BOX ABOVE AS THE EXACT AMOUNT TO BE TREATED AS A CIVIL
PENALTY IS NOT KNOWN. OTHER SANCTIONS: ADDITIONAL SERVICING AND ORIGINATION STANDARDS.
C.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement, or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived:
BANK OF AMERICA CORPORATION AND/OR ITS AFFILIATED ENTITIES SHALL PAY OR CAUSE TO BE PAID INTO AN INTEREST BEARING ESCROW
ACCOUNT TO BE ESTABLISHED FOR THIS PURPOSE THE SUM OF $2,382,415,075, WHICH SUM SHALL BE ADDED TO FUNDS BEING PAID BY OTHER
INSTITUTIONS RESOLVING CLAIMS IN THIS MATTER AND ACCORDING TO CERTAIN CRITERIA ESTABLISHED IN THE SETTLEMENT. UP TO $120
MILLION OF THIS AMOUNT MAY BE TREATED AS A CIVIL PENALTY. IN ADDITION, BANK OF AMERICA SHALL PROVIDE $7,626,200,000 OF RELIEF TO
CONSUMERS WHO MEET CERTAIN ELIGIBILITY CRITERIA RELATING TO SERVICING OF LOANS. THE ADDITIONAL SERVICING AND ORIGINATION
STANDARDS INCLUDE THE DEVELOPMENT OF NEW OR ENHANCED PROGRAMS TO PROVIDE BORROWER ASSISTANCE, THE DEVELOPMENT OF
PROPRIETARY PROGRAMS TO PROVIDE EXPANDED MORTGAGE MODIFICATION SOLUTIONS, INCLUDING THE BROADER USE OF PRINCIPAL
REDUCTIONS IF PERMITTED BY THE MORTGAGE INVESTOR, ENHANCED PROGRAMS FOR UNEMPLOYED, MILITARY SERVICE MEMBERS AND OTHER
CUSTOMERS WITH IDENTIFIED SPECIAL SITUATIONS, ENHANCED FACILITATION OF SHORT SALES, AND THE OFFER OF OTHER ASSISTANCE
PROGRAMS, SUCH AS DEED-IN-LIEU OF FORECLOSURE AND FUNDS FOR FAMILIES TRANSITIONING OUT OF HOME OWNERSHIP. ALSO, BANK OF
AMERICA SHALL PROVIDE $948,000,000 TO A NEW REFINANCING PROGRAM FOR CURRENT CONSUMERS WHO MEET OTHER ELIGIBILITY CRITERIA.
THE REFINANCING PROGRAM IS INTENDED TO EXPAND REFINANCING OPPORTUNITIES OR LOWER INTEREST RATES ON BANK OF AMERICA OWNED
MORTGAGES TO PROVIDE REDUCED PAYMENTS FOR MANY HOMEOWNERS WHO ARE CURRENT ON THEIR PAYMENTS BUT OWE MORE THAN THE
CURRENT VALUE OF THEIR HOMES. FOLLOWING FINALIZATION OF THE SETTLEMENT TERMS, BANK OF AMERICA WILL FINALIZE ITS PROGRAM
ENHANCEMENTS AND PROVIDE ADDITIONAL DETAILS OF ELIGIBILITY REQUIREMENTS.
14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must fit
within the space provided). 
BANK OF AMERICA CONSENTED TO THE ENTRY OF THE CONSENT JUDGMENT WITHOUT ADMITTING THE ALLEGATIONS IN THE COMPLAINT OTHER THAN
THOSE FACTS DEEMED NECESSARY TO JURISDICTION. THE ALLEGATIONS ARE DESCRIBED IN ITEM 7 ABOVE AND THE SANCTIONS ARE DESCRIBED IN
ITEM 13 ABOVE. BANK OF AMERICA MADE ITS PAYMENT TO THE ESCROW AGENT ON APRIL 11, 2012. THE SETTLEMENT DOES NOT RESULT IN AN
INJUNCTION OR ANY FINDINGS OF VIOLATIONS OF LAW.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Item 11.H. of Part
1A or Item 2.F. of Part 1B of Form ADV.
Civil Judicial
Check Part 1A item(s) being responded to:
11.H(1)(a)
11.H(1)(b)
11.H(1)(c)
11.H(2)
Check Part 1B item(s) being responded to:
2.F(1)
2.F(2)
2.F(3)
2.F(4)
2.F(5)

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with
a completed Execution Page.
One event may result in more than one affirmative answer to Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the
same event. Unrelated civil judicial actions must be reported on separate DRPs.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
7691
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
MERRILL LYNCH, PIERCE,
FENNER & SMITH
INCORPORATED
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BANK OF AMERICA, N.A.
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BANC OF AMERICA MORTGAGE
SECURITIES, INC.
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BANK OF AMERICA
CORPORATION
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.H.
(1)(a), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the
IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1.  Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) 
UNITED STATES OF AMERICA
2.
Principal Relief Sought:
Civil Penalty(ies)/Fine(s)
Other Relief Sought: 
PREJUDGMENT INTEREST, COSTS AND ATTORNEYS' FEES.
3.
Filing Date of Court Action (MM/DD/YYYY):
08/06/2013
 Exact
 Explanation
If not exact, provide explanation:
4.
Principal Product Type:
Other
Other Product Types: 
RESIDENTIAL MORTGAGE-BACKED SECURITIES
5.
Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case
Number): 
UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA, CIVIL ACTION NO. 3:13-CV-446
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 
7.
Describe the allegations related to this civil action (your response must fit within the space provided): 
ON AUGUST 6, 2013, THE DEPARTMENT OF JUSTICE FILED A CIVIL ACTION AGAINST MERRILL LYNCH, PIERCE, FENNER & SMITH, INC. F/K/A BANC OF
AMERICA SECURITIES LLC (THE "FIRM") AND OTHER ENTITIES (COLLECTIVELY THE "ENTITIES"). THE DEPARTMENT OF JUSTICE ALLEGES THAT THE
ENTITIES VIOLATED THE FINANCIAL INSTITUTIONS REFORM, RECOVERY AND ENFORCEMENT ACT OF 1989, 12 U.S.C. § 1833A, THROUGH CIVIL
VIOLATIONS OF 18 U.S.C. §§ 1001 AND 1014. THE COMPLAINT CLAIMS THAT THE ENTITIES MADE FALSE STATEMENTS TO AND OMITTED MATERIAL
INFORMATION FROM THE GOVERNMENT AND FEDERALLY INSURED FINANCIAL INSTITUTIONS. SPECIFICALLY, THE COMPLAINT ALLEGES THAT THE
ENTITIES FAILED TO DISCLOSE THE DISPROPORTIONATE CONCENTRATION OF WHOLESALE CHANNEL LOANS ORIGINATED BY THIRD PARTIES
UNDERLYING THE RESIDENTIAL MORTGAGE BACKED SECURITIES. THE COMPLAINT ALLEGES THAT THE ENTITIES KNEW THE WHOLESALE CHANNEL LOANS
WERE RISKIER AS COMPARED TO SIMILAR MORTGAGES ORIGINATED BY THE ENTITIES DIRECTLY. THE COMPLAINT ALSO ALLEGES THAT THE ENTITIES
FAILED TO DISCLOSE THE PERCENTAGE OF PAPERSAVER LOANS MADE TO SELF-EMPLOYED BORROWERS. THE COMPLAINT ALLEGES THAT THE ENTITIES
KNEW PAPERSAVER LOANS WERE RISKIER THAN MORTGAGES GIVEN TO SALARIED BORROWERS. THE COMPLAINT FURTHER ALLEGES THAT, EVEN
THOUGH THE ENTITIES WERE AWARE OF THE RISKS ASSOCIATED WITH THE CHARACTERISTICS OF THE POOL, THE ENTITIES FAILED TO CONDUCT THIRD-
PARTY DUE DILIGENCE ON THE MORTGAGES IN THE POOL AND VIOLATED THE FIRM'S DUE DILIGENCE POLICIES. THE COMPLAINT SEEKS A CIVIL
MONETARY JUDGMENT IN AN UNSTATED AMOUNT PURSUANT TO 12 U.S.C. § 1833A(B), PREJUDGMENT INTEREST, AND ATTORNEYS' FEES.
8.
Current Status? 
 Pending
 On Appeal
 Final
9.
If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 
10. If pending, date notice/process was served (MM/DD/YYYY):
08/06/2013
 Exact
 Explanation
If not exact, provide explanation:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.
11. How was matter resolved:
Dismissed
12. Resolution Date (MM/DD/YYYY): 
08/29/2014
 Exact
 Explanation
If not exact, provide explanation:
13. Resolution Detail:
A.  Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
NONE
C.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,

Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement, or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived:
NONE
14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must fit
within the space provided). 
ON AUGUST 21, 2014, THE U.S. DEPARTMENT OF JUSTICE ("DOJ") ANNOUNCED A GLOBAL SETTLEMENT AGREEMENT BETWEEN BANK OF AMERICA
CORPORATION AND SEVERAL OF ITS AFFILIATES (TOGETHER "BANK OF AMERICA") AND THE DOJ, AMONG OTHERS, IN CONNECTION WITH THE
PACKAGING, ORIGINATION, MARKETING, SALE STRUCTURING, ARRANGEMENT, AND ISSUANCE OF RESIDENTIAL MORTGAGE-BACKED SECURITIES ("RMBS")
AND COLLATERALIZED DEBT OBLIGATIONS ("CDOS"). AS PART OF THE GLOBAL SETTLEMENT AGREEMENT, THE DOJ RELEASED BANK OF AMERICA FROM
THE CONDUCT ALLEGED IN THE COMPLAINT FILED ON AUGUST 6, 2013. ON AUGUST 29, 2014, THE DISTRICT COURT DISMISSED THE DOJ COMPLAINT
(THE SUBJECT OF THIS DRP) WITH PREJUDICE. THE DOJ DID NOT ENJOIN BANK OF AMERICA AND, THEREFORE, 11H(1)(A) IS NOT APPLICABLE. THERE
WAS NO FINDING OF VIOLATIONS OF INVESTMENT-RELATED STATUTES OR REGULATIONS BY THE DOJ AND, THEREFORE, 11H(1)(B) IS NOT APPLICABLE.
AND THE DOJ IS NOT A STATE OR FOREIGN FINANCIAL REGULATORY AUTHORITY AND, THEREFORE, 11H(1)(C) IS NOT APPLICABLE. *****THE FIRM
THEREFORE REQUESTS THAT THIS DRP RELATED TO THIS DOJ DRP BE REMOVED AS THE MATTER WAS DISMISSED AND THERE WAS NO FINDING/ACTION
AGAINST BANK OF AMERICA BY THE DOJ.*****

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Item 11.H. of Part
1A or Item 2.F. of Part 1B of Form ADV.
Civil Judicial
Check Part 1A item(s) being responded to:
11.H(1)(a)
11.H(1)(b)
11.H(1)(c)
11.H(2)
Check Part 1B item(s) being responded to:
2.F(1)
2.F(2)
2.F(3)
2.F(4)
2.F(5)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with
a completed Execution Page.
One event may result in more than one affirmative answer to Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the
same event. Unrelated civil judicial actions must be reported on separate DRPs.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
COUNTRYWIDE FINANCIAL
CORPORATION
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
COUNTRYWIDE MORTGAGE
VENTURES, LLC
(For individuals, Last, First,
Middle)

CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
COUNTRYWIDE BANK, FSB
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BANK OF AMERICA, NATIONAL
ASSOCIATION
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BANK OF AMERICA
CORPORATION
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BAC HOME LOANS SERVICING,
LP F/K/A COUNTRYWIDE HOME
LOANS SERVICING, LP
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
COUNTRYWIDE HOME LOANS,
INC.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.H.
(1)(a), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the
IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) 
U.S. DEPARTMENT OF JUSTICE AND THE ATTORNEYS GENERAL OF 49 STATES AND THE DISTRICT OF COLUMBIA
2.
Principal Relief Sought:
Civil Penalty(ies)/Fine(s)
Other Relief Sought: 
RESTITUTION ADDITIONAL SERVICING & ORIGINATION STANDARDS

3.
Filing Date of Court Action (MM/DD/YYYY):
04/05/2012
 Exact
 Explanation
If not exact, provide explanation:
4.
Principal Product Type:
Other
Other Product Types: 
RESIDENTIAL MORTGAGE LOAN SERVICING AND ORIGINATION
5.
Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case
Number): 
U.S. DISTRICT COURT FOR THE DISTRICT OF COLUMBIA, DOCKET NUMBER 1:12-CV-00361-RMC
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 
7.
Describe the allegations related to this civil action (your response must fit within the space provided): 
ON MARCH 12, 2012, THE DEPARTMENT OF JUSTICE AND THE ATTORNEYS GENERAL OF 49 STATES AND THE DISTRICT OF COLUMBIA FILED A COMPLAINT
("COMPLAINT") AND CONSENT JUDGMENT AGAINST BANK OF AMERICA CORPORATION, BANK OF AMERICA, N.A., BAC HOME LOANS SERVICING, LP F/K/A
COUNTRYWIDE HOME LOANS SERVICING, LP, COUNTRYWIDE HOME LOANS, INC., COUNTRYWIDE FINANCIAL CORPORATION, COUNTRYWIDE MORTGAGE
VENTURES, LLC, AND/OR COUNTRYWIDE BANK, FSB (TOGETHER, "BANK OF AMERICA") AND OTHER MAJOR MORTGAGE SERVICERS TO SETTLE A NUMBER
OF RELATED INVESTIGATIONS INTO RESIDENTIAL LOAN SERVICING AND ORIGINATION PRACTICES (THE "SETTLEMENT"). THE COMPLAINT ALLEGED THE
DEFENDANT'S MISCONDUCT RELATED TO ITS ORIGINATION AND SERVICING OF SINGLE FAMILY RESIDENTIAL MORTGAGES CAUSED THE DEFENDANTS TO
HAVE VIOLATED, AMONG OTHER LAWS, THE UNFAIR AND DECEPTIVE ACTS AND PRACTICES LAWS OF THE PLAINTIFF STATES, THE FALSE CLAIMS ACT,
THE FINANCIAL INSTITUTIONS REFORM, RECOVERY, AND ENFORCEMENT ACT OF 1989, THE SERVICEMEMBERS CIVIL RELIEF ACT, AND THE BANKRUPTCY
CODE AND FEDERAL RULES OF BANKRUPTCY PROCEDURE.
8.
Current Status? 
 Pending
 On Appeal
 Final
9.
If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 
10. If pending, date notice/process was served (MM/DD/YYYY):
 Exact
 Explanation
If not exact, provide explanation:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.
11. How was matter resolved:
Settled
12. Resolution Date (MM/DD/YYYY): 
04/05/2012
 Exact
 Explanation
If not exact, provide explanation:
13. Resolution Detail:
A.  Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $ 0.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
THE TOTAL AMOUNT OF THE SETTLEMENT IS $10,956,615,075.00, AND CONSISTS OF THE THREE COMPONENTS AS FURTHER DESCRIBED IN 13.C.
UP TO $120 MILLION OF THIS AMOUNT MAY BE TREATED AS A CIVIL PENALTY AT THE DISCRETION OF THE STATES AND DISTRICT OF COLUMBIA.
THE AMOUNT IS BEING DISCLOSED IN THIS SECTION 13.B INSTEAD OF IN THE BOX ABOVE AS THE EXACT AMOUNT TO BE TREATED AS A CIVIL
PENALTY IS NOT KNOWN. OTHER SANCTIONS: ADDITIONAL SERVICING AND ORIGINATION STANDARDS.
C.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement, or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived:
BANK OF AMERICA CORPORATION AND/OR ITS AFFILIATED ENTITIES SHALL PAY OR CAUSE TO BE PAID INTO AN INTEREST BEARING ESCROW
ACCOUNT TO BE ESTABLISHED FOR THIS PURPOSE THE SUM OF $2,382,415,075, WHICH SUM SHALL BE ADDED TO FUNDS BEING PAID BY OTHER
INSTITUTIONS RESOLVING CLAIMS IN THIS MATTER AND ACCORDING TO CERTAIN CRITERIA ESTABLISHED IN THE SETTLEMENT. UP TO $120
MILLION OF THIS AMOUNT MAY BE TREATED AS A CIVIL PENALTY. IN ADDITION, BANK OF AMERICA SHALL PROVIDE $7,626,200,000 OF RELIEF TO
CONSUMERS WHO MEET CERTAIN ELIGIBILITY CRITERIA RELATING TO SERVICING OF LOANS. THE ADDITIONAL SERVICING AND ORIGINATION
STANDARDS INCLUDE THE DEVELOPMENT OF NEW OR ENHANCED PROGRAMS TO PROVIDE BORROWER ASSISTANCE, THE DEVELOPMENT OF
PROPRIETARY PROGRAMS TO PROVIDE EXPANDED MORTGAGE MODIFICATION SOLUTIONS, INCLUDING THE BROADER USE OF PRINCIPAL

REDUCTIONS IF PERMITTED BY THE MORTGAGE INVESTOR, ENHANCED PROGRAMS FOR UNEMPLOYED, MILITARY SERVICE MEMBERS AND OTHER
CUSTOMERS WITH IDENTIFIED SPECIAL SITUATIONS, ENHANCED FACILITATION OF SHORT SALES, AND THE OFFER OF OTHER ASSISTANCE
PROGRAMS, SUCH AS DEED-IN-LIEU OF FORECLOSURE AND FUNDS FOR FAMILIES TRANSITIONING OUT OF HOME OWNERSHIP. ALSO, BANK OF
AMERICA SHALL PROVIDE $948,000,000 TO A NEW REFINANCING PROGRAM FOR CURRENT CONSUMERS WHO MEET OTHER ELIGIBILITY CRITERIA.
THE REFINANCING PROGRAM IS INTENDED TO EXPAND REFINANCING OPPORTUNITIES OR LOWER INTEREST RATES ON BANK OF AMERICA OWNED
MORTGAGES TO PROVIDE REDUCED PAYMENTS FOR MANY HOMEOWNERS WHO ARE CURRENT ON THEIR PAYMENTS BUT OWE MORE THAN THE
CURRENT VALUE OF THEIR HOMES. FOLLOWING FINALIZATION OF THE SETTLEMENT TERMS, BANK OF AMERICA WILL FINALIZE ITS PROGRAM
ENHANCEMENTS AND PROVIDE ADDITIONAL DETAILS OF ELIGIBILITY REQUIREMENTS.
14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must fit
within the space provided). 
BANK OF AMERICA CONSENTED TO THE ENTRY OF THE CONSENT JUDGMENT WITHOUT ADMITTING THE ALLEGATIONS IN THE COMPLAINT OTHER THAN
THOSE FACTS DEEMED NECESSARY TO JURISDICTION. THE ALLEGATIONS ARE DESCRIBED IN ITEM 7 ABOVE AND THE SANCTIONS ARE DESCRIBED IN
ITEM 13 ABOVE. BANK OF AMERICA MADE ITS PAYMENT TO THE ESCROW AGENT ON APRIL 11, 2012. THE SETTLEMENT DOES NOT RESULT IN AN
INJUNCTION OR ANY FINDINGS OF VIOLATIONS OF LAW.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Item 11.H. of Part
1A or Item 2.F. of Part 1B of Form ADV.
Civil Judicial
Check Part 1A item(s) being responded to:
11.H(1)(a)
11.H(1)(b)
11.H(1)(c)
11.H(2)
Check Part 1B item(s) being responded to:
2.F(1)
2.F(2)
2.F(3)
2.F(4)
2.F(5)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with
a completed Execution Page.
One event may result in more than one affirmative answer to Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the
same event. Unrelated civil judicial actions must be reported on separate DRPs.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
7691
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
MERRILL LYNCH, PIERCE,
FENNER & SMITH
INCORPORATED
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BANK OF AMERICA, NATIONAL
ASSOCIATION
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No

Name:
BANC OF AMERICA MORTGAGE
SECURITIES, INC.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.H.
(1)(a), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the
IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) 
SECURITIES AND EXCHANGE COMMISSION
2.
Principal Relief Sought:
Injunction
Other Relief Sought: 
DISGORGEMENT WITH PREJUDGMENT INTEREST AND CIVIL MONETARY PENALTIES
3.
Filing Date of Court Action (MM/DD/YYYY):
08/06/2013
 Exact
 Explanation
If not exact, provide explanation:
4.
Principal Product Type:
Other
Other Product Types: 
RESIDENTIAL MORTGAGE-BACKED SECURITIES
5.
Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case
Number): 
UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA, CIVIL ACTION NO. 3:13-CV-447
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 
7.
Describe the allegations related to this civil action (your response must fit within the space provided): 
SEC LITIGATION RELEASE 22772, AUGUST 7, 2013: ON AUGUST 6, 2013, THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") FILED A CIVIL
INJUNCTIVE ACTION AGAINST MERRILL LYNCH, PIERCE, FENNER & SMITH, INC. F/K/A BANC OF AMERICA SECURITIES LLC ("FIRM") AND OTHER ENTITIES
(COLLECTIVELY THE "ENTITIES"). THE COMMISSION ALLEGES THAT THE ENTITIES MADE MATERIAL MISREPRESENTATIONS AND OMISSIONS IN
CONNECTION WITH THE SALE OF RESIDENTIAL MORTGAGE-BACKED SECURITIES. SPECIFICALLY, THE COMPLAINT ALLEGES THAT THE ENTITIES FAILED
TO DISCLOSE THE DISPROPORTIONATE CONCENTRATION OF WHOLESALE LOANS (72% BY UNPAID PRINCIPAL BALANCE) UNDERLYING THE RESIDENTIAL
MORTGAGE-BACKED SECURITIES AS COMPARED TO PRIOR RESIDENTIAL MORTGAGE-BACKED SECURITIES OFFERINGS. THE COMPLAINT ALSO ALLEGES
THAT THE ENTITIES FAILED TO DISCLOSE KNOWN RISKS ASSOCIATED WITH THE HIGH CONCENTRATION OF WHOLESALE LOANS IN THE RESIDENTIAL
MORTGAGE-BACKED SECURITIES INCLUDING HIGHER LIKELIHOOD THAT THE LOANS WOULD BE SUBJECT TO MATERIAL UNDERWRITING ERRORS, BECOME
SEVERELY DELINQUENT, FAIL EARLY IN THE LIFE OF THE LOAN, OR PREPAY. THE COMPLAINT FURTHER ALLEGES THAT THE ENTITIES VIOLATED
REGULATION S-K AND SUBPART REGULATION AB OF THE SECURITIES ACT OF 1933 (THE "SECURITIES ACT") BY FAILING TO DISCLOSE THE MATERIAL
CHARACTERISTICS OF THE POOL OF LOANS UNDERLYING THE RESIDENTIAL MORTGAGE-BACKED SECURITIES. THE COMPLAINT ALSO ALLEGES THAT THE
ENTITIES MADE MATERIAL MISREPRESENTATIONS AND OMISSIONS IN ITS PUBLIC FILINGS AND IN THE LOAN TAPES IT PROVIDED TO INVESTORS AND
RATING AGENCIES THAT THE LOANS IN THE RESIDENTIAL MORTGAGE-BACKED SECURITIES COMPLIED WITH UNDERWRITING STANDARDS WHEN A
MATERIAL AMOUNT DID NOT. FINALLY, THE COMPLAINT ALLEGES THAT THE FIRM VIOLATED SECTION 5(B)(1) OF THE SECURITIES ACT BY FAILING TO FILE
WITH THE COMMISSION CERTAIN LOAN TAPES THAT IT PROVIDED ONLY TO SELECT INVESTORS. THE COMMISSION'S COMPLAINT, FILED IN THE UNITED
STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA, CHARGES THE FIRM WITH VIOLATING THE ANTIFRAUD PROVISIONS OF THE
FEDERAL SECURITIES LAWS. THE COMPLAINT ALLEGES THAT THAT THE FIRM VIOLATED SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT. THE
COMPLAINT ALSO ALLEGES THAT THE FIRM VIOLATED SECTION 5(B)(1) OF THE SECURITIES ACT. THE COMPLAINT SEEKS AGAINST THE FIRM A
PERMANENT INJUNCTION, DISGORGEMENT WITH PREJUDGMENT INTEREST AND CIVIL MONETARY PENALTIES PURSUANT SECTION 20(D) OF THE
SECURITIES ACT.

8.
Current Status? 
 Pending
 On Appeal
 Final
9.
If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 
10. If pending, date notice/process was served (MM/DD/YYYY):
 Exact
 Explanation
If not exact, provide explanation:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.
11. How was matter resolved:
Judgment Rendered
12. Resolution Date (MM/DD/YYYY): 
11/25/2014
 Exact
 Explanation
If not exact, provide explanation:
13. Resolution Detail:
A.  Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
DISGORGEMENT OF $109,220,000; PREJUDGMENT INTEREST OF $6,620,000; AND CIVIL PENALTY OF $109,220,000.
C.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement, or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived:
ON NOVEMBER 25, 2014, THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA ("DISTRICT COURT") ENTERED
A FINAL JUDGMENT ("JUDGMENT") AGAINST MLPF&S, BANK OF AMERICA, N.A. ("BANA"), AND BANC OF AMERICA MORTGAGE SECURITIES, INC.
("BOAMS") (COLLECTIVELY, THE "RESPONDENTS") THAT ENJOINED RESPONDENTS FROM VIOLATING, DIRECTLY OR INDIRECTLY, SECTIONS 17(A)(2)
AND (3) OF THE SECURITIES ACT OF 1933 ("SECURITIES ACT"), AND MLPF&S AND BOAMS FROM VIOLATING, DIRECTLY OR INDIRECTLY, SECTION
5(B)(1) OF THE SECURITIES ACT. BANA WAS NOT NAMED AS A DEFENDANT IN CONNECTION WITH THE SECTION 5(B)(1) CLAIM AND THEREFORE
DID NOT CONSENT TO ENTRY OF AN INJUNCTION UNDER THAT SECTION. ADDITIONALLY, AS STATED IN THE SEC'S PRESS RELEASE, "[A]S PART OF
THE [GLOBAL RMBS SETTLEMENT], BANK OF AMERICA AGREED TO RESOLVE THE U.S. [SECURITIES AND EXCHANGE COMMISSION'S ("SEC" OR
"COMMISSION")] ORIGINAL CASE BY PAYING DISGORGEMENT OF $109.22 MILLION, PREJUDGMENT INTEREST OF $6.62 MILLION, AND A PENALTY
OF $109.22 MILLION."
14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must fit
within the space provided). 
ON NOVEMBER 25, 2014, THE DISTRICT COURT ENTERED A FINAL JUDGMENT AGAINST THE RESPONDENTS THAT ENJOINED RESPONDENTS FROM
VIOLATING, DIRECTLY OR INDIRECTLY, SECTIONS 17(A)(2) AND (3) OF THE SECURITIES ACT OF 1933 ("SECURITIES ACT"), AND MLPF&S AND BOAMS
FROM VIOLATING, DIRECTLY OR INDIRECTLY, SECTION 5(B)(1) OF THE SECURITIES ACT. BANA WAS NOT NAMED AS A DEFENDANT IN CONNECTION WITH
THE SECTION 5(B)(1) CLAIM AND THEREFORE DID NOT CONSENT TO ENTRY OF AN INJUNCTION UNDER THAT SECTION. THE RESPONDENTS CONSENTED
TO THE ENTRY OF THE FINAL JUDGMENT WITHOUT ADMITTING OR DENYING THE ALLEGATIONS IN THE COMPLAINT. THE DISTRICT COURT RETAINED
JURISDICTION OVER THE ADMINISTRATION OF ANY DISTRIBUTION OF THE FUNDS.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Item 11.H. of Part
1A or Item 2.F. of Part 1B of Form ADV.
Civil Judicial
Check Part 1A item(s) being responded to:
11.H(1)(a)
11.H(1)(b)
11.H(1)(c)
11.H(2)
Check Part 1B item(s) being responded to:
2.F(1)
2.F(2)
2.F(3)
2.F(4)
2.F(5)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with
a completed Execution Page.

One event may result in more than one affirmative answer to Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the
same event. Unrelated civil judicial actions must be reported on separate DRPs.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BANK OF AMERICA, NATIONAL
ASSOCIATION
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
COUNTRYWIDE HOME LOANS,
INC.
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
COUNTRYWIDE BANK, FSB
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.H.
(1)(a), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the
IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) 
UNITED STATES ATTORNEY FOR THE SOUTHERN DISTRICT OF NEW YORK ("US ATTORNEY")
2.
Principal Relief Sought:
Civil Penalty(ies)/Fine(s)
Other Relief Sought: 
RESTITUTION; TREBLE DAMAGES
3.
Filing Date of Court Action (MM/DD/YYYY):

07/31/2014
 Exact
 Explanation
If not exact, provide explanation:
4.
Principal Product Type:
Other
Other Product Types: 
WHOLE LOAN SALES
5.
Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case
Number): 
U.S. DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK, CASE NO. 1:12-CV-1422-JSR
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 
7.
Describe the allegations related to this civil action (your response must fit within the space provided): 
AFTER AN INDIVIDUAL COMMENCED A QUI TAM LAWSUIT, THE U.S. ATTORNEY FILED A COMPLAINT-IN-INTERVENTION IN 2012 IN THE UNITED STATES
DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK ("COURT") AGAINST COUNTRYWIDE HOME LOANS, INC., COUNTRYWIDE BANK, FSB, BANK
OF AMERICA, N.A. AND CERTAIN AFFILIATES ("DEFENDANTS") ALLEGING THAT THE DEFENDANTS ENGAGED IN AN INTENTIONAL SCHEME TO
MISREPRESENT THE QUALITY OF THE MORTGAGE LOANS THAT IT PROCESSED THROUGH A PARTICULAR LOAN ORIGINATION PROGRAM AND SOLD TO
FANNIE MAE AND FREDDIE MAC DURING AUGUST 2007 TO MAY 2008. THE COMPLAINT SOUGHT TO RECOVER TREBLE DAMAGES AND PENALTIES UNDER
THE FALSE CLAIMS ACT, 31 U.S.C. § 3729 ET. SEQ. ("FCA") AND CIVIL PENALTIES UNDER THE FINANCIAL INSTITUTIONS REFORM, RECOVERY, AND
ENFORCEMENT ACT, 12 U.S.C. § 1833A ("FIRREA").
8.
Current Status? 
 Pending
 On Appeal
 Final
9.
If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 
10. If pending, date notice/process was served (MM/DD/YYYY):
 Exact
 Explanation
If not exact, provide explanation:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.
11. How was matter resolved:
Judgment Rendered
12. Resolution Date (MM/DD/YYYY): 
07/31/2014
 Exact
 Explanation
If not exact, provide explanation:
13. Resolution Detail:
A.  Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $ 1,267,491,770.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
C.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement, or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived:
IN 2013, THE COURT GRANTED THE DEFENDANT'S MOTION TO DISMISS THE CLAIM FOR TREBLE DAMAGES AND PENALTIES UNDER THE FCA. LATER
IN 2013, A JURY FOUND COUNTRYWIDE HOME LOANS, INC. AND COUNTRYWIDE BANK, FSB AND ITS SUCCESSOR IN INTEREST, BANK OF AMERICA,
N.A. (COLLECTIVELY, THE "BANK DEFENDANTS") CIVILLY LIABLE FOR VIOLATING FIRREA. ON JULY 30, 2014, THE COURT ENTERED ITS OPINION
AND ORDER DIRECTING THE CLERK OF THE COURT TO ENTER A JUDGMENT DIRECTING BANK OF AMERICA, N.A., ON BEHALF OF THE BANK
DEFENDANTS, TO PAY THE SUM OF $1,267,491,770. ON JULY 31, 2014, THE CLERK OF THE COURT ENTERED A JUDGMENT. THE BANK DEFENDANTS
POSTED A BOND ON AUGUST 22, 2014. THE BANK DEFENDANTS ARE IN THE PROCESS OF FILING APPEAL DOCUMENTS.
14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must fit
within the space provided). 
THE ACTIONS, ALLEGATIONS, DISPOSITION, AND FINDINGS OF THIS MATTER ARE DESCRIBED IN ITEMS 7 AND 13 ABOVE.