Public Comment Dividend Requirements and One Time Assessment Credit Bank of America

Bank of America Carporation Legal Department NC1-002-294 1 101 South Tryon Stmt Charlotte. NC 28255 Td 704.386-6834 Fax 704-602-5785 BY ELECTRONIC MAIL August 2,2006 Mr. Robert E. Feldman, Executive Secretary Federal Deposit Tnsurance Corporation 550 17" Street, N.W. Washington, DC 20429 Attn: RIN 3064-AD07 and RrSd 3064-AD08; c~mments!&fdicC~o~~ Proposed Renulations Imwlementinrr Federal Deposit Insurance Reform Act of 2005 Re: Dear Madams and Sirs: Bank of America Corporation ("Bank of America") appreciates the opportunity to comment to the Federal Deposit Insurance Corporation (the 'TFDTC') regarding the FDIC's proposed regulations implementing the Federal Deposit Insurance Refom Act of 2005 (the "Reform Act"). Bttllk of America, with over $1.3 trillion in total assets, operates the largest banking network in the United States, with fill-service consumer and commercial operations in 30 states and the District of Columbia. Bank of America provides financial products and sewices to over 33 million households representing one out of three households within its franchise as well as two rniIIion businesses, and provides international corporate financial services for clients around the world. Bank of America supports the efforts of the FDIC and its proposed regulations to implement the Reform Act. Bank of America would specifically like to express support for the FDIC's proposed methodology for defining ~redecessof' and 'kuccessor" banks for ...